Public Comment Period Open on Proposed Rulemaking to Amend Federal Student Loan Programs

On January 29, 2026, the U.S. Department of Education published a notice of proposed rulemaking (NPRM) to amend regulations for federal student loan programs based on the recent enactment of HR 1 (P.L. 1119-21), sometimes referred to as the “One Big Beautiful Bill Act” (the “Reconciliation Act”). The Department established two negotiated rulemaking committees for the implementation of the Reconciliation Act. The first committee, the Reimagining and Improving Student Education (RISE) Committee, reached consensus on November 6, 2025, on the entire package of loan-related changes, including federal student-loan limits, repayment plans and the elimination of the Graduate/Professional PLUS Loan program.

Read the full Alert on the Duane Morris LLP website.

Department of Education Narrows PPA Owner-Signature Enforcement but Leaves Core Statutory Issue Unresolved

On January 16, 2026, the U.S. Department of Education issued an Electronic Announcement, “Program Participation Agreement Signature Requirements” (GEN-26-04), addressing the general circumstances under which an owner-entity of a Title IV-eligible institution may be required to sign a program participation agreement (PPA) under Section 498 of the Higher Education Act (HEA), codified at 20 U.S.C. § 1099c. The announcement was issued in connection with the Department’s settlement of litigation in Hannibal-LaGrange University v. U.S. Department of Education, 2:25-cv-00042 (E.D. Mo. 2025), which challenged the legality of the Department’s 2023 amendment to 34 C.F.R. § 668.14(a)(3)(ii).

Read the full Alert on the Duane Morris LLP website.

Department of Education Plans Enhancements to E-App System

By Katherine Brodie, Daniel Walworth and Matthew Steinway

On November 26, 2025, the U.S. Department of Education released an electronic announcement that describes planned enhancements to the electronic application for approval to participate in the Federal Student Financial Assistance Programs (E-App) on December 7, 2025. The E-App is part of the Department’s Federal Student Aid Partner Connect platform utilized by institutions participating in Title IV, Higher Education Act, programs to update or report eligibility information.

In addition to general improvements to the user experience throughout the E-App, the Department noted two significant platform changes that will require attention from institutions of higher education. The Department stated that it will provide guidance in early December to help its users better understand the changes.

Read the full Alert on the Duane Morris LLP website.

Webinar: Workforce Pell: Equipping Colleges for the Tools of the Trade

Duane Morris will present a webinar, Workforce Pell: Equipping Colleges for the Tools of the Trade, on Thursday, October 23, 2025 | 1:00 p.m. to 2:00 p.m. Eastern.

REGISTER

About the Program

The Workforce Pell provisions of the “One Big Beautiful Bill” offer colleges with short-term, workforce-focused programs the opportunity to provide students access to Workforce Pell for the first time. The new program is scheduled to launch in the 2026-2027 award year but will be subject to the rulemaking process of the Department of Education. Colleges should start preparing now so that their students will have the best chance at being the first to access the program when it launches. Join Duane Morris’ Higher Education Group members Kristina Gill and Edward Cramp as they provide pragmatic, action-oriented guidance to help your institution prepare.

Best Practices When Responding to DOE Investigations

In recent days, the Department of Education has announced two sets of investigations stemming from the administration’s application of the U.S. Supreme Court’s 2023 decision in Students for Fair Admissions v. Harvard. The announced investigations are focused on institutional compliance within the context of the Supreme Court opinion and subsequent guidance from the Department of Education in the February 14, 2025, “Dear Colleague Letter.” Read the full Alert on the Duane Morris website.

EdUp Legal Podcast: The Latest on DOE Regulations

Tony Guida, Duane Morris partner and Team Lead of the Education Industry Group, is featured in the EdUp Legal podcast.

In the episode,  Tony discussed the Department of Education’s most recent suite of regulations impacting institutions’ participation in the Title IV program, specifically with respect to certification, financial responsibility and administrative capability.

Listen to the EdUp Legal podcast, hosted by Deborah Solmor.

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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