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ProPEL Act Now: Comment on Proposed Student Loan Limits by March 2, 2026
PROFESSIONAL DEGREES & STUDENT LOANS
Comment on Proposed Student Loan Limits by March 2
The U.S. Department of Education (ED) has finalized a Notice of Proposed Rulemaking codifying professional degrees and eliminating Graduate PLUS loans as a result of the federal One Big Beautiful Bill Act (OBBBA). ACSA is encouraging our members to provide comments on the impact of this rule by the end of the public comment period on Monday, March 2nd, 2026. Comments can be made in 10 minutes or less and should include the phrase “architectural education” so that we might measure our impact. (Please see below for more background on the policy changes.)
ACSA will comment on behalf of the organization and our members, advocating for NAAB-accredited architecture degrees to be recognized as professional degrees and to stop the elimination of Graduate PLUS loans. We are working with AIA, NOMA, AIAS, NCARB, and NAAB to coordinate our organizational and member response. We are also in contact with our counterparts in planning, interior design, and landscape architecture.
Proposed Policy Curbs Access to Student Loans
Limits on borrowing will make access to architectural education more difficult, driving students to private lending options with higher interest rates and restrictive repayment terms. Both the exclusion of architecture among professional degrees and the elimination of Graduate PLUS loans would have this effect.
The proposed change defines “professional students” and “graduate students” differently. Professional students would be eligible for up to $200,000 total in federal student loans for graduate education, while other graduate students are limited to $100,000 total. (These limits exclude undergraduate loans.) Architecture is not included in the list of eligible professional degrees, along with other licensed professions, including engineering, nursing, and social work, among others. Moreover, the policy would completely eliminate Graduate PLUS loans that allow students to use federal loans to meet the total cost of attendance, including room and board, books and supplies, and student health plans.
Although these policy changes do not jeopardize architecture’s status as a licensed profession, ACSA is extremely concerned about the effects that the ED’s interpretation of the law will have on architectural education and practice. Just over two-thirds (68%) of professional architecture programs are graduate degree programs, i.e., M.Arch. and D.Arch., accounting for over 14,000 students. ACSA views access to student loans as essential to all students, particularly those historically underrepresented in the profession.
More information on the legislative impacts of the OBBBA is available on an explanatory webpage published by ACSA or by viewing our recent webinar on this topic.
About the Association of Collegiate Schools in Architecture (ACSA)
The mission of the Association of Collegiate Schools of Architecture is to lead architectural education and research. Founded in 1912 by 10 charter members, ACSA is an international association of architecture schools preparing future architects, designers, and change agents. ACSA’s full members include all of the accredited professional degree programs in the United States and Canada, as well as international schools and 2- and 4-year programs. Together, ACSA schools represent 7,000 faculty educating more than 40,000 students.
ACSA seeks to empower faculty and schools to educate increasingly diverse students, expand disciplinary impacts, and create knowledge for the advancement of architecture. For more information, visit www.acsa-arch.org.
Questions
Kendall A. Nicholson
Senior Director of Research, Equity, and Education
202-785-2324
knicholson@acsa-arch.org
