The Department of Education is proposing a federal rule that could significantly change how future occupational therapists finance their education by changing graduate student loan caps.
And right now, you can influence it by submitting a public comment!
Public comments are due March 2, 2026 at 11:59 PM Eastern.
- AOTA overview and instructions for submitting a comment letter
- AOTA Background article on student loan changes
- Department of Ed proposed rule
- Submitted comments mentioning OT (for your inspiration)
Submitting a comment is one of the most direct ways clinicians, students, educators, and advocates can shape national policy. Federal agencies are legally required to review and respond to substantive comments before finalizing a rule. So, your comments can actually influence regulatory language and how it impacts future OT students.
This is not symbolic advocacy.
This is regulatory advocacy.
So, get together with your SOTA, faculty team, friends, family, and coworkers, and start submitting your comments ASAP!
How are graduate student loan caps changing?
The Department of Education is proposing new federal loan caps for graduate students that would:
- Limit borrowing to $20,500 per year
- Cap total lifetime borrowing at $100,000
- Phase out the Graduate PLUS loan program
Currently, many OT students rely on Graduate PLUS loans to cover the remaining cost of attendance after Direct Unsubsidized Loans.
Join the Amplify OT Learning Platform today to gain immediate access to on-demand lessons and webinars to help you see the opportunities for OT in healthcare. Join us at amplifyot.com/membership today!
Why This Matters for Occupational Therapy
Most OT programs cost approximately $80,000–$160,000, and many doctoral programs approach $200,000 total cost of attendance.
Meanwhile:
- Most OT graduates leave school with more than $80,000 in student loan debt
- A significant portion carry $140,000–$250,000 or more
A $100,000 lifetime borrowing cap may fall below the total cost required to complete an accredited OT program. Read this OT Practice Article to learn more about OT student loan impact.
If that gap widens, students may be forced to:
- Take private loans (with fewer borrower protections)
- Have substantial personal financial support
- Delay or abandon entry into the profession
This is not just a student issue.
It is a workforce access issue.
Healthcare workforce pipelines begin with education financing policy. Change the financing structure, and you change who can realistically enter the profession.
Important Clarification: This Rule Does NOT Set Tuition
Many people understandably respond, “Schools should lower tuition.”
That is a valid and necessary conversation.
However, this specific rule does not regulate tuition rates. The Department of Education cannot set what universities charge through this rulemaking process. It only determines federal borrowing limits under Title IV of the Higher Education Act.
Advocacy about tuition belongs in accreditation standards, state funding policy, and institutional governance discussions.
This comment letter should stay focused on what the agency can control: how federal loan caps affect access to accredited OT education and the healthcare workforce.
Keeping comments relevant to agency authority makes them far more impactful.
Ad Break: Thanks for Supporting Amplify OT!
This is an affiliate link for Medbridge. Using our code gives you the best price and supports the content you love on Amplify OT!
How to Write an Effective Comment Letter for graduate student loan caps
A strong public comment is:
- Relevant to the proposed rule
- Grounded in evidence
- Profession-specific
- Clear in its requested action
Step 1: Introduce Yourself
Briefly explain who you are and your connection to occupational therapy (student, clinician, educator, employer, etc.).
Step 2: Clearly State Your Position
State what change you are requesting. For example:
- Inclusion of OT programs in the definition of “Professional Degrees” eligible for higher borrowing limits
- Reconsideration of the lifetime cap in light of healthcare workforce needs
Step 3: Provide Policy-Based Rationale
Stories are great – now it’s time to tie them into the bigger picture. Consider how the proposed policy changes will have far-reaching effects by discussing:
- Healthcare workforce shortages
- Rural access gaps
- Aging population demand
- Interdisciplinary healthcare workforce equity
- Return on federal investment in healthcare education
Step 4: Include Personal Impact
If these caps would have affected your ability to become an OT, explain how. Personal narratives strengthen regulatory comments when paired with policy reasoning. What would it mean for you if you couldn’t become an OT? How would it have impacted your life?
If you’re on faculty, how might these changes impact your program and students? Will it risk lowering student applications and the sustainability of your program?
Note: If you’re writing with a group, avoid copying identical templates. Individualized, well-reasoned comments carry greater weight!
Step 5: Make a Clear Request
End with a direct, concise statement of what you want the Department to change. We are requesting that the Department of Education’s definition of “Professional Degrees” be expanded to include Occupational Therapy programs.
Recommended products
-
OT Adult Rehab Guide
Price range: $19.00 through $22.00 -
I’m an OT Amplifier Occupational Therapy Shirt
$29.00 -
Occupational Therapy Level II Fieldwork Planner
Price range: $29.00 through $64.00
Using AI to Strengthen Your Comment
You can use generative AI tools to refine your draft. These tools are helpful for refining your argument when you have a lot to say, but want it to be shorter and clearer. Just open a new chat, paste your comment draft, and use a structured prompt like the one below. Please feel free to copy and paste this one or adjust it to fit your letter.
“I am submitting a formal public comment to the U.S. Department of Education regarding the proposed rule ‘Reimagining and Improving Student Education.’
The rule proposes new loan limits for graduate and professional students and phases out the Graduate PLUS program. Occupational Therapy programs are currently categorized as graduate degrees rather than professional degrees, making them ineligible for higher loan limits.
My goal is to advocate for Occupational Therapy programs to be included in the definition of Professional Degrees so OT students remain eligible for appropriate federal loan limits.
Please:
- Identify weaknesses in my argument
- Strengthen the policy reasoning
- Improve clarity and organization
- Flag unsupported claims
- Suggest one additional persuasive angle
Keep the tone professional and focused on workforce and access-to-care impacts.”
Frequently Asked Questions
What are the new proposed federal loan limits?
The proposed rule would cap Direct Unsubsidized Loans at $20,500 per year and $100,000 lifetime for most graduate students. The Graduate PLUS loan program would be eliminated.
Will Graduate PLUS loans be eliminated?
Yes, under the proposal, Graduate PLUS loans would be phased out for most graduate students. This removes the ability to borrow up to full cost of attendance using federal loans.
Does this rule change tuition rates?
No. The Department of Education does not set tuition. The rule only governs federal borrowing limits.
How does this proposal change student loan repayment programs?
The same rule restructures income-driven repayment (IDR) plans.
It proposes consolidating existing repayment options into a new primary income-based repayment structure. Key shifts may include:
- Fewer repayment plan options
- Stricter qualifying payment definitions
- Reduced flexibility during deferment and forbearance
- Greater emphasis on continuous qualifying payments
Borrowers may need to make consistent monthly payments without interruption to maintain progress toward forgiveness.
Does this eliminate Public Service Loan Forgiveness (PSLF)?
No. PSLF is not eliminated.
However, the proposed repayment restructuring may affect:
- How qualifying payments are counted
- Whether months in certain deferments or forbearances qualify
- How income-driven repayment plans interact with PSLF eligibility
In practical terms, repayment flexibility may decrease, and missed or paused months may not count toward the required 120 qualifying payments.
For healthcare professionals working in nonprofit hospitals, schools, and community settings, these details matter.
Who would be most affected?
- Students without significant financial support
- First-generation college students
- Students entering lower-paying public service roles
- Rural and underserved communities relying on workforce pipelines
Why does this matter for patients?
If fewer students can afford OT education, workforce shortages may worsen. Reduced workforce supply can limit access to rehabilitation services, particularly in rural, school-based, and community health settings.
When are comments due?
Public comments must be submitted by March 2, 2026 at 11:59 PM Eastern.
Advocacy does not always look like a rally or a meeting.
Sometimes it looks like a well-written, evidence-based public comment that shapes federal policy.
This is one of those moments.
Ad Break: Thanks for Supporting Amplify OT!
This is an affiliate link for Medbridge. Using our code gives you the best price and supports the content you love on Amplify OT!
Join the Amplify OT Learning Platform today to gain immediate access to on-demand lessons and webinars to help you see the opportunities for OT in healthcare. Join us at amplifyot.com/membership today!
