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Protect OT education: Submit comments on new loan caps

Abe Saffer, Federal Affairs

Submit comments by March 2, 2026

Why your voice matters

After H.R. 1, more commonly known as the One Big Beautiful Bill Act (OBBBA), was signed into law, the Department of Education ED began the process of implementing the changes the legislation made to federal student loan programs. The bill eliminated the Grad PLUS loan program for graduate students and established new loan caps for graduate students receiving loans through the Federal Direct Unsubsidized Loan Program, the sole remaining federal loan program for graduate education. For more information on these changes, please read our earlier article. Under the new structure, most graduate students will only be able to borrow $20,500 per year, up to a lifetime total of $100,000. However, students enrolled in programs classified as “professional degree programs” may be able to borrow up to $50,000 per year, with a lifetime limit of $200,000.

While Congress seemingly intended the list of graduate programs classified as “professional degree programs” to be broad, ED has issued a proposed rule that includes only 11 professions in this classification. Occupational therapy, along with multiple other health professions, was left off the list of “professional programs” and will be subject to the lower cap if this proposed rule is finalized as currently written. The exclusion of occupational therapy from this list is disappointing but expected, based on earlier actions by ED.

During the rulemaking process, federal agencies, such as ED, are required to solicit and review all comments submitted on the proposed rule. A large volume of thoughtful, personalized comments demonstrates widespread concern, creates a stronger administrative record, and strengthens future legislative and legal advocacy efforts, all of which increase the likelihood ED will revise the rule.

How to submit a comment on the Proposed Rule

Comments are due by March 2nd, 2026, 11:59 pm Eastern.

Form letters are helpful; however, in the proposed rule, ED stated that form letters will be counted as a single submission. Therefore, personalized letters have a significantly greater impact. When you explain how this rule affects you, your students, your clients, or your community, it becomes much harder to ignore. We encourage you to include as much of your personal story as you’re willing to share, as well as some or all of the suggested points you wish to include.

Step-by-step instructions to submit comments

Step 1: Draft your letter

Items to consider including:

  1. Who you are: State your role (student, practitioner, educator, employer, etc.) and your connection to occupational therapy. If you’re able to submit comments on behalf of your company, program, or staff, having the letter on official letterhead or signed by multiple people adds weight to your effort.
  2. Why this rule matters to you: Explain how lower loan caps would affect access to OT education, workforce supply, rural communities, or patient care.
  3. The personal touch: Personal stories are powerful. If you relied on federal loans, supervise students who do, or serve high-need populations, feel free to say so.
  4. Request a specific action: Ask the Department to include occupational therapy in the regulatory definition of a professional degree program.

Suggested points (please make these your own):

  • A graduate degree is required to become a licensed occupational therapist.
  • Graduation from an accredited OT program is required for both NBCOT certification and state licensure for individuals educated in the US.
  • Lower loan caps will reduce access to OT education and worsen workforce shortages, ultimately leaving people unable to access OT services.
  • Rural and underserved communities will be disproportionately affected.
  • Federal policy should strengthen healthcare workforce pipelines, not restrict them.

Step 2: Find the letter submission portal

  1. Comments can be submitted online here: https://www.regulations.gov/document/ED-2025-OPE-0944-0001.
  2. You can also go to regulations.gov and search for ED-2025-OPE-0944-0001.
    • The proposed rule is called “Reimagining and Improving Student Education.”

Step 3: Submit your letter

  1. Do not include contact information in the text of the letter. You will be able to provide that during the submission process.
  2. Convert your letter into a PDF.
  3. Click on the blue “Comment” button in the header of the page.
  4. Fill out the form and upload your letter.
  5. Click on the blue “Submit Comment” button.

Important items

Comments are due by 11:59 Eastern on March 2nd, 2026. ED will not review letters received after the deadline.

  • You will receive a confirmation email once you submit your comments.
  • There will likely be a high volume of letters submitted on the day of the deadline, so getting them in early will ensure your voice is heard.
  • If you have any questions, reach out to AOTA’s federal affairs team at askfad@aota.org.

The bottom line

Every individual comment strengthens the record. When policymakers see students, practitioners, educators, and patients speaking in their own voices, it changes the conversation. Feel free to share this with friends and family who aren’t practitioners and encourage them to personalize it with their own experiences.

Letters from a range of people demonstrate the real-world impact and show that this issue is not abstract. It affects real people and real communities. If the classification of occupational therapy education is not corrected in this rule, the consequences will be long-term. Your voice can help ensure that does not happen.

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