AACP Brief
Regarding Reimagining and Improving Student Education (RISE) Final Rule
June 2, 2026
Issue
The U.S. Department of Education’s Reimagining and Improving Student Education (RISE) Final Rule introduces sweeping changes to federal student loan programs, including new loan limits, the elimination of Graduate PLUS loans, and simplified repayment structures. These changes—effective July 1, 2026—will significantly impact students pursuing pharmacy education and the schools that educate student pharmacists.
Recommendation
AACP urges policymakers and partners to:
- Monitor and evaluate the impact of federal loan caps on access to health professions education
- Ensure adequate financing options for high-cost professional programs such as the Pharm.D.
- Engage interested parties, including AACP, to assess unintended consequences on workforce development
Current Law
The Department of Education published the RISE final rule (announced April 30, 2026) based on authority granted by the Working Families Tax Cuts Act (also referred to as the One Big Beautiful Bill Act; Public Law 119-21), signed into law on July 4, 2025, which enacted significant statutory changes to Title IV of the Higher Education Act of 1965. The regulations, effective July 1, 2026, modify Federal Direct Loan borrowing limits, repayment plan options, and borrower eligibility requirements for students participating in Title IV federal student aid programs.
Background
On May 1, 2026, the Department of Education released the RISE Final Rule to implement higher education reforms authorized under the Working Families Tax Cuts Act. The rule aims to lower college costs, curb excessive borrowing, and simplify repayment options. The rule represents one of the most significant restructurings of federal student lending in decades.
Key Policy Changes
- Professional Degree Classification
- The Doctor of Pharmacy (Pharm.D.) is explicitly recognized as a “professional degree.”
- Pharm.D. students qualify for higher federal loan limits than non-professional graduate programs.
- New Loan Limits [Beginning July 1, 2026]
- Professional Students (e.g., Pharm.D.):
- $50,000 annually
- $200,000 aggregate
- Graduate (non-professional)
- $20,500 annually
- $100,000 aggregate
- Lifetime cap (all loans): $257,500
- Professional Students (e.g., Pharm.D.):
- Elimination of Graduate PLUS Loans
- Graduate and professional students will no longer be able to borrow up to the full cost of attendance through PLUS loans.
- Simplified Repayment System
- Replacement of multiple income-driven repayment plans with:
- Tiered Standard Plan
- Repayment Assistance Plan (RAP)
- Replacement of multiple income-driven repayment plans with:
- Institutional Flexibility
- Institutions may set lower borrowing limits for specific programs and must ensure clear communication to students.
Relevant AACP Policies
- AACP supports and encourages the implementation of on-going program assessment processes at member institutions for the purpose of enhancing the quality of educational programs and student services. (Source: Academic Affairs Committee, 2004)
- AACP encourages colleges and schools of pharmacy to support and maintain adequate staffing to sustain all necessary administrative functions, including but not limited to: curricula; student affairs; experiential education; academic services; assessment; research; and accreditation activities. (Source: Administrative Services Section, 2018–19)
Strategies for AACP and Schools/Colleges of Pharmacy
Student Access, Affordability, and Institutional Financial Support
The RISE final rule introduces new federal borrowing caps that may create financing gaps for student pharmacists, particularly at institutions where the total cost of attendance exceeds the new annual and aggregate loan limits. The elimination of Graduate PLUS Loans for new borrowers may further increase affordability concerns for students pursuing a Pharm.D. degree.
Schools and colleges of pharmacy may need to:
- Evaluate tuition and financial aid strategies
- Expand institutional aid, scholarships, and support mechanisms
- Enhance financial literacy and debt counseling services
- Develop communication strategies and FAQs for prospective and current students regarding changes to borrowing and repayment options
Pharmacy Enrollment and Workforce Pipeline
Reduced borrowing flexibility could influence application patterns, enrollment decisions, and workforce pipeline development across academic pharmacy. Institutions may experience increased pressure to demonstrate the long-term value proposition of pharmacy education amid heightened student debt sensitivity. Member institutions should consider:
- Monitoring enrollment and student demographic trends
- Evaluating the impact of borrowing changes on recruitment and retention
- Strengthening messaging around career outcomes, workforce demand, and the value of pharmacy education
Financial Aid, Administrative, and Compliance Readiness
The implementation of the RISE final rule will require substantial operational and administrative preparation prior to the July 1, 2026, effective date. Institutions may need to:
- Conduct gap analyses across financial aid, curriculum, and student services
- Update financial aid packaging and loan counseling practices
- Modify institutional systems to distinguish between graduate and professional student classifications.
- Implement updated reporting and borrower eligibility requirements
- Train faculty, financial aid personnel, admissions teams, and student affairs staff on regulatory changes and student advising implications
- Coordinate with accreditors and partner organizations to encourage information exchanges.
- Educate decision makers on adjustments to federal loan limits for high-cost health professions
Institutional Planning and Long-Term Strategy
The RISE final rule may place additional pressure on institutions to reassess educational cost structures, program sustainability, and student support models. Schools and colleges of pharmacy may increasingly need to evaluate:
- Tuition and cost-containment strategies
- Program length and curricular efficiency
- Experiential and interprofessional education models
- Alternative funding partnerships and workforce pipeline initiatives (e.g., scholarships, private loans, working while in school)
Conclusion
The RISE final rule represents a major federal policy shift that will reshape how pharmacy education is financed. While the Pharm.D. retains its designation as a professional degree eligible for higher borrowing limits, new caps and the elimination of Graduate PLUS loans introduce significant challenges for institutions and students. Proactive planning, coordinated advocacy, and institutional innovation will be essential to maintain access, affordability, and the future pharmacy workforce.
References/Resources
U.S. Department of Education. Reimagining and Improving Student Education (RISE) Final Rule, Federal Register (May 1, 2026)
U.S. Department of Education. Press Release: Finalizes Landmark Rule to Lower College Costs and Simplify Student Loan Repayment (April 30, 2026)
U.S. Department of Education. RISE Final Rule Fact Sheet (2026)
Contact Information
For more information, contact:
Olunife Akinmolayan
AACP Director of Policy, Advocacy, and Strategic Engagement
Oakinmolayan@aacp.org
202-631-4773
Information contained in this brief is for the general education and knowledge of our readers. It is not designed to be and should not be used as the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. If you have specific questions regarding a particular fact situation, we urge you to consult competent legal counsel.