ARLINGTON, Va., Feb. 26, 2026 /PRNewswire/ — The American Academy of Physician Associates (AAPA), representing approximately the nation’s 190,000 physician associates/physician assistants (PAs), formally submitted public comments to the U.S. Department of Education opposing its proposed federal student loan rule under the Reimagining and Improving Student Education (RISE) framework.
AAPA’s public comments explain that, “Public Law 119-21 does not delegate discretion to the Department to redefine or narrow the term ‘professional degree’ … Any additional criteria imposed through rulemaking exceed the Department’s statutory authority and undermines Congressional intent.”
The Department’s narrow definition improperly excludes PA programs from the higher federal loan limits Congress intended for professional students. AAPA’s comments detail how the proposed rule imposes new eligibility criteria not found in the statute or the incorporated regulation and inappropriately relies on how the profession is regulated at the state level as a basis for exclusion.
“The statute is clear,” said AAPA President and Chair of the Board Todd Pickard, DMSc, PA-C, DFAAPA, FASCO said. “Congress defined ‘professional degree’ by citing an existing regulation, and PA programs meet that definition. The Department does not have the authority to rewrite that definition through rulemaking — full stop.”
Under H.R. 1, Congress clearly incorporated the existing regulatory definition of “professional degree” at 34 C.F.R. § 668.2. PA programs meet that definition which requires graduate-level education, completion of rigorous clinical training, and mandatory professional licensure to practice medicine.
If finalized as written, the proposed rule would place PA students in the lower “graduate” borrowing tier, limiting federal loans to just $20,500 per year instead of the $50,000 annual limit available to professional students. That cap falls dramatically short of the actual cost of PA education. Median tuition alone exceeds $96,900 for in-state students and $101,229 for non-residents, and total cost of attendance often surpasses $200,000, often because many programs have limitations on allowing students to work while in PA school due to the rigor and intensity of these programs.
AAPA’s public comments emphasize that the consequences would extend far beyond individual students. The gap between allowable federal borrowing and real-world costs could leave many students with no viable option other than high-interest private loans to complete their training.
“This rule doesn’t just affect how students will finance their education; it directly affects patients,” said Pickard. “If this proposed rule moves forward, it will push students toward higher-cost private loans, increase long-term repayment burdens, and ultimately raise healthcare costs. Most importantly, it will shrink the pipeline of future PAs at a time of historic workforce shortages.”
According to a recent AAPA survey, 84% of PA students and aspiring PAs say the proposal would decrease the number of applicants to PA school. Most concerning, more than a third (37%) of current PAs and PA students reported that they would have changed career plans entirely and not pursued healthcare if this cap was finalized at the time they were considering the PA profession.
PAs are critical to meeting healthcare workforce demands. Employment of PAs is projected to grow more than 20% over the next decade, outpacing the average for all occupations by more than six times. One-third of PA students report planning to work in rural communities, and nearly half intend to practice in medically underserved areas.
“Excluding PAs from the professional tier undermines federal efforts to strengthen rural health and expand access to care,” said AAPA Chief Executive Officer Lisa M. Gables. “At a time when the Administration is focused on workforce development and lowering healthcare costs, this proposal moves in the opposite direction. We are hopeful the Department will take this opportunity to align with the rest of Administration and bring the rule into alignment with Congressional intent.”
About the American Academy of Physician Associates (AAPA)
AAPA is the national membership organization for all physician associates/assistants (PAs). PAs are licensed clinicians who practice medicine in every specialty and setting. Trusted, rigorously educated and trained healthcare professionals, PAs are dedicated to expanding access to care and transforming health and wellness through patient-centered, team-based medical practice. Learn more about the profession at aapa.org and engage through Facebook, LinkedIn, Instagram, and X.
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SOURCE American Academy of Physician Associates
