PEER Center Comments on Reconciliation Rulemaking
Stephanie Cellini, Jordan Matsudaira, Clare McCann
August 2025
In August 2025, the PEER Center submitted comments to the Education Department on its upcoming rulemaking to implement a new law that will significantly alter the higher education landscape. In the comments, among other recommendations, we urge the Administration to:
- Provide radically improved transparency to students and policymakers on the costs and value of higher education programs by maintaining the financial value transparency rules;
-
Protect students and taxpayers by ensuring that federal dollars do not go to perpetually low-value programs that fail to meet the gainful employment standards;
-
Assess eligibility for Workforce Pell prior to extending federal dollars to programs, and ensure the use of high-quality data in doing so;
-
Limit administrative burden for, and provide clarity to, borrowers in implementing changes to student loan repayment plans; and
-
Anticipate significant impacts of new graduate loan limits, including by adopting a careful, data-driven approach to defining the types of graduate programs eligible for higher annual and aggregate limits.