OBBA Heads to Implementation

News

Published on : December 4, 2025

OBBA Heads to Implementation: What's at Stake for Social Work Students?

Despite the government shutdown, ED continued to hold the negotiated rulemaking for the Reimagining and Improving Student Education (RISE) Committee.

ED began its 2025 negotiated rulemaking process to implement major Title IV changes that were made to student financial assistance programs under Title IV through the passage of the One Big Beautiful Bill Act that was signed into law on July 4, 2025.

ED’s initial framework proposed that a professional degree should reflect “completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor's degree” as well as a four-digit Classification of Instructional Programs (CIP) code, and a requirement for professional licensure. By the end of the negotiations, the definition that was reached excluded social work among the 18 degrees categorized as “professional.”

As such, graduate social work students are classified as graduate students, meaning that they will face an aggregate federal student loan cap of $100,000 with an annual limit of $20,500, while professional students will have a $200,000 aggregate limit and a $50,000 annual cap. ED plans to implement this change by July 1, 2026.

CSWE's Advocacy Actions Related to Negotiated Rulemaking

  • Submitted formal comments to ED
  • Testified during ED listening sessions
  • Partnered with FASHP to urge the use of Health Professions CIP codes
  • Engaged congressional champions
    • Rep. Bonnie Watson-Coleman (D-NJ)
    • Rep. Hillary Scholten (D-MI)
    • Sen. John Hickenlooper (D-CO)
    • Rep. Sylvia Garcia (D-TX)
    • Rep. Diana DeGette (D-CO)
    • Sen. Alex Padilla (D-CA)
  • Coordinated with member institutions to gather data and impact statements
  • Communicated concerns in public statements
  • Responded to ED's new proposed definition of a "professional" degree


As the public comment period following ED's decisions opens in late 2025 and early 2026, CSWE will continue advocating tirelessly on behalf of the social work education community and will provide ongoing updates.