Trapped by Design: The Student Loan Rewrite

You’re invited to speak. Just don’t expect anyone to listen.

Let’s not sugarcoat this.

The Trump administration has officially launched the student loan rulemaking process under the One Big Beautiful Bill (OBBB). And while the Department of Education is opening up the microphones and eComment boxes for your input, let’s be honest—this whole thing feels like kabuki theater.

You’re being invited to participate in a process that’s already scripted.

You can comment. You can testify. You can even apply to sit at the negotiating table.

But—and here’s the kicker—even if you’re selected to be a “negotiator” on the student loan committee, you are not allowed to dissent from the final proposed rules.

Yes, you read that right. You can be on the committee and still be forced to nod along silently when things go south.


🚨 The Trojan Horse of Public Participation

According to the official Federal Register notice, the Department will establish two negotiated rulemaking committees:

  • RISE Committee – Focused on federal student loan changes
  • AHEAD Committee – Focused on Pell Grants and program accountability

They’ve outlined a virtual hearing for August 7 and are asking for public comments through Regulations.gov, under Docket ID ED-2025-0151.

But here’s what they’re not shouting from the rooftops:

Committee members must work toward consensus and may not dissent from the proposed regulations.

In other words, even if someone at the table says, “This proposal will devastate low-income borrowers,” they’re expected to fall in line if the majority votes to move forward.

Let that sink in. The system is designed to look collaborative while muzzling anyone who might raise real objections. It’s a mock trial with a predetermined verdict.


🧨 What’s Actually Being Negotiated?

If you thought this was just a routine update, think again. Here’s what the Trump administration is putting on the table under the RISE Committee:

  1. Phase-out of Graduate and Parent PLUS Loans
  2. New annual and lifetime borrowing caps for students and parents
  3. Elimination of the Income-Contingent Repayment (ICR) plan
  4. Streamlined repayment: One standard + one income-based Repayment Assistance Plan (RAP)
  5. Severe limits on forbearance, deferment, and rehabilitation
  6. Letting schools lower loan limits for programs they don’t see as “worth it”

Meanwhile, the AHEAD Committee is proposing:

  • Loss of Direct Loan eligibility for programs with low earnings outcomes (2 out of 3 years)
  • A new Workforce Pell Grant for short-term job training
  • Exclusions from Pell for students with high family resources or full scholarships

This isn’t tinkering. This is a teardown.


😠 The “Consensus-Only” Rule Should Outrage You

Here’s the part that should light a fire under every borrower, advocate, and higher-ed expert reading this:

“A participant chosen by the Department is expected to represent the interests of their constituency group and to participate in the negotiations in a manner consistent with the goal of developing proposed regulations on which the committee will reach consensus, which means no member of the committee dissents from the proposed regulations.
Federal Register Notice 2025-13998

Let me translate that for you:

You can be the voice for borrowers.
You can sit in the room.
You can explain how the new rules will harm people.

But if the final draft is a disaster, you’re not allowed to say no.

This is Consensus by Coercion.

And it confirms what many of us suspected from the start: this process is performative. It’s the illusion of inclusion while marching forward with an anti-borrower agenda.


🗓️ Key Dates You Should Know

Want to show up anyway? Here’s how the charade is structured:

  • Register to speak at the hearing by: July 28, 2025 (email: ne***********@**.gov)
  • Virtual public hearing date: August 7, 2025, 9 a.m.–4 p.m. ET
  • Submit written comments by: ~August 24, 2025
    (30 days after publication via Regulations.gov, Docket ID ED-2025-0151)

Even if the game feels rigged, flood the docket with your story. Let your voice be part of the record they’re trying to ignore.

Do You Have a Question You'd Like Help With? Contact Debt Coach Damon Day. Click here to reach Damon.

💀 What’s At Stake If This Moves Forward

If these rules go into effect, here’s what borrowers could face:

  • Higher monthly payments due to fewer repayment options
  • Less forgiveness, especially for Parent PLUS and grad borrowers
  • Reduced access to deferment or emergency relief
  • Taxable loan forgiveness starting 2026 if ARPA expires
  • Disqualification from PSLF due to vague “illegal purpose” rules
  • Pell restrictions and program closures for low-income students

And all of it wrapped in the warm PR blanket of “modernization.”


⚠️ A System Designed to Pretend You Matter

This isn’t negotiation—it’s optics.

And if they really wanted borrower voices at the table, they wouldn’t:

  • Strip dissent from the rulemaking process
  • Pre-package policy goals before hearings even begin
  • Host one public hearing, mid-summer, with a 3-minute limit per speaker

This is a slow-motion policy trainwreck—one that tries to blame you for standing on the tracks.


👉 When you need real help, I always recommend talking to Damon Day, a debt coach and friend I trust.


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author avatar
Steve Rhode Debt Coach and Author
Steve Rhode is the Get Out of Debt Guy and has been helping good people with bad debt problems since 1994. You can learn more about Steve, here.