U.S. Department of Education (ED) Negotiated Rulemaking 

The Reimagining and Improving Student Education (RISE) Committee has concluded its negotiated rulemaking. First convened in late September, the committee aimed to develop regulations related to changes to federal student aid made by the One Big Beautiful Bill Act (OBBBA), with the goal of enacting these changes on July 1, 2026. Committee negotiators reviewed and agreed to 17 regulatory provisions and reached consensus on the entire package of federal student loan-related changes. 

The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee intends to begin negotiated rulemaking on December 8. This committee will consider OBBBA’s changes to institutional and programmatic accountability, the Pell Grant program, including the adoption of Workforce Pell, and other changes to Title IV programs. 

ED Announces Funding Opportunities Through the Fund for the Improvement of Postsecondary Education (FIPSE)

The ED Office of Postsecondary Education has issued a notice inviting applications for $167 million in new FIPSE-Special Projects awards.

FIPSE-Special Projects provides grants to higher education institutions, nonprofits, state higher education agencies, and other organizations to support innovative projects on areas of national need, as identified by the Secretary. This competition focuses on various areas, including advancing the understanding and use of Artificial Intelligence (AI) technology in postsecondary education and supporting capacity-building for high-quality short-term programs.

Applications are due December 3, 2025.

ED Requests Public Comments on Proposed IPEDS Rule 

ED has released a request for public comments regarding a proposed change to Integrated Postsecondary Education Data System (IPEDS) data collection. The proposed change would add a new survey component—the Admissions and Consumer Transparency Supplement (ACTS)—to IPEDS data collection. This change responds to a Presidential Memorandum published in August, entitled Ensuring Transparency in Higher Education Admissions. 

Comments will be accepted through December 15, 2025. 

ED Finalizes PSLF Rule

ED has finalized a rule, first released in August, that disqualifies from the Public Service Loan Forgiveness program any 501(c)(3) employer the Administration deems as having “a substantial illegal purpose.” The final rule will take effect on July 1, 2026, pending litigation.

The attorneys general of 21 states and Washington, D.C., in addition to two advocacy groups, have sued ED over this rule.

HLC previously joined more than 40 other higher education associations in sending a letter to ED requesting that it reconsider the rule.

Rescheduled National Advisory Committee on Institutional Quality and Integrity (NACIQI) Meeting

The summer meeting of the National Advisory Committee on Institutional Quality and Integrity (NACIQI) is now scheduled for December 16. The public can register to attend virtually.

U.S. Citizenship and Immigration Services (USCIS) Clarifies H-1B Visa Fee

In September, the Trump Administration announced that American employers would have to pay $100,000 per new hire on an H-1B visa.

The following month, USCIS issued additional guidance clarifying that the fee only applies to potential H-1B visa holders who live outside of the U.S. at the time of hiring. It does not apply to workers who already reside within the U.S., such as student visa holders or current H-1B visa holders who require a visa extension.

Highlighted Trend in State Higher Ed Policy: Dual Enrollment

Dual enrollment expansion continues to be an area of focus for many state legislators.

In 2024, 21 states passed a cumulative 39 laws impacting dual enrollment or early college high school, out of a total 242 bills introduced on the topic that year.

This year, states including Alabama, Iowa, Kentucky, Missouri, Washington State, and West Virginia have all passed legislation to expand dual enrollment access.

The work continues. Four Wisconsin state lawmakers, for example, recently proposed the Dual Enrollment Reform Bill, which aims to reduce the gap in student dual enrollment between rural and urban and lower- and higher-income districts. If passed, this bill would create a statewide online portal where families could find information about all available dual enrollment programs. It would also create an oversight council composed of higher ed and K-12 leaders to recommend strategies to expand dual enrollment participation.

Advocacy Agenda

HLC maintains an Advocacy Agenda that outlines its advocacy priorities related to federal and state regulations and legislation that apply to accreditation and higher education.   

HLC’s Relationship Within the Triad 

HLC has developed a statement on its Relationship Within the Triad to explain the shared oversight and the interconnected higher education environment in the United States. In particular, HLC notes in its statement that:

“The college or university’s mission is central to HLC’s accreditation and assurance of academic quality. In determining whether institutions meet HLC requirements, HLC considers the institution’s mission. An accredited institution demonstrates how it meets HLC requirements through a mission-reflective lens.

Should any of HLC’s requirements overlap with requirements from other members of the Triad, we work with the other Triad members to identify these situations and limit the burden on the institution.

HLC does not prescribe how a member institution meets HLC’s requirements. If a requirement of another entity of the Triad may appear to limit an institution’s ability to meet HLC’s requirements in a particular manner, an institution has the flexibility within HLC’s requirements to identify other ways to demonstrate it meets HLC’s requirements.” 

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