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Institutional Variation in New Federal Student Loan Limit Regulations

ByBlake Decker

While most calendar watchers have appropriately had their eyes focused on celebrations of the United States’ 250th anniversary, those within higher education circles might have viewed July 1, 2026 as the day when widespread changes to the federal student loan borrowing system became active. A year after the US Congress passed the One Big Beautiful Bill Act (OBBBA), which included new loan limits for graduate students, the Reimagining and Improving Student Education (RISE) Rule was published on May 1, 2026 and took effect on July 1, 2026.

As presented in our previous blog post, the RISE Rule revised caps for new student borrowers in graduate and professional programs, as well as placed limits on Parent PLUS borrowers who take out federal loans on behalf of dependent undergraduate students (RISE Rule Fact Sheet). Under the RISE Rule, annual loan limits for new student loan borrowers have been set at $20,500 for students in graduate programs and $50,000 for students enrolled in professional programs. Note: A list of new regulations and the definition of professional programs can be found at the end of this blog post, including an interim exemption for existing loan borrowers.

This blog post will continue to use estimates published by the Postsecondary Education & Economics Research (PEER) Center, which were based on data from the US Department of Education’s Office of the Chief Economist. The PEER dataset covered more than 58,000 graduate and professional academic programs across more than 2,200 institutions that received federal Title IV funding. Using the loan caps outlined above as cut points, the PEER Center calculated the number and percentage of students who acquired federal loans in excess of the new loan limits, as well as determined the volume of loan amounts that were in excess of the new limits. We drill-down further into the PEER Center data to explore institution-level data as a follow-up to our previous post that looked at national and state-level trends.

Share of Loan Borrowers Affected

As a reminder, the PEER Center’s data showed a national annual average across all institution types of 29 percent (367,518 out of 1,266,247) of borrowers who would have been affected by the new loan limits when using historical data. In the first visualization below, we show data for two of the three institutional control types in the PEER Center data: Public and Private Nonprofit institutions. Texas public universities are shown by university system, which can be filtered using the dropdown menu at the top.

  • The annotations below show that almost one out of every four (23.8%) graduate/professional students at Public institutions across the United States would have been affected by the RISE Rule loan limits. By comparison, over 35% of students enrolled in graduate/professional programs at Private Nonprofit institutions would have been affected, which is a 51% difference between the two institution types on the first chart below.
  • Across the 42 Public institutions in Texas included in the PEER Center data, 14.2% of loan borrowers at these Texas institutions would have been above the new loan limits, which is 9.6 percentage points below the national average for Public institutions.
  • Nine (9) of the 42 Public institutions in Texas were above the national average of 23.8% for this institutional group. UT Austin had the highest percentage of all Texas public institutions with 42.3% of their graduate/professional students having borrowed in excess of the new annual loan limits. Six (6) of those 9 institutions were Health-Related Institutions: University of Texas HSC at San Antonio (37.3%), University of Texas HSC at Houston (32.7%), Texas Tech University HSC (32.3%), Texas Tech University HSC-El Paso (31.3%), University of North Texas HSC (28.6%), and University of Texas Southwestern Medical Center (25.2%).

Loan Volume Affected

The second visualization above shows the percentage of loan borrowers that would have been affected by the new loan limits under the RISE Rule that went into effect on July 1, 2026.

  • Across all institution types and credential levels, the PEER Center’s nation-wide estimates based on historical data showed that more than $8.7B out of $34.4B (25.2%) in annual loan volume disbursed were above the new loan limits.
  • At all Public institutions in the PEER Center’s data, the national average for the amount of loan volume affected by the new loan limits was $11.7M for Public institutions, as compared to the national average of $30.5M across the all institutions in the Private Nonprofit category.
  • The average amount of loan volume affected at Public institution across Texas was $3.4M in the PEER Center’s data, which is more than $8M below the national average of $11.7M for Public institutions as shown in visualization above.
  • In comparison to the national average, only one Public institution in Texas had a total loan volume affected that was higher than the national average. The University of Texas at Austin had more than $22.6M out of a total of $88.9M in loans disbursed to students in graduate/professional programs that would have been above the new loan limits. The Texas Tech University HSC was the only other Public institution in Texas with more than $10M in loans disbursed that were above the new loan limits in the PEER Center’s data.
  • Two Private Nonprofit institutions in Texas had loan volume amounts affected by the new loan limits that were above UT Austin: Baylor University ($32.1M out of $84.2M) and University of the Incarnate Word ($27.2M out of $85.9M).

So What?

In the grand scheme of things, what do the data shown above represent? For the Public institutions in Texas, there were more than 57,000 total borrowers across the 42 Public institutions in the PEER Center’s dataset. Out of those 57K students enrolled in graduate/professional programs , 8,125 students had annual loan amounts that exceeded either the new $20,500 loan limit for graduate programs or new $50,000 loan limit for professional programs. With another 6,010 students at Private Nonprofit and For Profit institutions in Texas, there were over 14,000 graduate/professional students in Texas in the PEER Center’s data that would have had to find alternative sources of funding to cover the costs above the new RISE Rule loan limits. Given the focus on the difference in loan limits for graduate versus professional programs, our next blog post will disaggregate the PEER Center’s data to see how the borrowers affected and loan volume affected differ by academic program of study.

RISE Rule Definitions

As stated on pages 2-3 of the RISE Rule Fact Sheet:

Beginning on or after July 1, 2026:

  • Graduate student loans are capped annually at $20,500, with an aggregate cap of $100,000;
  • Professional student loans are capped annually at $50,000, with an aggregate cap of $200,000;
  • For the first time, Parent PLUS borrowers are capped annually at $20,000, with an aggregate cap of $65,000 per dependent;
  • All borrowers who receive a loan made on or after July 1, 2026, are subject to an aggregate lifetime loan limit of $257,500, with narrow exceptions discussed below;
    • Grad PLUS loans that a borrower has received will be included in this new aggregate lifetime limit, unless the borrower qualifies for the interim exception discussed below, in which case they will continue to be subject to the former (preAct) limits during the interim exception period; and
    • Parent PLUS loans made to a borrower for their dependent students are excluded
      from a borrower’s lifetime limit.

Interim exception: for borrowers enrolled in a program before July 1, 2026, and who have already received a loan for that program, an interim exception to the new loan caps will apply. Under this exception, borrowers may continue borrowing under the prior (pre-Act) annual, aggregate, and lifetime loan limits for the lesser of three years or their expected time to credential (defined as the period determined by subtracting from the program length the portion of the program the borrower has already completed), provided that they remain continuously enrolled. If a borrower ceases enrollment or withdraws from the program, they will no longer qualify for the interim exception and will instead be subject to the new annual, aggregate, and lifetime loan limits.

Professional Student Definition: The definition includes a list of 11 core program fields: pharmacy (Pharm.D.), dentistry (D.D.S. or D.M.D.), veterinary medicine (D.V.M.), chiropractic (D.C. or D.C.M.), law (L.L.B. or J.D.), medicine (M.D.), optometry (O.D.), osteopathic medicine (D.O.), podiatry (D.P.M., D.P., or Pod.D.), theology (M.Div., or M.H.L.), and clinical psychology (Psy.D. or Ph.D.). Nearly all of these fields have long been classified as professional degrees under the Department’s existing regulations, and no program has lost its professional degree classification under the final rule.