New Federal Court Ruling Reinforces AAPA-PAEA Challenge Over Professional Degree Loan Limits

Joint Update from AAPA and PAEA

Recent federal court decisions reinforce the central argument in AAPA and PAEA’s legal challenge against the U.S. Department of Education’s (ED) restrictive definition of “professional degree” for federal student loan purposes.

The latest ruling, issued on October 16 by the U.S. District Court for the District of Oregon, represents now the third federal judge to independently reach the preliminary conclusion that the ED likely exceeded its authority in restricting access to higher loan limits available to professional students. This ruling provides additional encouragement as AAPA and PAEA pursue a permanent resolution protecting PA students’ access to federal loans.

PA students’ current borrowing eligibility remains unchanged. The preliminary relief secured by AAPA and PAEA in June remains in effect. Under ED’s implementation guidance, eligible PA students may continue to access the federal loan limits available to professional students: $50,000 annually and $200,000 in aggregate, subject to applicable federal requirements.

Court Reinforce the Limits of ED’s Authority

The Oregan ruling granted preliminary relief in a lawsuit brought by organizations representing naturopathic medical education and practitioners. Judge Michael Simon found that the plaintiffs were likely to succeed in challenging ED’s treatment of naturopathic medical degrees under the new federal student loan regulations.

In reaching the conclusion, Judge Simon expressly relied on Judge Beryl Howell’s reasoning in her June 24 decision in the lawsuit brought by PAEA and AAPA, where she explained:

“Congress explicitly directed the Department to apply the preexisting regulatory definition set forth in 34 C.F.R. § 668.2 as the relevant test, and the Department has no power to revise the definition Congress codified or to add additional substantive criteria.”

In the Oregon case, Judge Simon quoted that exact passage in his October 16 Oregon ruling, underscoring the consistency of their reasoning.

Together, the rulings reflect growing judicial agreement with the central statutory reasoning advanced by PAEA and AAPA. Although the other cases involve different plaintiffs and do not directly determine the outcome of our lawsuit, they provide additional encouragement as we pursue a permanent resolution recognizing PA students as professional students for federal loan purposes.

What This Means for PA Programs and Students

Importantly, the legal landscape for PA students has not changed as a result of this latest decision.

The preliminary relief secured by AAPA and PAEA in June remains in effect. Under the Department’s subsequent implementation guidance, eligible PA students may currently access the higher federal loan limits available to professional students: $50,000 annually and $200,000 in aggregate, subject to applicable federal requirements.

PAEA and AAPA continue to encourage institutions to make these higher borrowing limits available to eligible PA students, while providing clear information about the benefits and potential risks associated with borrowing during ongoing litigation so that students can make informed decisions.

We recognize that institutions must consider the possibility of future changes to federal loan eligibility. At the same time, restricting access to federal financing that is currently available carries its own significant risks. Students may face unnecessary financial barriers, turn to more expensive private loans, or reconsider pursuing PA education altogether.

Our shared position is that students should have the opportunity to make informed borrowing decisions based on the federal financing currently available to them, with a clear understanding of the uncertainty surrounding future loan eligibility.

Resources for PA Programs and Financial Aid Offices

To support institutions as they implement current federal guidance, we encourage PA program directors and institutional leaders to revisit the following resources and share them with their financial aid offices:

• Talking Points for PA Program Directors: PA Student Access to Federal Financial Aid
• AAPA Frequently Asked Questions
• PAEA Frequently Asked Questions

These resources explain the current legal landscape, institutional implementation considerations, and the importance of ensuring that students receive accurate information about their borrowing options.

What Comes Next

PAEA and AAPA filed their motion for summary judgment earlier this month, asking the court to resolve the underlying legal challenge. Briefing is scheduled to conclude in early December, after which the court will determine next steps.

Although the agreement among these courts is encouraging, these are preliminary decisions, our litigation remains ongoing, and a permanent resolution has not yet been secured.

AAPA and PAEA remain committed to working together to protect PA students’ access to federal financial aid, support institutional implementation of current guidance, and secure a lasting outcome that recognizes PA education as the professional education it is.