On March 2, 2026, a broad coalition of higher education associations—including the Association for Institutional Research (AIR)—joined the American Council on Education (ACE) and more than 60 peer institutions and organizations in submitting formal comments to the U.S. Department of Education regarding the Department’s Reimagining and Improving Student Education (RISE) proposed rulemaking. The comments were filed in response to the Department’s Notice of Proposed Rulemaking (NPRM) under Docket ID ED-2025-OPE-0944, which seeks to implement key student loan and accountability reforms mandated by the recently enacted One Big Beautiful Bill (OBBB) Act.

The letter underscores the coalition’s support for the Department’s intent to implement statutory changes impacting student loan programs and postsecondary accountability frameworks. At the same time, signatories—including AIR—express concerns about specific elements of the proposed regulatory approach and urge careful refinement to ensure that implementation supports institutional effectiveness and student success.

Among the key recommendations, the members of the coalition call on the Department to extend negotiated rulemaking timelines to allow for more meaningful stakeholder discussions and to ensure a diversity of institutional voices at the negotiating table. They also press for adherence to established procedural timelines under the Higher Education Act to give colleges and universities sufficient lead time to operationalize significant regulatory changes. Furthermore, the comments highlight concerns with proposed definitions—such as the narrow list of professional degree programs eligible for higher loan limits—which the organizations argue could undermine student access to needed financial support.

By joining this unified submission, AIR reinforces its commitment to evidence-informed policymaking and to advancing the capacity of postsecondary institutions to interpret, implement, and assess federal policy changes that affect students, data systems, and institutional planning.