NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICERS (NACUBO)

Opposition to the proposed changes to the Public Service Loan Forgiveness (PSLF) program in the Notice of Proposed Rulemaking (NPRM) issued on August 18 in the Federal Register, denying certain organizations qualifying employer status. Support the Department of Education working with Congress to delay implementation of the H.R. 1. until at least July 1, 2027. Support for clear and direct communication for students, borrowers, and families to understand the new annual and aggregate loan limits and student loan repayment plans. Support for the Department of Education to create and disseminate a comprehensive list of professional degree programs, which should include programs identified in the Federal Register as meeting the definition of qualifying graduate program in the financial value transparency (FVT) final regulations. Support for proper staffing at the Department of Education in order to implement the full scope of the H.R.1. Support for the data used to determine the median earnings for each program to be be made publicly available in a timely, clear and concise manner. Request for further guidance on the requirement for institutions to package non-federal grant aid before the Pell Grant, and regarding institutional accountability reporting. Support for the the negotiated rulemaking committee adding additional constituency groups. Support for the work of the Joint Associations Group on Indirect Costs (JAG)s effort to develop a new, more transparent model for ensuring that institutions essential research costs are adequately supported.

Support for FY 2026 appropriations bills that mandate that the administration allocate funds as directed by Congress, and swift finalization of the FY 2026 appropriations process. Opposition to cuts to critical education programs contained in the House fiscal year (FY) 2026 Labor-Health and Human Services-Education and Related Agencies (Labor-HHS) bill. Oppose the elimination of the Federal Supplemental Education Opportunity Grants (FSEOG) and the reduction in funding for the Federal Work-Study (FWS) program. Support the House and Senate Labor-HHS bills providing level-funding for the Pell Grant.

Support for the exemption of nonimmigrant visas, including F, J, and M student visas, for those countries included under the June 4, 2025, Presidential Proclamation Restricting the Entry of Foreign Nationals to Protect the United States from Foreign Terrorists and other National Security and Public Safety Threats.

Concern over Consumer Financial Protection Bureau's (CFPB) proposed rule on the legal standards applicable to supervisory designation proceedings published in the Federal Register on August 26, 2025. Support for CFPBs intent to standardize the supervisory designation process and for transparency about the criteria and data sources it will use. Support for a final CFPB rule that distinguishes payment plans, emergency loans, and other higher education financing tools from high-cost or predatory financial products and clarify that they do not meet the significant harm threshold.

Support for the work of the Joint Associations Group on Indirect Costs (JAG)s effort to develop a new, more transparent model for ensuring that institutions essential research costs are adequately supported. Support the JAG effort included in some of the FY 2026 annual appropriations bills. Opposition to the Office of Management and Budget instituting arbitrary caps on costs essential to conducting high quality research.