AIM NPRM Receives 5,374 Submissions of Comments Including 1,898 Published Comment Documents

Overview
Last night at 11:59 PM EDT the comment period for submission of responses to the Accreditation, Innovation, and Modernization: Secretary’s Recognition of Accrediting Agencies: Institutional Eligibility under the Higher Education Act, as Amended, Student Assistance General Provisions (Docket ID: ED-2025-OPE-1042) (us.list-manage.com/12KYgygW2xu?e=05bce952ad&c2id=828e2f13ae2569477ba2b7da4ef30812) proposed rule(AIM NPRM) officially closed.

As noted in the headline, according to the AIM NPRM data (us.list-manage.com/TPA16pens4t?e=05bce952ad&c2id=828e2f13ae2569477ba2b7da4ef30812) provided this morning on Regulations.gov, the AIM NPRM received a total of 5,374 submissions, of which a total of 1,898 comment submissions (us.list-manage.com/aAVM7jbHyPy?e=05bce952ad&c2id=828e2f13ae2569477ba2b7da4ef30812) have been posted for publication. (Note: The agency reviews all comments prior to posting/publication as explained on the regulations.gov (us.list-manage.com/7OYLrGwRXE5?e=05bce952ad&c2id=828e2f13ae2569477ba2b7da4ef30812) website and there may still be some comments under review that could still be published.)

With public comment window now closed, CSPEN will spend the next few days attempting to categorize the close to 2.000 published documents to provide some general, and potentially more detailed analysis of the comments received to share with the community on this Thursday’s CSPEN Federal Legislative & Regulatory Update webinar.

This week, CSPEN will focus our efforts on providing a first look at the submissions which came directly from the accrediting agencies and their umbrella organizations and the higher education community and their umbrella organizations.

Following this review, by next week we hope to provide additional analysis and summaries related to the comments provided directly by students – including those student and families who have served our country. And then an additional review, analysis and summary of the submissions of legal assistance, consumer advocacy, and civil rights organizations and more.

What’s Next
With the NPRM public comment period now closed, the Department of Education (Department) will essentially be undertaking the same comprehensive review process we aspire to undertake and share with you. Like us, the Department is now responsible for reviewing all of the published comments – as well as some three thousand plus more that we are not privy to in order to determine if any revisions, additions, or omissions will be made to the proposed regulations which were approved by consensus for publication as the NPRM.

Once their Department’s review is completed, the Department will work to develop a final rule, including an analysis of public comment and changes and summary of comments and changes from the NPRM to other portions of the final rule which will draw heavily from the NPRM content. When the Department has developed what they believe to be the draft final rule, it will be submitted to the White House, more specifically the Office of Management and Budget’s Office of Information and Regulatory Affairs for regulatory review.

At this time, interested and affected parties have one final opportunity to provide their comments on the pending final rule by requesting an Executive Order 12866 Meeting. The community will hopefully recall several times in which we have shared information on this part of the process throughout the development and consideration of the RISE and AHEAD Committee regulatory packages.

Following OMB/OIRA consideration the final draft regulations are returned to the Department of Education with comments. The Department can either accept or reject the comments and upon completion will develop the final rule. The Final Rule will then be submitted to the Federal Register for publication – which may or may not be preceded by unofficial public release by the Department.

All the process will take place here in Washington within the next thirty-five days, as the Department has made it very clear that the AIM Final Rule will be published on or before Sunday, November 1, 2026.