National Association of Schools of Music
Federal Update: Announcement of the Creation of a Negotiated Rulemaking Committee, the Accreditation, Innovation, and Modernization (AIM) Committee; and the Publication of the Rise Proposed Rule
On January 27, USDE published in the Federal Register a notice of its intention to establish a negotiated rulemaking committee, tasked with preparing proposed regulations intended to amend current regulations as they pertain to the Secretary’s recognition of accrediting agencies. This is of note as NASM is recognized by the Secretary as an institutional accrediting agency. As a result of this recognition, freestanding institutions offering music and music related programs (both degree and non-degree-granting), including those offered via distance education, may use their NASM accreditation to establish eligibility to participate in programs authorized under Title IV of the Higher Education Act of 1965, as amended. NASM undergoes a Secretary-directed recognition review every 5 years.
A non-exhaustive list of topics to be considered by this Committee may be found in the Federal Register notice linked above and should be reviewed by NASM institutional representatives in detail.
As well, the notice includes a list of constituency groups from which a primary and alternate negotiator will be selected. The Secretary welcomes suggestions for negotiators. Nominations must be received on or before February 26, 2026. Complete instructions for submitting nominations may be found in the Federal Register notice.
This Committee will meet for a total of two weeks, separated into two one week long sessions. Session 1 will be held from April 13–17, 2026; Session 2 from May 18–22, 2026. Throughout these sessions, USDE will post information (draft amendatory text, negotiator proposals, data requests, etc.) on the Negotiated Rulemaking page of its website.
For reference, current regulations pertaining to the Secretary’s recognition process can be found in the Code of Federal Regulations (see 34 CFR Part 602). The announcement of this negotiated rulemaking was preceded by Executive Order 14279, Reforming Accreditation to Strengthen Higher Education, published on April 23, 2025. This Executive Order will provide helpful context for the upcoming negotiated rulemaking sessions.
Publication of Proposed Rule, Comment Period Open — Reimagining and Improving Student Education (RISE)
On January 30, USDE published in the Federal Register a Proposed Rule encompassing the topics negotiated by the RISE Committee which convened in September and October of 2025. The Proposed Rule is now open for public comment until March 2, 2026. Institutional representatives are encouraged to review the language of the Proposed Rule and, as deemed appropriate, submit a comment(s). All comments must be made through www.regulations.gov.
The comment page for this proposed rule may be found by either searching regulations.gov with the Docket ID number ED-2025-OPE-0944, or here. Complete instructions for submitting a comment are found in the Federal Register notice linked above under the “Addresses” heading. USDE has provided tips and suggestions for submitting comments in the Federal Register notice under the heading “Supplementary Information: III. Invitation to Comment.”
Among other places in the Federal Register notice, the section labeled “VI. Significant Proposed Regulations” under the subheading “William D. Ford Federal Direct Student Loan (Direct Loan) Program, Definitions (§ 685.102),” includes detailed information about the proposed regulatory definition of “professional student” and the associated definition of “professional degree.” USDE invites feedback in this area, stating “Specifically, it would be useful to have feedback on how the Department applied the operative definition of professional student and utilized the context of the illustrative list of degrees when interpreting the definition.” The definition of “professional degree” has received legislative attention subsequent to the RISE committee’s work with at least three bills introduced in the House of Representatives aiming to expand the statutory definition of the term, and thus expand the number of programs eligible for the higher annual and lifetime loan limits outlined in P.L. 119-21 (see H.R.6718, H.R.6677, and H.R.6739).
Subsequent to the conclusion of the public comment period, USDE will consider all comments received, draft the final rule, and once cleared through the Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB), publish the final rule. USDE does have the ability to amend the language of the final rule based on information gathered during the public comment period.
As a reminder, the RISE Committee did reach consensus on this regulatory package, and so the regulatory language included in the Proposed Rule reflects that which was approved by the Committee. The Federal Register announcement includes additional explanatory information related to the regulatory language. NASM previously published two notices which provide additional background information on the law that these proposed regulations are intended to implement, and on the work of the RISE Committee:
Federal Update: Work of the AHEAD and RISE Negotiated Rulemaking Committees (12/11/2025)
Staff in the NASM office remain available should any questions arise.
Thank you.