Comments on the administration’s proposed regulations to expand the Pell Grant to cover short-term job training programs are due April 8. Here’s our recap of how to write and submit a public comment.
Your high school government teacher may have taught you how a bill becomes a law, but did they teach you how to write an impactful public comment on federal regulations? Our guess at Inside Higher Ed is, probably not.
But last week, the Education Department published the first in what will likely be a series of highly consequential regulatory proposals related to the largest overhaul of federal student aid in more than a decade. With officials now accepting comments from the public to guide their decision-making, our team thought it was time for a quick refresher on how to provide effective feedback.
We talked with a former department official, a higher ed lobbyist and an advocate for student loan borrowers to illuminate the nuts and bolts of the regulatory process, why public comment matters and how to strengthen your next submission.
Here’s what they had to say.
Understand How Public Comment Works
First, the experts said, it’s important to know what you’re commenting on and how policymaking works.
In this case, the regulatory process started in July when Congress used a tool called reconciliation to pass a sweeping piece of legislation known as the One Big Beautiful Bill Act, or OBBBA. The bill touched on many topics outside of higher ed, but with regard to colleges and universities, lawmakers set new loan limits, streamlined options for repayment, expanded the Pell Grant and introduced a new accountability system.
But, as is often the case when it comes to federal legislation, much of this law was pretty bare bones; it fell to the executive branch, more specifically the Department of Education, to interpret and flesh it out enough to take effect on July 1, 2026.
In order to do so, ED was required to use a process known as negotiated rule making, which both starts and ends with public comment. The first period of public comment opened in August and led to weeks of debate between the department and select groups of higher education experts.
Now that consensus has been reached on each of the three key issues—loans, the Pell Grant and accountability—it’s time for the public to comment again. For each of the three sets of regulations, the department must publish the text to the Federal Register and open itself up to feedback for at least 30 days.
Only after it has responded to every comment submitted will the Trump administration be able to finalize the rules.
Stay Narrow and Solutions-Oriented
So far, only the proposal on loan limits has been published and opened for comment. But as commenters start to draft their responses, Clare McCann, managing director of policy at American University’s Postsecondary Education and Economics Research Center, recommended they focus on determining the topics most susceptible to outside influence.
To submit a public comment, go to regulations.gov and search for the proposal you want to weigh in on.
When regulations are based on laws Congress has passed—as in this case—the department has limited wiggle room on certain issues but more authority to amend others, said McCann, who served as a senior policy adviser at ED during the Biden administration.
For example, regarding loans, Congress was pretty clear about which repayment plans will be available, to whom and for how long. But it left more room for flexibility on the new loan caps and determining which degree programs have access to the higher limit, she explained.
“So the bigger question should be, what are the areas where the department does have discretion, and then within those areas, what new information can commenters bring to bear?” McCann said.
Often, a good way to figure that out is by looking for questions the department posed in its notice of proposed rule making, she added, or by focusing on the most hotly debated topics during negotiations. Another expert noted that think tanks, advocacy groups and research centers often put out briefs that give a quick rundown of the key issues at stake.
Once you know what you’re going to focus on, McCann and others said, it’s helpful to stick to that narrow topic and get to the point quickly. While there’s typically no limit on how long a comment can be, usually one to two pages with a summary at the top will do the trick.
“Narrowing the focus on the impact to your institution, the major issues that you are concerned with can make your comments stand out,” said Sarah Spreitzer, vice president of government relations at the American Council on Education. “It’s better to submit good comments than just lengthy, repetitive ones.”
Spreitzer and McCann also advised that it takes more than identifying a problem. Although the number of people writing about any one concern can add weight, to really hold sway, they said, you have to propose a solution to that issue.
In fact, the Trump administration has made clear that any mass comments, or a high volume of individual submissions that appear to be near duplicates of one another, will be treated as one and given a singular response. So proposing fresh, original solutions is key.
“The more you can be concrete about how the situation you’re writing about could be improved in some way that benefits students, taxpayers or whomever, the more useful that is to the department, and the more likely they are to feel the need to substantively respond,” McCann said.
Provide Evidence
Another key to writing an influential comment is to provide data-based evidence, both to back up your concern and to show that your proposed solution will be legal, efficient and effective, experts said.
When writing regulations and responding to public comments, department officials are required by case law to use reasoned decision-making, “examine the relevant data and articulate a satisfactory explanation.” If they don’t, opponents can challenge the administration’s rules in court, deeming them “arbitrary and capricious.” When a judge rules in favor of the plaintiffs, the rule can be completely overturned, though if the evidence backing ED’s decision is strong, it may hold.
For example, in recent court cases concerning an existing accountability regulation known as the gainful-employment rule, challengers from for-profit institutions tried to argue the department’s policy was arbitrary. But because the standard for maintaining access to federal aid had been backed by evidence as an effective way to ensure efficient use of taxpayer dollars, the court ruled in favor of the department.
So the more data commenters provide to back their claims, the more time and attention the department will have to spend on it. That’s why research-focused faculty members are strong candidates for writing public comments, McCann explained, cautioning that it is still important for them to avoid using academic or scientific jargon to make their case.
“When the department is trying to resolve comments, they are looking for holes being poked in what they put forward, or unintended consequences they may not have thought about,” she said. “So when there are thoughtful comments that bring new research to their attention, those are the comments that tend to hold the most influence in the process.”
The research and data being cited don’t have to come from elite, peer-reviewed journals, either. Working papers, policy briefs and other sources can also be effective so long as they are clear and credible.
Amy Czulada, the outreach and advocacy manager at Protect Borrowers, a student advocacy group, emphasized that you don’t have to be a higher ed policy researcher to write a well thought-out comment. She suggested looking to advocacy groups like her own or other trusted sources for data to back up your personal experiences.
“For instance, thinking about the [most recent regulatory proposal], we put out some great data and graphs on exactly how much folks’ payments will go up under the new [loan repayment] plan,” she said. “So it’s just about looking for those trusted sources, folks that are really in the weeds on this to back up your argument.”
Demonstrate Costs and Benefits
Combined with data, anecdotal comments from individual institutions, students and employers can also be valuable in clarifying the costs and benefits of a proposed regulation, Czulada and others said.
In addition to “examin[ing] relevant data,” one of the department’s standards for reasoned decision-making standards is a “regulatory impact analysis.” This element, which must be included in every proposal, is used to justify the rule’s efficiency and effect on constituents.
And while much of the RIA is based on quantifiable costs and gains, such as the tax dollars saved or the time it will take to implement, individual commenters, especially students, can often draw attention to other difficult-to-quantify effects.
For example, what kind of administrative burden does a regulation place on institutions, or what kinks does it create in the customer service experience of student borrowers or grant recipients?
“We know that the student loan system was broken well before this moment in time. We’re certainly not advocating for the status quo, but a lot of these changes within OBBBA are going to make matters even worse,” Czulada said. “So a demonstration that these bills were already too much to manage and now they’re going to go up can be useful to relay to the department.”
McCann from PEER added that comments don’t just have to be about the drawbacks.
“The extent a commenter agrees with something the regulator is doing is also helpful to know,” she said, especially if opposing parties will likely want that policy amended. “It doesn’t just need to be things that should change. It could be a comment on things that should not.”
