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Volume 3, No. 92, July 29, 2025 |
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ED Releases “Dear Colleague” Letter Regarding Certain Provisions of the One Big Beautiful Bill
The Department of Education (ED) issued a Dear Colleague Letter
(DCL), providing guidance on the newly enacted One Big Beautiful Bill Act,
signed by President Donald Trump in early July. While much of the Act’s significant
impact on higher education is scheduled to take effect on or after July 1, 2026,
the DCL outlines several key provisions that became effective immediately upon the bill’s signing.
Among the changes of interest to the oral health community that are now in effect
are revisions to the income-based repayment (IBR) plan, changes to eligibility
under the Public Service Loan Forgiveness (PSLF) program and loan limits for part-time students.
The One Big Beautiful Bill Act eliminates the requirement for borrowers
to show partial financial hardship to qualify for the IBR plan, making more borrowers
eligible immediately. Those with loans from July 1, 2014, to July 1, 2026, who
were previously ineligible can now access IBR’s more favorable terms, such as
payments at 10% of discretionary income with loan forgiveness after 20 years,
instead of the less generous Income Contingent Repayment plan.
The bill also amends the PSLF program to allow for payments made under the newly
created Repayment Assistance Plan (RAP) to count toward loan forgiveness, if all
other eligibility criteria are met. The RAP was created by the Act and will take
effect July 1, 2026. This PSLF provision is effective upon enactment, meaning
that whenever ED launches the RAP program, borrowers will be able to immediately get credit for PSLF under RAP.
Finally, the Act mandates a proportional reduction in annual student loan limits
for students enrolled less than full time, based on the extent of their part-time
enrollment. ED is developing a reduction schedule that will be released for public
comment and finalized later this year. Starting in the 2026–27 academic year,
institutions will be required to use this schedule to adjust loan limits for all students not enrolled full time.
Despite the immediate enactment of some provisions, many questions remain about
how these changes will be implemented. The Department acknowledged this uncertainty
and stated in the DCL that it will release additional regulations and guidance
for these provisions and other aspects of the law later this year.
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Reagan-Udall Foundation and FDA Hold Public Meeting on Ingestible Fluoride for Kids
On July 23, the Food and Drug Administration (FDA), in collaboration with the Reagan-Udall
Foundation, held a public meeting to gather input on the use of orally ingestible
fluoride supplements. The meeting followed the FDA’s May announcement
that it is considering removing these unapproved products from the market. Please
find the master slide deck from the meeting here.
Dr. George Tidmarsh, the newly announced FDA Director of the Center for Drug Evaluation
and Research, expressed the need for balancing risk and benefit.
He criticized
the initial presentations in the meeting that were favorable towards fluoride supplements.
Dr. James Bekker, of the University of Utah School of Dentistry emphasized that
fluoride is a naturally occurring nutrient essential for oral health, noting that
both deficiency and excess can pose risks.
He underscored the importance of shared
decision-making between health care providers and patients to determine appropriate
fluoride use based on individual needs and local water fluoridation levels.
Citing
Utah as an example, where some communities have recently discontinued water fluoridation, Dr.
Bekker highlighted the growing reliance on ingestible fluoride supplements as a
necessary alternative for pediatric oral health.
Presenters raised concerns about potential neurocognitive effects of fluoride exposure.
Dr. Griffin Cole, who represented the International Academy of Oral Medicine and
Toxicology, argued that fluoride is only effective topically and called for the
FDA to remove ingestible supplements, citing a meta-analysis linking fluoride to lower IQ.
In contrast, Dr. Susan Fisher-Owens, of University of California, San Francisco,
School of Medicine, stressed the need to weigh risks and benefits in pediatric
care, noting that many pediatric drugs, including fluoride, lack FDA approval.
She questioned the reliability of fluoride-IQ studies and noted that mild fluorosis
is not harmful and may reflect appropriate exposure.
The meeting concluded with members of the public offering comment.
Many of the
commentors were supportive of fluoride supplements for the pediatric population.
ADEA strongly supports continued access to ingestible fluoride supplements and
filed written comments
ahead of this meeting.
The FDA will take both oral and written comments from this public meeting into
consideration and is aiming to conclude its review of ingestible fluoride supplements by the end of October.
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21 Democratic Governors Sue HHS Over New ACA Eligibility and Enrollment Rule
A coalition of 21 Democratic-led states has filed a lawsuit
against the Department of Health and Human Services (HHS) and the Centers for Medicare
& Medicaid Services (CMS), challenging a new final rule
they argue would significantly limit access to health coverage under the Affordable
Care Act (ACA). Filed July 17 in the U.S. District Court for the District
of Massachusetts, the suit targets a final rule set to take effect Aug.
25. The
states are seeking preliminary relief to halt the rule before it is implemented.
They argue the rule’s changes would result in up to 1.8 million people losing
coverage, increased out-of-pocket expenses and would impose administrative burdens that deter enrollment.
Furthermore, plaintiffs believe that the regulation undermines years of progress
in ACA enrollment, which reached over 24 million this year.
The rule introduces stricter eligibility verification, shortens enrollment periods
and removes gender-affirming care as an essential health benefit.
Among the key
issues raised in the complaint is the rule’s elimination of coverage for gender-affirming
care, which the states argue directly conflicts with their own laws mandating such coverage.
The rule also modifies exchange eligibility rules, reducing the open enrollment
window by one month and eliminating a special enrollment period for low-income
individuals. It further restricts leniency for applicants who struggle to verify
their income or reconcile tax data, potentially stripping away subsidies and making coverage unaffordable for many.
The states claim the rule is “arbitrary and capricious” and would impose substantial
costs on states by increasing the number of uninsured individuals who would then
rely on state-funded health care programs, such as Medicaid and emergency services.
They also warn that the rule will create unrecoverable costs related to technology
upgrades, staff training and public outreach, and reduce tax revenue from insurance premiums.
The lawsuit also accuses HHS of violating the Administrative Procedure Act by rushing
the rule through passage with only 23 days for public comment, despite public requests for more time.
HHS defends the rule as a measure to reduce fraud and prevent unauthorized enrollments.
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ED Announces Investigation of Universities for Offering Scholarships Exclusive to DACA Students
On July 23, the Department of Education (ED) announced
that its Office for Civil Rights (OCR) has launched investigations into five universities—University
of Louisville, University of Nebraska, University of Miami, University of Michigan
and Western Michigan University—for allegedly offering scholarships exclusively
to Deferred Action for Childhood Arrivals (DACA) or undocumented students.
ED
argues that such programs violate Title VI of the Civil Rights Act, which prohibits
discrimination based on national origin.
The investigations were initiated in
response to complaints filed by the Equal Protection Project of the Legal Insurrection Foundation.
ED also indicated it will review other scholarships designated for LGBTQ+ students,
as well as those intended for African American, Hispanic and Native American students.
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ED Announces Negotiated
Rulemaking for Implementation of the Trump Administration’s Student Loan Reforms
The Department of Education (ED) announced, on July 25, that it will convene two advisory committees
as part of a new round of negotiated rulemaking. This rulemaking is necessary
to implement recent statutory changes to the Title IV, Higher Education Act
programs included in Pub. L. 119-21, known as the One Big Beautiful Bill (OBBB)
Act, that President Trump signed into law on July 4.
As part of this process, the Department will hold a virtual public hearing Thursday,
Aug. 7, to gather public input on implementing the OBBB Act before drafting new
proposed regulations. To view the virtual public hearing livestream on Aug. 7,
register here.
The hearing runs from 9:00 a.m. – 4:00 p.m. ET.
Additionally, written comments will be accepted through Monday, Aug. 25.
Information regarding submitting comments can be found here
under the Addresses section.
This notice also provided information on the nominating processes for the negotiated rulemaking advisory committees.
ED is creating two advisory committees: the Reimagining and Improving Student Education
(RISE) committee, which will focus on federal student loan reforms, and the Accountability
in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) committee,
which will address issues related to institutional and program accountability and the Pell Grant program.
Nominations for committee members serving on the RISE Committee may be sent via
email to [email protected]
by Aug. 25.
Additional information about the nomination process, the constituency groups who
can be nominated and the negotiation schedules can be found here
toward the bottom of the page.
Nominations for committee members serving on the AHEAD Committee may be submitted
to the via email to [email protected]
by Aug. 25. Additional information about
the nomination process, the constituency groups who can be nominated and the negotiation
schedules can be found here
toward the bottom of the page.
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