Reconciliation Bill of 2025
The Reconciliation Bill of 2025 (Public Law 119-21) was signed into law on July 4, 2025; this is also known as the One Big Beautiful Bill (OB3), or sometimes as the Working Families Tax Cut Act (WFTCA). Among its many components are changes to (or related to) the federal financial aid programs; for purposes changes to financial aid programs and administration at the U, we use OB3 to refer to the law and its implementing regulations and guidance. In order to provide information and to help address questions and concerns regarding these changes, we are providing our current understanding of the provisions of the bill and regulations related to financial aid. Because details are still emerging and evolving—including the U.S. Department of Education’s publication of final regulations (on May 1, 2026) with at least one pending court case challenging a section of the regulations—we will update our understanding as clarifying information is released.
Note: Students classified as ‘Undergraduate’ are typically pursuing a bachelor’s Degree; ‘Graduate’ students are typically pursuing a master’s degree or a doctoral degree; and ‘Professional’ students are typically pursuing a degree (such as the M.D., J.D., and D.D.S., among others) that signifies readiness to practice in a specific profession.
| Federal Financial Aid Program/Area |
Existing Standards or Terms (prior to OB3) |
OB3 Bill Change | Notes |
|---|---|---|---|
| Federal Direct Student Loans – Annual/Aggregate Borrowing Limits |
Graduate and Professional students
Undergraduate students
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Professional students
Graduate students
Undergraduate students
(*Limited legacy provisions exist for for up to 3 calendar years (or the eligible remaining duration of their degree program of study, which is earlier ) for eligible students who were continuously enrolled in their same degree program of study and had a Federal Direct Unsubsidized Student Loan* disbursed prior to July 1, 2026 while enrolled in their same degree program of study; these limited “legacy” provisions would allow eligible students to continue borrowing under existing annual and aggregate limits instead of the OB3 limits) For more detailed information on this issue, please see the Limited Legacy/Exception Status information page. |
For more detailed information on these and related topics, please access the following information pages: |
| Graduate PLUS Federal Student Loan Program(GradPLUS) |
Annual Loan Limit : Students enrolled at least half-time in a graduate or professional degree program can borrow up to their Title IV Cost of Attendance (direct and indirect costs) less any other financial aid received Aggregate Borrowing Limit : There are no aggregate or lifetime limits on GradPLUS borrowing |
Eliminates GradPLUS loan program effective beginning with the 2026-27 academic year (*Limited legacy provisions exist for up to 3 calendar years (or the eligible remaining duration of their degree program of study, whichever is earlier ) for eligible students who were continuously enrolled in the same degree program of student and had a Federal Direct GradPLUS loan* disbursed prior to July 1, 2026 while enrolled in the same degree program of study; these limited “legacy” provisions would allow eligible students to continue borrowing under the GradPLUS program). For more detailed information on this issue, please see the Limited Legacy/Exception Status information page. |
For more detailed inforamtion on these and related topics, please access the following information pages: |
| Federal Direct Student Loans – Lifetime Borrowing Limits | No “lifetime” borrowing limit exists across all federal student loan programs (Subsidized, Unsubsidized, and GradPLUS) |
New $257,500 lifetime borrowing limit on all federal student loans
(*Limited legacy provisions exist for up to 3 calendar years (or the eligible remaining duration of their degree program of study, whichever is earlier) for eligible students who were continuously enrolled in their same degree program of study and who had a federal student loan disbursed prior to July 1, 2026 while enrolled in the same degree program of study; it is our understanding, students qualifying for the legacy exception would be able to continue borrowing (within the limited legacy exception timeframes noted above) under the Federal Direct Student Loan programs’ annual and aggregate borrowing limits in effect prior to the OB3/Reconciliation Bill provisions) |
This new limit will affect students who have prior borrowing under any Federal Direct Student Loan Program (Subsidized, Unsubsidized, and GradPLUS). Students who have lifetime borrowing totals above $257,500 will likely need to utilize private loans as their primary funding option, unless they qualify for the limited legacy* exception |
| Loan Reductions based on Less-Than-Full-Time Enrollment | Undergraduate students in their final semester of their undergraduate degree program of study must have their annual loan limit prorated if their remaining period of enrollment is less than a full academic year |
All annual loan limits must be prorated based on the student’s enrollment status when the enrollment status is less than full-time Applies to students enrolled in Undergraduate, Graduate, and Professional degree programs who borrow any type of Federal Direct Student Loan and are not enrolled full-time There are no legacy exceptions to this rule and the loan reduction calculations apply for each loan disbursement in an academic year (Fall semester, Spring semester, and/or Summer term) |
For more detailed information on these and related topics, please access the following information pages:
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| Parent PLUS Federal Student Loan Program (ParentPLUS) |
The parent of a dependent student who is enrolled at least half-time in an undergraduate degree program can borrow up the Title IV Cost of Attendance (direct and indirect costs) less any other financial aid received. There are no aggregate or lifetime limits on ParentPLUS borrowing. |
All parents may borrow up to a combined $20,000 per year per dependent student and a $65,000 aggregate limit per dependent student (*Limited legacy provisions exist for up to 3 years (or the remaining duration of the student’s eligible degree program of study, whichever is earlier) for parent borrowers who had a ParentPLUS loan disbursed prior to July 1, 2026 and on behalf of a student enrolled for a period prior to July 1, 2026 in their same degree program of study; these “legacy” provisions would allow eligible students to have a parent borrower, or parent borrowers, continue borrowing under the existing ParentPLUS terms for the limited additional timeframe of the legacy provisions). For more detailed information on this issue, please see the Limited Legacy/Exception Status information page. |
Unless qualifying for the limited legacy* exception, these new borrowing limits are in effect beginning with the Fall 2026 semester and beyond. Students (or parents of dependent students) needing to borrow additional funds beyond these limits will likely need to utilize private loans as a primary funding option For more detailed information on these and related topics, please access the following information page: |
| Federal Pell Grant – Short Term Programs (a/k/a “Workforce Pell”) | Students enrolled in short term programs less than an academic year (i.e., 30 instructional weeks) in length for the entire program are generally ineligible for Federal Pell Grant funding | Short-term programs of less than 15 instructional weeks in length are now eligible for students to receive Federal Pell Grants | Currently there are no qualifying short-term programs at the U |
| Federal Pell Grant – Eligibility for students with full COA aid |
Federal Pell Grants have long been considered an entitlement; that is, if a student is eligible for the Pell Grant, the full amount of eligibility must be paid to the student
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Students who receive grants or scholarships from non-federal sources covering their entire COA are ineligible to receive a Federal Pell Grant, even if otherwise eligible There are no legacy exceptions to this rule and it is in effect beginning with the Fall 2026 semester and beyond. |
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| FAFSA data elements and Need Analysis |
Family farm and family-owned small business net asset values must be reported on FAFSA and included in need analysis calculations Foreign income excluded from Adjusted Gross Income (AGI) in need analysis, particularly when affecting Federal Pell Grant eligibility Regardless of Student Aid Index (SAI) calculation (from need analysis formula), students could be determined as eligible for a minimum or maximum Federal Pell Grant |
Exempts net asset value of a family farm and/or family-owned small business from being reported on the FAFSA or included in the need analysis calculations Foreign income must be included in the AGI in need analysis and a financial aid administrator can no longer exclude it when a reported foreign income prevented a student from being eligible for a Federal Pell Grant If a student’s SAI is more than twice the amount of the maximum Pell Grant award, the student is not eligible for a Federal Pell Grant regardless of any need analysis calculations or other indications of such eligibility |
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| Institutional Accountability | No such measure currently exists | New accountability measure that would cause an academic program to lose Federal Direct Student Loan eligibility if its graduates fail the “low earnings outcomes" measure 2 out of 3 years | |
| Federal Student Loan Repayment |
There were multiple provisions related to student loan repayment, including loan repayment options and loan forgiveness programs. The U.S. Department of Education (a) issued high-level guidance on some issues in Dear Colleague Letter GEN-25-04 (published on 07/18/2025) and (b) published on May 1, 2026, final regulations on loan repayment rules/plans. Until more details are analyzed from the final regulations, the following topical summary is a guide to the changes made by the Reconciliation Bill (some of the descriptions below are from a summary prepared by the National Association of Student Financial Aid Administrators); all references to ‘loans’ and ‘borrowers’ below are to the federal student loan programs:
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