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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  

  • Annual Loan Limit: up to $20,500 per year 
  • Aggregate Borrowing Limit: $138,500 (includes federal direct student loan amounts borrowed as an undergraduate student) 

 Undergraduate students 

  • Annual Loan Limit for Dependent Students: up to $7,500 per year depending upon grade level 
  • Annual Loan Limit for Independent Students: up to $12,500 per year depending on grade level
  • Aggregate Borrowing Limit for Dependent Students:  $31,000  
  • Aggregate Borrowing Limit for Independent Students:  $57,500  

 Professional students

  • Annual Loan Limit:  Increase to up to $50,000 per year (from $20,500) 
  • Aggregate Borrowing Limit: $200,000 (excludes borrowing as an undergraduate) 

 Graduate students  

  • Annual Loan Limit:  No Change (remains at up to $20,500 per year) 
  • Aggregate Borrowing Limit: $100,000 (excludes borrowing as an undergraduate student) 

Undergraduate students  

  • Annual Loan Limit
    No Change (remains at up to $7,500 per year for dependent students and up to $12,500 for independent students, each depending upon grade level)
     
  • Aggregate Borrowing Limit
    No change (remains at $31,000 for dependent students and $57,500 for independent 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. 

  • The final regulations published on May 1, 2026 defined a professional program (for purposes of federal student loan limits); that definition applies to the following programs at the U: Doctor of Dental Surgery (DDS, Dentistry); Juris Doctorate (JD, Law); Doctor of Medicine (MD); and Doctor of Pharmacy (PharmD). 
  • In addition, due to a federal court order, the following programs are also considered ‘professional’ while the court hears a case challenging the definition in the final regulation:  Doctor of Audiology (AuD); Doctor of Nursing Practice (DNP); Doctor of Occupational Therapy (OTD); Doctor of Physical Therapy (DPT); Master of Arts and Master of Science in Speech-Language Pathology (MA.SLP, MS.SLP);  Master of Athletic Training (MAT); Master of Physician Assistant Studies (MPAS); Master of Science in Nursing (MSN). [NOTE: These are temporary designations and may change; students in these programs are encouraged to consider borrowing at the lower annual level ($20,500) to avoid a potential overaward should the court rule that the May 1, 2026 definition of professional programs (which excluded these programs) stands.]
  • The increase to the annual borrowing limit for Unsubsidized Federal Direct Loans for students enrolled in Professional degree programs will offset some of the loss of the GradPLUS loan program (see below); Note the increased annual limit of $50,000 is an additional $29,500 above existing annual limit for students enrolled in Professional degree programs.
  • Prior to OB3, students enrolled in certain health-related  programs (at the graduate and professional levels) were eligible for additional federal student loan limits under the program known as “HEAL”this additional HEAL eligibility was eliminated unless such students qualify for the limited legacy* exception to the OB3 rules.

 

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. 

  • As noted above, the annual limit for borrowing under the Federal Direct Student Loan will increase for students enrolled in Professional degree programs, which will mitigate some of the loss of borrowing under the eliminated GradPLUS loan program. 
  • However, for students enrolled in Graduate degree programs, as well as some students enrolled in Professional degree programs, the loss of the GradPLUS program leaves private student loans as the primary remaining option for funding unless they qualify for the limited legacy* exception.

     

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  

  • For a dependent student whose parent(s) borrowed a Parent PLUS loan on their behalf, the PLUS loan amount is excluded from this lifetime total 

(*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) 

  • This new rule requires calculating reduced borrowing limits based on the percentage of enrollment for the specific term and across the academic year. For example, a fourth-year student enrolled in an undergraduate degree program three-quarter-time would be eligible for an annual maximum of $5,625 ($7,500 annual limit x 0.75 = $5,625) under the Federal Direct Student Loan program (Subsidized and Unsubsidized combined). 
  • Note this reduction calculation applies to each term in the academic year and must account for all enrollment (and courseload reductions) throughout the academic year, even for those that occurred after a prior disbursement occurred
  • This provision is effective for the Fall 2026 semester and beyond.

 

For more detailed information on these and related topics, please access the following information pages: 

 

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  

  • When a student receives an overaward (defined as the case in which a student receives total aid from all sources in excess of their Cost of Attendance (COA)), the Pell Grant must not be reduced; rather, other aid is reduced to resolve the overaward, and in some very limited situations the overaward is allowed.

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.

 
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 

 
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: 

  • Deferment of loan repayment options – the bill ends the economic hardship deferment and the unemployment deferment; borrowers with federal student loans made on or before 07/01/2027 are still able to use these two deferment options under the current rules; once all of a borrower’s loans made prior to 07/01/2027 are paid in full, these options will cease to exist 
  • Forbearance of loan repayment – the bill changes forbearance for any federal student loans made on or after 07/01/2027 such that these loans are eligible for forbearance for up to nine months maximum in any two-year period. Current rules allow for a forbearance up to 12 months at a time, with a cumulative limit of three years. 
  • Loan rehabilitation – the bill allows borrowers to rehabilitate a defaulted loan twice, as opposed to once under current/existing rules; the minimum rehabilitation payment for Federal Direct Loans changes to $10 
  • Standard repayment plan (SRP) – the bill creates a new standard plan with four fixed terms of 10, 15, 20, or 25 years based on the amount borrowed (or outstanding balance if in repayment) 
  • New income-based repayment plan (RAP) – the bill creates a new income-based repayment plan called the Repayment Assistance Plan (RAP) in which the monthly payment is one to ten percent of income based on the borrower’s Adjusted Gross Income with reductions to the base payment for each dependent the borrower has; there is a $10 minimum monthly payment and no cap on monthly payment amount, and a 30-year repayment period; this change eliminates negative amortization 
  • New borrowers entering repayment – new loans made on or after 07/01/2026 can be repaid using only two plans—a new standard repayment plan (SRP) or the new income-based repayment plan (RAP); a borrower with such new loans who does not select a plan will be assigned to the SRP; note that all loans must be paid under the same repayment plan, thus, borrowers with loans made before 07/01/2026 who take out additional loans on or after this date will only have RAP and SRP as options 
  • Current borrowers entering or in repayment – borrowers with no new loans made on or after 07/01/2026 are eligible to enroll in the current Standard, Graduated, Extended, or existing Income-Based (IBR) repayment plans, and they may also opt into the new RAP; current borrowers may also switch between, enter or remain on existing income-driven repayment plans until 07/01/2028 
  • Existing Income-Based Repayment (IBR) plan – the bill removes the requirement for borrowers in the existing IBR plan to demonstrate a partial financial hardship; the bill retains cancellation of balances of loans repaid under IBR at 25 years (or 20 years for new borrowers) 
  • Repayment options for Consolidation loans – Consolidation loans made on or after July 1, 2026 are only eligible for the RAP or SRP; there are several additional provisions applying to Consolidation loans in which decisions or actions must be made prior to 07/01/2028 and if not, then all eligible loans will be automatically moved to RAP and any loans not eligible for RAP will be moved to IBR; if you are or will be considering consolidating your federal student loans, be sure to consult with your loan servicer(s) regarding options 
  • Repayment options for ParentPLUS loans – all new ParentPLUS loans made on or after 07/01/2026 must be repaid under the SRP and are not eligible for RAP; should a borrower choose RAP for an ineligible loan such as ParentPLUS, they must repay the ineligible loans separately (for borrowers who had borrowed a ParentPLUS loan prior to 07/01/2026 and subsequently borrowed from the program on or after 07/01/2026, repayment must be under the same repayment plan which will be SRP)  
Last Updated: 8/31/26