Budget Reconciliation Act Impact on Federal Aid and Student Loans

One Big Beautiful Bill Act (OBBBA) introduces significant changes to federal aid and federal student loans beginning in 2026-2027. Although some guidance has been released by the U.S. Department of Education, information is still needed to fully understand how changes will impact students and aid. Please speak with the Office of Financial Aid about individual circumstances as the loan changes have legacy provisions for current borrowers for a limited time. As information becomes available, we will update our website.

FAFSA:

  • Foreign income will be included in a family's Adjusted Gross Income, even if it was excluded for tax purposes through a Foreign Income Exclusion.
  • Family-owned small business/farm assets do not need to be reported on the FAFSA.

Federal Pell Grant:

  • Eligibility limitations apply to families with high SAI.
  • Eligibility limitations apply if the full cost of attendance is already being covered by other state, private, and/or institutional scholarships and grants.

Federal Direct Loans: 

  • All Direct Loan student borrowers: Loan eligibility is reduced for less than full time enrollment. (Applies to all borrowers at all degree levels.) Full-time students may borrow up to their full loan eligibility, but any students enrolled less than full time will have loans reduced based on their percentage of enrollment. This applies to dropped or withdrawn courses at any point in the academic term.
  • Parent PLUS borrowers: For each dependent student, parents are now limited to borrowing up to $20,000 annually in Parent PLUS loans. Additionally, parent borrowers will have a new overall borrowing limit per student of $65,000.
  • New Direct Loan graduate/professional student borrowers: Graduate and professional students will have new Direct Unsubsidized Loan borrowing limits based on their degree program. Graduate students will be limited to borrowing $100,000 overall for their graduate degree. Students in professional programs have different limits. Note that graduate students in the School of Nursing will be offered standard graduate level loans pending the outcome of legal challenges to the U.S. Department of Education's defined professional programs.
  • The Graduate PLUS program has been eliminated and will no longer be available to new graduate/professional degree students and new Direct Loan borrowers beginning in 2026-2027. A limited group of existing graduate borrowers qualifying for an interim exception to the new loan limits may have continued eligibility for this loan for a limited time.
  • Federal loan repayment programs have been simplified into a tiered standard repayment plan and a single income-driven plan known as the Repayment Assistance Plan (RAP).
OBBBA FAQs

What is the One Big Beautiful Bill Act (OBBBA)?

The OBBBA was a federal budget reconciliation act signed into law on July 4, 2025. It is also known as the Working Families Tax Cuts Act and H.R. 1. Learn more about the impact on student aid from the U.S. Department of Education on the One Big Beautiful Bill Act Updates webpage.

What will happen to my 2026-2027 loans if I drop a class and enroll part time?

The OBBBA requires schools to reduce federal loans for any student completing less than full-time credit hours. For undergraduate students, full-time enrollment means completing at least 24 credit hours in an academic year, or 12 credits per term; graduate students must complete at least 16 credit hours in an academic year, or at least 8 credits per term to be considered full time for loans. For example, if you enroll half time then your direct loans must be reduced to half of what your eligibility is for the term. This reduction applies to subsidized, unsubsidized, and Graduate PLUS Direct Loans.

If your credits drop below full time (12 credits for undergraduates and 8 credits for graduate/professional students) by the add/drop date for the term, then your tuition rate is adjusted and your loans for the term will be reduced based on your actual enrollment. 

If your credits drop below full time after the add/drop date in the term, be aware that your tuition is not adjusted but your borrowing eligibility is still reduced. Rather than reduce already disbursed loans, you may see the reduction applied to any upcoming loans scheduled for the year. In this case, it is important that you plan ahead for the reduced aid.

Will any of my loans be impacted if I switch from an Engineering undergraduate program to LSA?

Undergraduate students transferring internally between U-M schools and colleges retain their eligibility to be considered for parent PLUS loan borrowing limit exceptions. Switching majors, minors, concentrations, and programs at the undergraduate level will not have an impact since you are still a bachelor’s degree student at U-M. That’s what matters for parent borrowing exceptions. 

Note that graduate and professional student borrowing eligibility is linked to the academic program of student. Unlike undergrads, a graduate student qualifying for the interim exception to OBBBA loan limits must remain enrolled in credits toward the same degree program. Students pursuing joint graduate degrees should speak with financial aid about their enrollment plans to learn more about possible impacts on borrowing eligibility.

What happens to my aid eligibility if I stay an extra term or year to complete my degree?

In general, as long as you are meeting Satisfactory Academic Progress guidelines then you are eligible to continue receiving financial aid.

OBBBA allows some current Direct Loan borrowers (generally those who have borrowed Direct Loans on or before June 30, 2026, for an ongoing degree program) to continue to utilize federal loans without being impacted by most changes for a limited time. These borrowers have what is known as an "interim exception" exempting them from some of the new loan limits. These students are referred to as “legacy borrowers.” The exception cannot exceed the lesser of three years of loan borrowing or the remaining time the borrower would generally need to complete their program assuming full-time progress towards their degree and after factoring in how long they have already been enrolled.

If an interim exception borrower enrolls longer than it generally takes to finish their degree (ex: a fifth year senior or a third year masters degree student) or if their standard enrollment lasts longer than the three year extension, they will lose eligibility for the loan limit exception and immediately become subject to the new Direct Loan rules. This could impact the borrower’s ability to utilize Graduate or Parent PLUS loans. There is no appeal process for extending interim exception borrowing eligibility.

Why are my AP credits impacting my eligibility for the borrowing interim exception?

The U.S. Department of Education requires aid offices to include all credits counting toward your degree, including transfer credits and credits earned by exam (AP/IB), when determining if and how long an interim exception to the new loan limits may be granted. Since these credits count toward a degree in aggregate, the definition of full-time for financial aid (12 credits per term for undergraduate students and 8 credits per term for graduate/professional students) is used to convert those credits into equivalent full-time terms. This calculated equivalency becomes part of your time already spent pursuing your degree.

I’m in the PharmD program and borrow loans each year. Why are new students in my program being offered more in unsubsidized loans than me?

Certain degree programs have been identified as professional degrees eligible for increased Federal Unsubsidized Direct Loans in the OBBBA. At U-M, these programs include the M.D., J.D., Pharm.D., and D.D.S. degrees. Beginning July 1, 2026, new professional program federal loan borrowers are eligible to borrow up to $50,000 per year and up to $200,000 total over the duration of their post-undergraduate professional degree program(s). Financial aid offers for new borrowers pursuing these specific degrees are based on the new $50,000 per year maximum unsubsidized loan eligibility.

Note that there is a pending legal challenge to the list of professional degree programs defined as eligible for professional level loans by the U.S. Department of Education. While the case is pending, the court has authorized temporary allowances to increase the loans for certain programs, like graduate nursing. However, should the government win the legal challenge, the increased borrowing will count against the standard graduate total eligibility of $100,000, significantly reducing what can be received for the remainder of the degree program. While the case is pending and to limit confusion and disruption to borrowers, the University of Michigan is continuing to offer graduate-level loans to graduate nursing students. Those loans can be increased if a final decision permanently changes eligibility.

Borrowers qualifying for the interim exception must be offered loans consistent with their prior eligibility, even if loans are less than what new borrowers in the same degree program qualify for under the new rules. The U.S. Department of Education has indicated that “interim exception" borrowers may not opt out of this status and must be offered loans consistent with prior eligibility until such time they no longer qualify.

I’m currently enrolled in two graduate degree programs. Will I be able to continue borrowing Graduate PLUS loans?

It depends. OBBBA allows Direct Loan borrowers (qualifying for the interim exception) to continue to utilize federal loans without being impacted by most changes for a limited time. A key component of “interim exception” eligibility is continuing to enroll in the same degree program.

If you enroll in different programs between terms or in different academic years, current U.S. Department of Education guidance suggests that you will lose access to your “interim exception” status.

Example: A continuing M.S.W. student who is qualifies for the interim exception enrolls in MSW credits (majority enrollment) in the fall term and borrows GradPLUS for fall. In the winter term, this student enrolls in courses towards their MBA degree. Do they lose the ability to borrow GradPLUS?

Yes. By changing from M.S.W. enrollment to M.B.A. enrollment, the student no longer qualifies for legacy borrowing and is subject to the new Direct Loan rules. GradPLUS loans are only available to legacy borrowers so the student can no longer borrow in that program to help with educational costs. Private educational loans would still be a possible resource.

Aid Application FAQs

What semesters are covered by my 2026-2027 FAFSA?

Fall 2026, winter 2027, and spring/summer 2027

Note: Students admitted into spring/summer 2027, including students admitted into the Summer Bridge program, must complete the 2026-2027 FAFSA to be offered summer aid.

When will the 2027-2028 FAFSA and CSS Profile become available?

Oct. 1, 2026

When is the 2027-2028 aid application(s) filing date for UM-Ann Arbor?

  • Early Decision undergraduate applicants: Submit your aid applications (CSS Profile and FAFSA) by Nov. 15.
  • Early Action and Regular Decision undergraduate applicants: The suggested filing date is Dec. 15 to submit the CSS Profile and FAFSA. This is not a deadline, but ensures we can provide preliminary financial aid information sooner. The deadline to apply is March 1.
  • Graduate/Professional applicants: Submit your FAFSA only by March 1.
  • Returning U-M students: Submit your FAFSA only by May 1.

What school code should I use for the FAFSA?

The UM-Ann Arbor school code is 002325. Be sure to look for UM-Ann Arbor specifically as there are different codes for each campus.

What school code should I use for the CSS Profile?

Use the U-M school code: 1839.

My parents are separated or divorced. Which parent is a contributor for my FAFSA?

The parent who provides the most financial support to the student should be the contributor on the FAFSA.

Note that both biological parents must provide CSS Profile information. For your primary CSS Profile application (Household A), use the same parent used on the FAFSA. The other parent will complete a separate CSS Profile Household B.

How can I be considered an independent student?

The FAFSA will determine if you meet any of the criteria to be considered independent. Learn more about dependency status.

I’m a graduate student. How do I apply for financial aid? 

U-M graduate student financial aid processing relies on the FAFSA. Learn more about graduate student aid.

I’m a current U-M student. When will I receive my financial aid package? 

Current U-M students can submit the FAFSA at any time once it is available on Oct. 1 and are encouraged to do so by May 1. Financial aid notices for returning students are typically emailed in July.

Plan Ahead for 2027-2028

The financial aid applications for the 2027-2028 academic year will not be available until Oct. 1, but you can still plan ahead by reviewing key information below.

Applicants/Incoming Undergraduate Students:

  • Apply early! You don’t have to be admitted to apply. Complete both the CSS Profile and FAFSA as soon as possible, by Nov. 15 (Early Decision applicants only) or apply by Dec. 15 (for Early Action and Regular Decision applicants) to receive your financial aid package sooner, get earlier consideration for scholarships from your school/college, and have more time to fix any issues if they come up.
  • Admitted undergraduate students who have submitted their aid applications, will receive their estimated financial aid package approximately two weeks after receiving their admissions decision, which is our typical window. This allows admitted undergraduate students to have information about the financial support available to them from U-M when evaluating their options.
  • Learn more about applying for aid.

Returning Undergraduate Students:

  • The 2027-2028 FAFSA will become available on Oct. 1. Complete yours no later than May 1. Financial aid offers for the 2027-2028 academic year will be emailed in the summer.
  • You do not need to resubmit the CSS Profile. The CSS Profile is only completed in your entering year. If you have never completed it, complete the CSS Profile by May 1. 

Graduate and Professional Students:

  • Graduate and professional degree applicants should complete the 2027-2028 FAFSA by March 1. It will become available on Oct. 1. Financial aid offers will be emailed to admitted students with a completed FAFSA within a few weeks of receiving their admissions decision.
  • Returning graduate and professional degree students should complete the 2027-2028 FAFSA by May 1. The FAFSA for the upcoming aid year will become available on Oct. 1. Financial aid offers for the 2027-2028 academic year will be emailed in the summer.
Common Errors When Completing the FAFSA

Look out for these common mistakes when completing your FAFSA. If you submit the FAFSA and you need to make corrections, learn How To Correct or Update Your FAFSA Form on the Federal Student Aid website.

  • Missing or incorrect school code ​
    • Use UM-Ann Arbor’s Federal School Code (002325). Note that there are multiple school codes identifying different campuses in the University of Michigan system. It may not be immediately obvious which one you are choosing because of the way the names are listed. We encourage you to search for the Ann Arbor campus using our code (002325) and add it to your FAFSA. Michigan residents: U-M must be the first code listed for state scholarships to be directed correctly. University of Michigan Medical School (UMMS) students: Use UMMS’s school code (E00398).
    • Remove any University of Michigan school codes attached to your FAFSA that are not 002325 (E00398 for UMMS students) to ensure your aid application is directed to the correct campus.
  • No student signature
  • No parent signature
  • No student federal tax information (FTI) consent
  • Missing critical data from your parents (also called FAFSA contributors)
  • Missing or unconfirmed information about your U.S. citizenship status
Ways To Prepare
  • Apply for your FSA ID. A Federal Student Aid (FSA) ID is required for all contributors including the student.
  • Determine who your contributors are. The FAFSA will also offer assistance when filing. Students, parents, step-parents, and a student’s spouse may be considered contributors.
  • Gather Federal Tax Information and W-2s. All contributors will need this information, if applicable.
Terms To Know
  • Interim Exception: The interim exception grants some existing borrowers an exemption from new loan limits for a limited time. Borrowers qualifying for the interim exception are sometimes called "legacy" borrowers.
  • Student Aid Index (SAI): Calculated by FAFSA data and will determine student aid eligibility. This replaces the EFC that was used in previous years.
  • Cost of Attendance (COA): COA includes tuition and fees, food and housing, books and supplies (including course materials and equipment), miscellaneous expenses, and transportation.
  • Contributor: A parent, step-parent, student, or spouse of the student who is providing information to the FAFSA.
  • Consent: Required from all contributors in order for the IRS to share tax data directly to the FAFSA. If any contributor does not provide consent, the student will automatically be ineligible for aid.
  • Direct Data Exchange (DDX): Previously known as IRS Data Retrieval; this tool imports tax data directly from the IRS to your FAFSA.
  • FAFSA Submission Summary (FSS): A summary of your completed FAFSA information. This replaces the Student Aid Report (SAR) that was used in previous years.