H.R. 1 Act Impact on Federal Aid and Student Loans

The H.R.1 Act 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 This applies to dropped or withdrawn courses at any point in the academic term.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 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.)
  • 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.
  • Federal loan repayment programs will be simplified and details are still being finalized by the U.S. Department of Education.
FAQs

What is the H.R. 1 Act?

The H.R. 1 Act was a federal budget reconciliation act signed into law on July 4, 2025. It is also known as the One Big Beautiful Bill Act (OB3) or Working Families Tax Plan. 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 H.R. 1 Act requires schools to reduce federal loans for any student completing less than full-time credit hours (12 credits for undergraduates and 8 credits for graduate/professional students). 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 “legacy borrower” 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 “legacy borrowing” exceptions. 

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.

The H.R.1 Act allows current Direct Loan borrowers (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 up to three additional years or until the standard length of their degree program has elapsed, whichever is less. These students are referred to as “legacy borrowers.”

If a legacy 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 legacy borrower status and 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 legacy borrowing eligibility.

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 H.R.1 Act. 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.

Existing borrowers meeting the “legacy borrower” criteria continue to have access to the federal student loans programs as they have previously, including the GradPLUS loan. A borrower’s “legacy borrower” status remains active until they complete their program, no longer meet “legacy borrower” guidelines, or enroll beyond the three year legacy borrower extension, whichever comes first. “Legacy borrowers” 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 “legacy 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. H.R.1 Act allows current Direct Loan borrowers (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 up to three additional years or until the standard length of their degree program has elapsed, whichever is less. These students are referred to as “legacy borrowers.” A key component of “legacy borrower” 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 “legacy borrower” status.

Example: A continuing M.S.W. student who is a legacy borrower 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.

What semesters are covered by my 2026-2027 FAFSA?

Fall 2026, winter 2027, and spring/summer 2027

Note: Students admitted into spring/summer 2026, including students admitted into the Summer Bridge program, must also complete the 2025-2026 FAFSA to be offered summer aid.

When will the 2027-2028 FAFSA 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

2026-2027 Updates

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.
Key FAFSA Updates From the FAFSA Simplification Act
  • The FAFSA has been streamlined and is more user-friendly with fewer questions.
  • The Student Aid Index (SAI) replaced the Expected Family Contribution (EFC).
  • Federal aid eligibility was extended to more students.
  • IRS Direct Data Exchange (DDX) was launched to make entering tax information easier and will be required for students, spouses, and parents to transfer their tax information or non-filing status.
  • The number of family members in college no longer factors into the FAFSA calculation.
  • Untaxed items such as payments to tax-deferred retirement or pension plans, veteran’s non-educational benefits, and worker’s compensation are no longer required.
  • For divorced or separated parents: The parent who provided the most financial support to the student will need to provide their information. Previously, the parent who the student lived with the most provided their information.
  • Everyone contributing to the FAFSA form online must have their own account on the Federal Student Aid (FSA) website. Each contributor, including the student, will access their account with their own FSA ID (account username and password).
Terms To Know
  • 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.