By Maria Carrasco, NASFAA Staff Reporter

With the start of the 2026-27 award year just under two months away, and final regulations being issued just last week, schools across the country are struggling to implement the sweeping changes made under the One Big Beautiful Bill Act (OBBBA), prompting some financial aid professionals to warn that this condensed implementation timeline could lead to delays in the disbursement of aid to students. 

Since OBBBA was signed into law on July 4, 2025, the Department of Education (ED) has worked to implement the sweeping changes of the law through two negotiated rulemaking sessions. Both the Reimagining and Improving Student Education (RISE) Committee, which focused on implementing new loan limits, and the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee, which focused on the creation of a new Workforce Pell Grant program and institutional accountability metrics, ultimately reached consensus on ED’s proposed regulations. 

However, ED is not following the normal timeline for promulgating new regulations. Because the OBBBA set July 1, 2026, as the effective date for many of the student aid provisions, ED determined that it does not have to follow standard master calendar rules, which, per the Higher Education Act (HEA), would have required a final rule to have been published by November 1, 2025. Since reaching consensus, ED has published three Notices of Proposed Rulemaking (NPRM) through the Federal Register, with the goal of finalizing these rules in May and June. 

This expedited timeline presents a slew of challenges for schools to manage, with some voicing fears that the quick turnaround in implementation could create issues for students, including delays in disbursing student aid. 

“Without final rules, schools are having to be reliant on what they've heard in certain places,” said Jill Desjean, NASFAA’s director of policy analysis. “What we've been faced with has not just been not having information, but sometimes getting information, and it is not final. We saw that even at the FSA conference. An ED official would answer a question, and then the next day they would come back and say, ‘Well, we're looking at that some more.’”

Already, the financial aid community has seen ED reverse its course on unofficial guidance. In mid-April, ED told NASFAA that Graduate PLUS loans will be included in the new $257,500 lifetime borrowing limit established through OBBBA. Prior to that, ED had consistently communicated that Graduate PLUS loans would not count toward the lifetime limit. 

“It's not even the lack of information – it is that sometimes information comes, we assume that it's good information, and then it changes,” Desjean said. “That's the challenge of working in an environment without a final rule.”

ED published its final rules for its new loan limit regulations made under the RISE Committee on May 1. However, final rules do not necessarily resolve all outstanding questions, since it is common practice for ED to issue subregulatory guidance to help schools operationalize the regulations after the final rules have been published.

This implementation timeline is already stressful for schools, which have to communicate these changes to both their campus offices and students. However, summer header schools face an even tighter timeline, with many programs beginning as early as May, and, as a result, are having to estimate aid offers to students. 

“We are already packaging students for summer because we're out of school, and [students] need to know what they're going to get,” said Heidi Carl, assistant vice provost and executive director of the division of financial aid at Purdue University and NASFAA’s 2025-26 national chair. “We've already pretty much been told by our software provider that we won't have information soon enough to figure out how to program this. So [aid professionals] are going to have to figure this out themselves.”

An important area of ongoing confusion concerns “grandfathering,” also known as legacy provisions, which determines which loan limits apply to individual students. This is especially important for graduate and professional students, as the Grad PLUS loan program sunsets on July 1, 2026, and for parent borrowers, who will see new caps on Parent PLUS loans.  

Along with waiting for guidance from the department, on April 26, ED implemented sweeping OBBBA changes to the layout of Institutional Student Information Records (ISIR), and updates to the Common Origination and Disbursement (COD) system, along with new fraud prevention measures to the FAFSA.

NASFAA spoke with several financial aid administrators to share their concerns about this tight timeline, ED’s lack of guidance, and other issues facing the profession, as many OBBBA provisions are weeks away from enactment. 

‘This Is A National Problem’

Marvin Smith, executive director of financial aid and scholarships at the University of California, Los Angeles, warned that due to the sweeping changes Federal Student Aid (FSA) is making, schools may not be able to disburse aid to students in May. And if those students don’t receive their aid, there could be long-lasting effects on their lives – such as not being able to pay for their schooling, rent, groceries, and more. 

Smith stressed that this is a problem for schools across the country, but it is particularly exacerbated for summer header schools.

“This is a national problem,” Smith said. “I think the summer header schools are like the canary in the coal mine, that we're going to know where the problems are. This is a major change to ISIR, FAFSA, NSLDS, and COD records. So I personally am more worried about federal loans, but there's even a chance that Pell Grants will be impacted, because COD is changing.”

A big concern is whether ED, software vendors, and schools will be able to implement these new regulations in time to give students accurate aid offers and ultimately, have their aid disbursed on time. While this issue is especially impactful for students in summer programs, several aid professionals warned that it could impact students for the entire 2026-27 academic year.

A big lift for schools is having to manually create estimated aid offers for summer students since systems aren’t yet updated and running. Tim Wold, interim executive director of financial aid and scholarships at the University of Washington, stressed that the number of manual interventions financial aid administrators will have to endure throughout the 2026-27 year could result in possible delays in aid disbursement. 

“It's going back to 10 keys and pencil and paper,” Wold said. “I keep joking with my staff about that, but that's really what it's going back to, at least for [this year,] until we can really understand and figure out how to program a lot of this. But that's pretty significant for schools our size.”

Carl also raised concerns about her office having to perform manual calculations because software vendors are uncertain about whether their software will be updated in time to comply with OBBBA regulations. 

Another aspect that Brad Barnett, associate vice president for access and enrollment management and director of financial aid and scholarships at James Madison University (JMU), pointed out is that there will be students in the COD system that will not have their legacy status correctly marked. That means aid professionals will need to call COD for each individual student whose status is incorrectly marked — a huge administrative burden on schools, he said.

“All of these issues are uncharted territory for financial aid professionals,” Barnett said. 

“The challenge is the need to communicate to students and campus partners, since summer is upon us, but not knowing exactly what to communicate because we don’t have final rules,” Barnett added. “We only have bits and pieces. ED is under a tight timeline based on the OB3 legislation at a time when they also have fewer staff. We all — ED and schools — are under a timeline that I haven’t seen in 30 years of working in this field.”

Solutions Schools Are Using

Throughout this confusion, schools are communicating updates to their campus offices and students. Some schools are posting updates on their websites for students, such as James Madison University, which has an entire webpage dedicated to OBBBA updates. Barnett added that his institution is also communicating this information with new students and will begin contacting current students soon. 

Other schools are dipping into their own funds to help students during this uncertain time. Smith noted that UCLA’s dental and medical schools are committed to providing emergency resources to some of their students because of the uncertainty about whether they’ll be able to disburse loans in May for summer programs. However, many schools don’t have the ability to provide this support. 

Other institutions are discussing not charging late fees for impacted students who will not receive their loans in time to pay their bills.

As they plan proactive outreach, financial aid professionals are tasked with striking a delicate balance between providing some assurance and stoking panic among students.

“I don't want to communicate this to students until I know what to tell,” Smith said. “I don't want to panic them. So I don't have anything on our website or anything that says we might not disburse your rent money this summer.”

Valerie Miller, assistant vice president and executive director of student financial aid and scholarships at Ohio University, stressed that schools are working hard to communicate loan limit changes to students. 

“All of us do this because of the students,” Miller said. “The uncertainty for students and the lack of them being able to really determine how affordable something even is for them, considering the focus on affordability [in our profession], it's really counter to that.”

‘This Is More Labor-Intensive Than FAFSA Simplification’

Over the past six years, financial aid offices have faced challenge after challenge. That includes the COVID-19 pandemic and administration of the Higher Education Emergency Relief Fund (HEERF), the rollout of FAFSA simplification, and now the implementation of OBBBA, Carl noted.

That’s among other issues, such as staffing shortages and administrative burnout in aid offices. 

“It almost feels crushing at times,” Carl said. 

Implementing the provisions of OBBBA has been just as, if not more, labor-intensive than the rollout of FAFSA simplification, according to UCLA’s Smith. 

“This is what you sow when you try to get rid of a Department of Education,” Smith said. “These students will suffer this summer. We're trying to do all we can to prevent them from suffering, and we turn ourselves into pretzels doing that.”

For Carl and many financial aid professionals across the country, support from others in the profession has been key to getting through this tough time. 

“The one thing I do want to make sure I stress is we do it because of each other,” Carl said. “That's part of what I love about this profession, is how much we are willing to kind of lend a hand and pull each other up and help each other along. It's not like we have insider trade secrets because we understand that, at the end of the day, it's about helping a student afford college. And we all want all students to afford college, even if they're not at my institution.”

Publication Date: 5/6/2026

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