ED Changes Guidance on Calculating Expected Time to Credential

By NASFAA Policy & Federal Relations Staff

During the webinar on August 12th, Implementation of New Loan Limits and Interim Exception for Continuing Students, ED staff instructed schools to use credits instead of time as the basis of calculating Expected Time to Credential (ETTC), a key component of eligibility for the interim exception to new loan limits enacted under the One Big Beautiful Bill Act (OBBBA). This is a significant departure from guidance offered in previous office hours and ED’s loan limits FAQ that have all consistently instructed schools to calculate ETTC by determining the difference between the program length in weeks, months, or years (as defined by the institution) and the period of the program of study that the student has completed prior to July 1, 2026. Under certain circumstances, this will result in a different ETTC, and may impact a student’s loan eligibility.

NASFAA has followed up with ED to request clarification, but also to convey the significant impact a change of this magnitude will have on disbursement of aid to students. Summer header schools have disbursed loans based on previous guidance and others are actively welcoming thousands of students to campus who are in need of their aid. Change in eligibility status mid-cycle introduces more confusion and delay in disbursing aid to students arriving on campus. NASFAA has not received a response from ED, but stay tuned to Today’s News for updates.

Publication Date: 8/14/2026

Bee S | 8/30/2026 2:57:49 PM

Re-reading through the statutes and comments now as still struggling to make sense of everything -- I keep seeing the word "clearly" as in the statute "clearly" states. Clearly, it is not clear -- specifically, what constitutes "the period of such program of study that such individual has completed". In June DOE seemed to say this had only to do with the time the student had attended and nothing to do with credits. Now they are saying, it's a conversion into time of credits completed including transfer credits compared to the minimum required to graduate. The key being that to convert into time one must divide by the credits per annual year for the program. Are we in a "choose your own adventure" book where we get to decide which way we like best and then eventually we'll find out if we made a terrible mistake or if we stumble upon a great reward? This is so exciting.

Katherine A | 8/14/2026 4:52:03 PM

Does what is uttered during Office Hours constitute official guidance? We are going to stick with what's written. We need to get our grad students packaged!

Elisabeth K | 8/14/2026 2:4:06 PM

I don't think ED is allowed to amend the statute, only Congress can do that, and the statute clearly states:

(B)Expected time to credential
For purposes of this paragraph, the expected time to credential of an individual shall be equal to the lesser of—
(i)three academic years; or
(ii)the period determined by calculating the difference between—
(I)the program length for the program of study in which the individual is enrolled; and
(II)the period of such program of study that such individual has completed as of the date of the determination under this subparagraph.

(C)Definition of program length
In this paragraph, the term “program length” means the minimum amount of time in weeks, months, or years that is specified in the catalog, marketing materials, or other official publications of an institution of higher education for a full-time student to complete the requirements for a specific program of study.

20 U.S. Code § 1087e (a)(8)(B) and (C)

Alexandria H | 8/14/2026 1:53:41 PM

Internally screaming.

Our medical school students started over a month ago.

Michelle P | 8/14/2026 10:13:38 AM

OK so if we're to use remaining credits to credential wouldn't that also mean time frame limitations for SAP etc are out the window???!!! This is ridiculous!

I hope there's a thorough back-track on this soon.

Joshua M | 8/14/2026 10:10:52 AM

DONT ASK FOR ANY MORE "CLARIFCATION" just make your own policy based off the CFRs... the more you ask the more conflicting info they give

Joshua M | 8/14/2026 9:53:15 AM

I'm going off the CFR not the 'office hours' suggested guidance. this is ridiculous.

Aaron S | 8/14/2026 9:32:05 AM

Office Hours are useful for discussion and clarification, but they are not, by themselves, official published guidance that institutions can reasonably rely upon for compliance purposes.

Given that ED has apparently changed its interpretation of how Expected Time to Credential (ETTC) is calculated based on information provided during an Office Hours session, can schools expect this clarification to be issued through an official guidance mechanism—such as a Dear Colleague Letter, Electronic Announcement, Federal Register publication, or at a minimum, an update to the Federal Student Aid Handbook?

The regulatory language in 34 CFR 685.102(b) establishes the definition of Expected Time to Credential. If ED is changing or materially clarifying how institutions are expected to apply that definition, schools need something more authoritative than a verbal statement made during an Office Hours session.

Financial aid offices are being asked to make eligibility and loan-limit determinations with significant compliance implications. We should not have to rely on institutional recollections of what was said during a webinar or on a subsequent interpretation published by NASFAA to establish what ED considers compliant.

Can ED please provide this clarification through an official, published guidance vehicle?

John S | 8/14/2026 9:20:52 AM

My hope is ED will clarify that the method described in the webinar was only an example for when a school is choosing to use credit hours (not that credit hours MUST be used over program length measured in other units like weeks, months, or years).

Daniel D | 8/14/2026 8:24:59 AM

How are we supposed to do our job when ED doesn't know what they are doing and change policy every other day?

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ED Changes Guidance on Calculating Expected Time to Credential

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