This page is for informational purposes only and is based on the current understanding of the One Big Beautiful Bill Act’s proposed implementation by the U.S. Department of Education. This information is subject to change pending final regulatory text.
Last updated: Thursday, January 22, 2026
The One Big Beautiful Bill Act (OB3 or OBBBA) was signed into law on July 4, 2025, through the federal budget reconciliation process. This legislation contains significant provisions that reshape federal student financial aid nationwide.
More information is available from the National Association of Student Financial Aid Administrators (NASFAA).
Some of the key changes include the following:
Early 2026
Notice of Proposed Rulemaking (NPRM) published.
First official look at proposed rules.
Early 2026 (after NPRM published)
Public comment period.
Starts immediately after NPRM is published. 30 or 60 days.
Spring 2026
Final Rules published.
Final Rules are published with potential changes made based on public comment period feedback.
July 1, 2026
Rules go into effect.
Institutions now must abide by the rules.
Learn more about common questions regarding the One Beautiful Bill Act.
No, effective July 1, 2026, Students who receive grants or scholarships from non-federal sources covering their entire cost of attendance (COA) are ineligible to receive a Pell Grant, even if otherwise eligible for the program.
No, students who meet the legacy provisions may not forfeit their legacy borrower status and must continue to borrow under the current loan regulations prior to OB3.
A professional student is a student enrolled in a program of study that awards a professional degree upon completion of the program. A professional degree is a degree that signifies both completion of the academic requirements for beginning practice in a given profession, and a level of professional skill beyond that normally required for a bachelor’s degree; is generally at the doctoral level, and requires at least six academic years of postsecondary education coursework for completion, including at least two years of postbaccalaureate level coursework; generally requires professional licensure to begin practice; and includes a four digit program CIP code that are the same as the 11* spelled out (medicine, pharmacy, law, divinity, etc.) but must also lead to licensure and have at least two years of post-baccalaureate study.
*Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), Theology (M.Div., or M.H.L.), and Clinical Psychology (Psy.D. or Ph.D.).
Note: Graduate-level students who do not meet this definition are considered graduate students.
More information from NASFAA regarding professional students >
Federal full-time status is 12 credits per semeseter for undergraduate students and 9 credits per semester for graduate students.