ACE, Higher Ed Groups Urge Delay in Implementing One Big Beautiful Bill

In comments submitted to ED on Aug. 28, the associations stressed that the complexity of the OBBB-which overhauls federal student loan systems, repayment plans, accountability procedures, and aid packaging-requires more time, clearer guidance, and sufficient staffing to avoid disruptions for students and institutions. Forty-two associations endorsed the comments, representing every sector of higher education, including public and private institutions, accreditors, and discipline-specific organizations.

ACE and the associations asked ED to work with Congress to postpone implementation until at least July 1, 2027. Under current timelines, final rules could not be issued until spring 2026 at the earliest, leaving institutions and vendors only a few months to make extensive system changes before a July 2026 effective date. Also by regulation, any rule published by Nov. 1 must take effect the following July, underscoring the need for delay.

"Given the massive disruptions of the flawed launch of the new FAFSA, it is essential that we avoid another large-scale disruption of our aid and lending systems," the associations wrote.

Key Concerns

The comments identify several areas requiring clarification and additional support:

• Clear communication on loan limits and repayment changes. Institutions and families need timely guidance to navigate new annual and aggregate loan limits, as well as repayment options. ACE's survey of institutions showed concerns that changes will restrict access for graduate and professional students and reduce enrollment of low-income and first-generation students.
• Professional degree definitions. The OBBB raises borrowing limits for professional students but relies on vague regulatory definitions. ACE urged ED to publish a comprehensive list of covered degree programs to avoid confusion.
• Department staffing. Recent cuts in career staff at ED have already led to service delays. With OBBB's additional $1 billion in student aid administration funding, ACE called for restoring capacity to ensure smooth implementation.
• Data transparency. Since the law ties Title IV loan eligibility to program-level graduate earnings, the groups urged ED to release median earnings data and calculations in a clear and timely way, enabling institutions and students to make informed decisions.
• Pell Grant packaging rules. The OBBB alters the longstanding "first-dollar" structure of Pell Grants. ACE requested clarification that Pell should remain first-dollar except in cases where other aid fully covers the cost of attendance, consistent with congressional intent.
• Institutional accountability and reporting. The law's accountability provisions are ambiguous and risk being applied retroactively. The associations called for forward-looking implementation and clearer guidance on reporting, appeals, and how new programs will be evaluated.
• Negotiated rulemaking participation. ACE asked that financial aid administrators be added to the negotiated rulemaking committees, given their central role in implementing aid programs. The comments also recommended reinstating prior categories to ensure diverse representation, including community colleges, Historically Black Colleges and Universities, Hispanic-Serving Institutions, and other mission-driven institutions.

The associations emphasized that they stand ready to work with ED to ensure implementation of the OBBB strengthens, rather than disrupts, access to higher education. They also urged the agency to provide clarity, sufficient time, and the necessary staffing to carry out the law in a way that supports students, families, and campuses nationwide.