BBB Chart 7.4.25.xlsx

	A	B	C	D	E
1	The table below provides a side-by-side comparison of existing law, the original House and Senate bills, and the final bill.	Source: NCAN
2	Provision	Current Law	House Reconciliation Bill	Senate Reconciliation Bill	Final Bill
3	Pell Grants and SAI Calculation
4	Enrollment requirements (DID NOT PASS)	Requires at least 12 credits per semester for full-time and six credits for half time enrollment for Pell	Requires at least 30 credits per year for full-time and eliminates eligibility for less than half-time for Pell	No change from current law	N o change from current law
5	Consideration of high assets, low-income in Pell eligibility calculation	Allows students with a low adjusted gross income (AGI), based on the poverty table, to receive Pell, regardless of their SAI. Typically, students with an SAI of more than ~$6,700 are not eligible for Pell unless their parental income meets the poverty table minimum.	Excludes students whose SAI is greater than or equal to twice the maximum Pell Grant from eligibility	Excludes students whose SAI is greater than or equal to twice the maximum Pell Grant from eligibility	Excludes students whose SAI is greater than or equal to twice the maximum Pell Grant from eligibility
6	Workforce Pell program	Pell not available for < 15 week programs	Establishes a Workforce Pell program: Students enrolled less than half-time are eligible; program duration must fall between eight- 15 weeks; the completion rate for the program must be at least 70%; and students will have to verify financial need.	Establishes a Workforce Pell program: Program duration must fall between eight-15 weeks , have a completion and job placement rate of at least 70%, and prepare students for high-demand careers.	Establishes a Workforce Pell program: Program duration must fall between eight-15 weeks , have a completion and job placement rate of at least 70%, and prepare students for high-demand careers.
7				Prohibits students from receiving a Pell Grant and a Workforce Pell Grant simultaneously.	Prohibits students from receiving a Pell Grant and a Workforce Pell Grant simultaneously .
8					Programs that are for-profit or unaccredited may not participate.
9	Pell shortfall	N/A	Provides $10.5 billion in federal funds over the next three fiscal years to address the shortfall	Provides $10.5 billion in federal funds over the next fiscal year to address the shortfall.	Provides $10.5 billion in federal funds over the next fiscal year to address the shortfall.
10	Consideration of additional grant funding in Pell eligibility determination	Additional grants do not impact Pell eligibility.	No change	Excludes students who have received grants that equal or exceed their cost of attendance from Pell eligibility.	Excludes students who have received grants that equal or exceed their cost of attendance from Pell eligibility.
11	Consideration of foreign income in Pell eligibility determination	Considers foreign income as untaxed income and does not include as part of AGI.	Includes foreign income as part of AGI, used to determine a student’s eligibility for the Pell Grant.	Includes foreign income as part of AGI, used to determine a student’s eligibility for the Pell Grant.	Includes foreign income as part of AGI, used to determine a student’s eligibility for the Pell Grant.
12	Treatment of small business and farm assets	Requires the net value of family farms and small businesses with less than 100 employees be used in the SAI calculation.	Exempts the value of family farm and small businesses with less than 100 employees in SAI calculation .	Exempts the value of family farm and small businesses with less than 100 employees in SAI calculation .	Exempts the value of family farm and small businesses with less than 100 employees and fishing businesses in SAI calculation.
13	Federal student aid eligibility for certain non-citizens ((DID NOT PASS)	N/A	Appears to eliminate eligible non-citizens with I-94 from USCIS with designations of Refugee; Asylum Granted; Haitian Entrant; Conditional Entrant; Victims of Human Trafficking; T-visa (T-2,3 or 4); and Parolee .	Appears to eliminate eligible non-citizens with I-94 from USCIS with designations of Refugee; Asylum Granted; Haitian Entrant; Conditional Entrant; Victims of Human Trafficking; T-visa (T-2,3 or 4); and Parolee, with the exceptions of “aliens of the Additional Ukraine Supplemental Appropriations Act and Afghanistan Supplemental Appropriations Act.”	No change from current law
14	Federal Student Loans
15	Student borrowing options and loan limits	Sets undergraduate loan limits of $5,500 total ($3,500 subsidized) for freshmen, $6,500 ($4,500 subsidized) for sophomores, and $7,500 ($5,500 subsidized), annually for juniors and beyond, with an aggregate maximum of $31,000.	Caps loans at the median cost of college program annually, establishes an undergraduate loan maximum of $50,000 in aggregate.	Maintains existing undergraduate annual and aggregate loan limits.	Maintains existing undergraduate annual and aggregate loan limits.
16		Allows parents to borrow PLUS loans up to the cost of attendance for their student and does not include borrowing requirements for students.	Requires undergraduate students to exhaust their unsubsidized loans before parents can use Parent PLUS to cover the remaining cost of attendance and sets an aggregate limit for Parent PLUS loans of $50,000.	Sets aggregate loan limit for Parent PLUS loans of $65,000, and an annual limit of $20,000, per dependent student and lifetime loan limit of $257,500 .	Cap loans to parents of undergraduates (parent PLUS) at $20,000 per student per year and $65,000 per student lifetime . Allows parents to borrow for multiple students.
17		Allows graduate students to borrow Grad PLUS loans up to the annual cost of attendance, excluding any other financial aid awarded.	Eliminates new Grad PLUS loans, starting with award year 2026-27, except for presently enrolled students.	Eliminates Grad PLUS loans starting in academic year 2026-2027 and sets annual unsubsidized loan limits at $20,500 for graduate students and $50,000 for professional students. Sets aggregate (lifetime) loan limits of $100,000 for first-time graduate students and $200,000 for professional students. Graduate limits are in addition to undergraduate limits.	Eliminate s Grad PLUS loans starting in academic year 2026-2027 and sets annual unsubsidized loan limits at $20,500 for graduate students and $50,000 for professional students. Sets aggregate (lifetime) loan limits of $100,000 for graduate students and $200,000 for professional students. Graduate limits are in addition to undergraduate limit s.
18		No aggregate loan maximum for combined undergraduate and graduate borrowing .	Caps graduate and professional borrowing at the median cost of program of study, annually, and establishes a loan maximum of $100,000 in aggregate for graduate students, or $150,000 in aggregate for professional students. These sums account for any amounts borrowed as an undergraduate .
19			Limits student borrowing to $200,000 in aggregate .
20	L oan repayment options	Includes multiple repayment options (Income-Based Repayment, Income-Driven Repayment, and Pay As You Earn) with time-based loan forgiveness, after 20 or 25 years of consistent, on-time payments.	Creates two repayment plans: a standard loan repayment plan, and a Repayment Assistance Plan (RAP) which would require a $10 minimum monthly payment, and forgiveness after 360 monthly payments (30 years). RAP caps payments at 15% of discretionary income, and 10% for recent borrowers. The government will cover unpaid interest and help pay down the principal each month.	Creates two repayment plans: a standard loan repayment plan, and a Repayment Assistance Plan (RAP) which would require a $10 minimum monthly payment, and forgiveness after 360 monthly payments (30 years). RAP caps payments at 15% of discretionary income, and 10% for recent borrowers. The government will cover unpaid interest and help pay down the principal each month.	Same language as House and Senate. Requires ED to facilitate current borrowers enrolled in income-contingent repayment plans (SAVE, PAYE, etc ) to opt into IBR or RAP by July 1, 2028. If borrowers d o not choose a plan ED , will select one for them.
21			Transfers those on Income-Contingent Repayment (ICR) to standard loan repayment plan.	Transfers those on Income-Contingent Repayment (ICR) to standard loan repayment plan.
22			Eliminates ICR and SAVE options.	Eliminates ICR and SAVE options.
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24	Public Service Loan Forgiveness (PSLF) for those in medical and dental residencies (DID NOT PASS)	Includes hours accrued through medical and dental internships in calculations for PSLF.	Excludes medical or dental internships and residencies from counting towards time accrued for PSLF. Instead, provides four years.	Excludes medical or dental internships and residencies from counting towards time accrued for PSLF.	No change from current law
25	Economic hardship deferment	Allows students incurring economic hardship to apply for a deferment of up to one year.	Establishes that any loans after July 1, 2026, will not be eligible for deferment, and that for any loans after July 1, 2026, forbearance may not exceed nine months within a 24-month period.	Establishes that any loans after July 1, 2026, will not be eligible for deferment, and that for any loans after July 1, 2026, forbearance may not exceed nine months within a 24-month period.	Establishes that any loans after July 1, 2026, will not be eligible for deferment, and that for any loans after July 1, 202 7, forbearance may not exceed nine months within a 24-month period.
26	Economic hardship deferment	Allows borrowers to be in forbearance for up to 12 months at a time, for a total of four years.
27	Enrollment intensity caps	Allows students to borrow up to the annual limits, regardless of enrollment intensity.	Pro-rates student loans for students enrolled less than full-time and allows institutions of higher education to set lower limits for all students in the program.	Pro-rates student loans for students enrolled less than full-time and allows institutions of higher education to set lower limits for all students in the program.
28	Enrollment intensity caps				Pro-rates student loans for students enrolled less than full-time and allows institutions of higher education to set lower limits for all students in the program.
29	Higher Ed Program Accountability
30	Employment and earnings outcomes requirements	Requires colleges and universities to submit Financial Value Transparency and Gainful Employment reports (no elimination of federal student aid eligibility has occurred yet).	Requires institutions of higher education to make annual payments to the US Department of Education based on the non-repayment balance of borrower cohorts, starting for loans made on or after July 1, 2027.	Ends participation in the federal student loan program for any undergraduate program where graduates earn less than the average high school graduate in the state and any graduate program where graduates earn less than college graduates in the same field and state for two out of three consecutive years.	Ends participation in the federal student loan program for any undergraduate program where graduates earn less than the average high school graduate in the state and any graduate program where graduates earn less than college graduates in the same field and state for two out of three consecutive years.
31	Employment and earnings outcomes requirements		Provides grants to institutions that provide a maximum price guarantee to support students from low-income backgrounds (PROMISE Grants).
32				R epealed the Biden Administration’s Borrower D efense to Repayment and C losed School Discharge regulations, which provide relief to students who were defrauded by postsecondary programs	Delays the application of the Biden Administration’s Borrower Defense to Repayment and Closed School Discharge regulations for 10 years.
33				limite d ED from regulating and taking executive such actions if the rule or action was economically significant or would have resulted in an increase in subsidy cost.	L imits ED from proposing regulations, promulgating final regulations or taking executive actions that would increase the subsidy cost of the Part D loan programs by more than $100 million.
34	Savings Accounts
35	529 College Savings Plans	Allowable expenses for 529 accounts in include attendance at elementary and secondary school, whether public, private, or religious.	Includes fees for dual enrollment programs, costs associated with postsecondary credential programs, and costs associated with homeschooling as expenses that can be covered by 529 accounts.	Includes f ees for dual enrollment programs and costs associated with postsecondary credential programs as expenses that can be covered by 529 accounts.	Includes fees for dual enrollment programs and costs associated with postsecondary credential programs as expenses that can be covered by 529 accounts.
37	“Trump Accounts”	N/A	Creates “ Trump Accounts. ” F amilies may contribute up to $5,000 annually for children under the age of eight. At 18, c hildren can access 50% for education, business , or the purchase of a first home. At 25, children can withdraw the full balance for the purposes above. At age 30, they can access the full balance for any purpose. The government will contribute $1,000 under a new temporary pilot progra m for children born between January 1, 2024, and December 31, 2028 . Parents must have SSNs.	Creates “ Trump Accounts.” Families may contribute up to $5,000 annually for children under the age of eight. At 18, children can access 50% for education, business, or the purchase of a first home. At 25, children can withdraw the full balance for the purposes above. At age 30, they can access the full balance for any purpose. The government will contribute $1,000 under a new temporary pilot program for children born between January 1, 2024, and December 31, 2028. Parents must have SSNs.	Creates “ Trump Accounts.” Families may contribute up to $5,000 annually for children. At 18, children can access 50% for education, business, or the purchase of a first home. At 25, children can withdraw the full balance for the purposes above. At age 30, they can access the full balance for any purpose. The government will contribute $1,000 under a new temporary pilot program for children born between January 1, 2024, and December 31, 2028. Parents must have SSNs.
38	“Trump Accounts”	N/A
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