The Education Department has quietly changed how it decides whether continuing graduate students can still borrow uncapped Grad PLUS loans, and the change is already generating denials for students who have been enrolled.

During an August 12 Federal Student Aid webinar on the implementation of new loan limits and the interim exception for continuing students, FSA staff told schools to calculate “expected time to credential” using credit hours completed rather than time enrolled. That formula determines how much longer a grandfathered borrower keeps access to Grad PLUS after the program formally ended on July 1, 2026.

The National Association of Student Financial Aid Administrators called it a significant departure from prior guidance, noting that ED had previously told schools to measure the difference between program length in weeks, months, or years and the portion the student finished before July 1.

Education Department spokesperson Ellen Keast told Inside Higher Ed the approach is “not anything new” and had come up in earlier virtual office hours, though the department did not point to where it was written down. When ED finalized the loan limits and new repayment plans, the written record pointed the other way: the final rule text at 34 CFR 685.102 and the department’s May 20 loan limits FAQ both describe the calculation in terms of time.

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