Policy Status Index

EAB’s Policy Status Index is designed to help institutional leaders stay informed about the latest changes to federal policy that will affect higher education.

For each relevant policy introduced by the Trump administration, this index provides leaders with a summary of the directive, the implications for institutions and students, and the implementation status. Leaders should use this instrument to stay abreast of the broad array of policy changes stemming from the White House, then reflect on which changes their institution is well-positioned to navigate and which need additional attention.

Explore policy updates and their current statuses within the following terrains:

• Immigration and International Enrollment
• Inclusion, Belonging, and Campus Culture
• Research Enterprise
• Financial Aid
• Accreditation and Accountability

This index was last updated on July 10.

Explanation of Policy Statuses

• Introduced: This policy has been proposed but has not been passed.
• Passed: This policy will become effective but is not yet active.
• Active: This policy can be implemented.
• Blocked: This policy has been prevented from being implemented by the court via an injunction. An injunction is a court order that requires someone to do or cease doing a specific action. The three types of injunctions are: temporary restraining orders, preliminary injunctions, and permanent injunctions.
  • Temporary restraining order: A short-term measure put into effect to maintain the status quo until the court issues something more enduring, such as a preliminary injunction. TROs can be issued without a court hearing and without informing the opposing party. TROs are typically requested and issued when the applicant is facing irreparable harm.
  • Preliminary injunction: An injunction granted before or during a trial, in order to maintain the status quo before final judgment. A preliminary injunction is issued following a formal hearing, and the applicant must demonstrate that they will experience irreparable harm unless the injunction is issued.
  • Permanent injunction: A court order that requires someone to do or cease doing a specific action that is issued as a final judgment in a case. A permanent injunction is issued after the case has been heard and proven that, without the permanent injunction, the applicant would suffer ongoing and irreparable harm.
• Vacated: This policy has been legally voided or annulled.

Sources from which these definitions were adapted:

• Cornell Law School, Legal Information Institute
• Bochetto & Lentz

Immigration and International Enrollment

The policy changes below pose substantial challenges for institutions aiming to enroll and support international and undocumented students. In particular, the administration has targeted international students in recent months, with at least 4,700 international students having their immigration status records terminated (though some have been subsequently restored). Given these policy changes, many institutions are downgrading their expectations for international enrollment for the upcoming academic year.

Policy	Description	Implications for Institutions and Students	Current Status
Cap To Replace Duration of Status	The Department of Homeland Security (DHS) and the Immigration and Customs Enforcement (ICE) submitted a proposal for the Office of Management and Budget (OMB) to end “duration of status." NAFSA has shared that it is likely this proposal shares similarities to the rule proposed in 2020 by the Trump administration, which proposed changing the admission period of F, J, and I nonimmigrants from duration of status to an admission for a fixed time period.	If this proposed rule is the same as the 2020 proposed rule, it would impact international students and exchange visitors, institutions that admit or sponsor international students, and employers who hire international students pursuing optional practical training (OPT).	Proposed (6.27.25)
Travel Bans	Citizens from 12 countries are blocked from entering the US: Afghanistan, Chad, Republic of Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Myanmar, Somalia, Sudan, and Yemen. Additionally, 7 countries have partial restrictions: Burundi, Cuba, Laos, Sierra Leone, Togo, Turkmenistan, and Venezuela. Students and scholars are both included in the full and partial restrictions, which suspends F, M, and J visas.	Bans severely limit institutions' ability to recruit international students from affected regions and may also impact the retention of current students from those countries. Students from impacted countries have indicated that they may choose to remain in the U.S. during breaks rather than risk being unable to return.	Active (as of 6.4.25)
One-strike Policy: Catch-and-Revoke	The State Department will take action to revoke the status of any non-U.S. citizens who engage in any instance of illegal activity, potentially including traffic violations, or pro-Palestinian sentiments, which the administration has equated to support for Hamas.	Reports have indicated that this policy has created an atmosphere of extreme caution among international students, given that even minor infractions could result in potential deportation. This policy will likely create a chilling effect on international enrollment in the US, such that students may choose to study at institutions outside the US.	Active (as of 5.2.25)
Targetting of In-State Tuition Policies	The Trump administration has asked federal officials via executive order to “take appropriate action” to prevent undocumented students from receiving in-state tuition. The order does not specifically threaten federal funding.	Over 400K undocumented students are estimated to be enrolled in HE institutions nationally, and around 84% of immigrants reside in states with tuition-equity laws. Thus, this tuition change would make college less accessible for many undocumented students who rely on these policies since they cannot access federal financial aid.	Active (4.28.25). Immigrants rights groups have criticized the order and asked institutions to avoid pre-emptive changes. Tuition equity laws have withstood past legal challenges.
Increased Screening and Vetting of Visa Applicants	All visa applicants are now subject to stricter vetting, consistent with standards from the first Trump administration, and social media/online presence scrutinization, which includes requiring visa applicants to make their social media profiles public.	Increased vetting and screening could likely create significant delays in visa processing and increased denial rates, leading to decreases in in-person international student enrollment. There has already been a 13% decline in postgraduate international student enrollment for the 2025-26 academic year, as students face heightened uncertainty about visa approval. Scholars and researchers are facing increased scrutiny as well, which could impact US status as a leader in research.	Active (as of 1.20.25). The administration started focusing on enhanced vetting and screening in January 2025. The most recent policy focused on social media screening was released on June 18, 2025.
Rescission of Protected Areas for Immigration enforcement	The Department of Homeland Security rescinded the protected areas policy that had previously prevented I.C.E. agents from conducting immigration enforcement in schools, churches, and hospitals. However, agents do still need a judicial warrant to enter private areas.	ICE agents can now conduct enforcement operations on college campuses, with reports indicating that this change has created a climate of fear and confusion among undocumented students and those from mixed-status families. Research has shown that this policy has led to decreased attendance in certain school districts following increased ICE operations.	Active (as of 1.20.25)
Deputization of Local Law Enforcement to Perform Immigration Functions	Local and campus police participating in 287(g) agreements can conduct immigration enforcement actions on behalf of I.C.E.	Campus police participating in 287(g) agreements are now empowered to "interrogate any alien or person believed to be an alien" and make warrantless arrests, transforming university police from community safety officers into federal immigration enforcement agents. This shift can damage campus trust, enable racial profiling, and hurt public safety.	Active (as of 1.20.25). The 287(g) program was established in 1996, but the Trump administration has made its revival and expansion a key components of immigration enforcement, calling out 287(g) agreements in Executive Order 14159.

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Inclusion, Belonging, and Campus Culture

The policy changes below outline the Trump administration’s swift and sweeping efforts to attempt to dismantle institutional DEI initiatives. The Department of Education has launched investigations into dozens of universities related to DEI programming, while also dismissing a high number of civil rights complaints. Institutions should work with legal counsel on interpreting federal and state laws in order to stay in compliance while simultaneously avoiding over-complying.

Policy	Description	Implications for Institutions and Students	Current Status
Race-based Classifications Deemed to be "Illegal DEI"	The Education Department’s February 14th “Dear Colleague Letter” stated that any time an institution treats one individual differently to another based on race, that action violates the law, based on the administration's interpretation of the Students for Fair Admissions vs. Harvard decision.	Many institutions have changed their policies and practices to ensure that they are in compliance, which has also created concern among DEI advocates about the risks of pre-compliance or "anticipatory obedience."	Temporarily blocked (as of 4.24.25). In New Hampshire, Judge Landya McCafferty ruled the directive was unconstitutionally vague, noting the letter failed to even define what constitutes a "DEI program.” While the New Hampshire court’s preliminary injunction was limited to institutions that are members of the plaintiff association, just hours later, in Maryland, Judge Stephanie Gallagher filed her opinion, which essentially serves as a nationwide injunction to postpone enactment of the Feb. 14th DCL.
NCAA Restrictions on Transwomen Competing in Women's Competitions	The NCAA ruled that transwomen athletes can still practice with women's teams, but they are no longer eligible to compete in women's competitions. This policy change was a result of Trump's executive order seeking to deny federal funding to schools that allow trans girls and women to play on girls'/women's sports team.	NCAA member institutions are now responsible for certifying athlete eligibility for both practice and competition. This shift marks a significant reversal from previous NCAA policy to adopt a sport-by-sport approach for transgender participation.	Active (as of 2.6.25)
Roll Back of Title IX Regulations to 2020 Standards	Protections for transgender students under Title IX have been removed. Due process protections for those accused of sexual assault have also been reinstated.	To be in compliance with new Title IX regulations, institutions must adjust policies and procedures and update trainings. The administration has been targeting Title IX violations, with the Departments of Education and Justice launching the Title IX Special Investigations Team in April 2025 to expedite investigations. The administration has since opened several investigations at colleges and K-12 schools related to transgender policies and has threatened to remove federal funding for non-compliance.	Active (as of 1.31.25)
Recognition of Sex, Not Gender	The federal government now only recognizes two sexes, male and female, as assigned at birth. This is reflected on all federal forms and reporting.	Institutional leaders should be aware that students will no longer be able to select the nonbinary gender marker from the FAFSA form, and that the State Department has also suspended X gender markers. Institutions should communicate support to non-binary and trans students, faculty, and staff, including sharing on- and off-campus resources.	Active (as of 1.20.25)

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Research Enterprise

The policy changes outlined below have the power to overhaul the higher education research enterprise, representing a comprehensive effort to slow the distribution of and ultimately decrease federal research funding. Research institutions should thus prepare for a substantial reduction in federal appropriations for research.

Policy	Description	Implications for Institutions and Students	Current Status
Review of Federal Research Grants Due to Flagged Terms	US federal science agencies have canceled billions in current grants and contracts that are misaligned with the Trump administration's agenda, including the NIH canceling 2,300+ grants. Cancellations are focused on research related to topics such as: diversity, equity, and inclusion; foreign aid, support, or collaboration; immigration research and assistance; and clean energy projects.	These cancellations from various agencies have impacted the ability of institutions to conduct various research projects. Additionally, cancellations have led to several research institutions implementing hiring freezes, buy outs, and layoffs.	Partially active (as of 6.25.25). The NIH has been ordered to restore ~900 grants that the court deemed to have been cancelled illegally. Many other grants and contracts are still canceled.
15% Cap on Facilities and Administrative Cost at NSF	This policy from the National Science Foundation seeks to limit reimbursement for institutions' indirect research costs—which covers expenses such as laboratory maintenance and administrative support—to 15% for all new grants.	See above.	Vacated (as of 6.24.25). The Trump administration can appeal the ruling but has not yet said if they will.
15% Cap on Facilities and Administrative Cost at DoD	This policy from the Department of Defense seeks to limit reimbursement for institutions' indirect research costs—which covers expenses such as laboratory maintenance and administrative support—to 15% for all new grants.	See above.	Temporarily blocked via temporary restraining order (TRO) (as of 6.17.25). Judge Brian Murphy then extended the temporary restraining order on July 2 for two weeks.
15% Cap on Facilities and Administrative Cost at DoE	This policy from the Department of Energy seeks to limit reimbursement for institutions' indirect research costs—which covers expenses such as laboratory maintenance and administrative support—to 15% for new grants and terminate existing grants that don't conform.	See above.	Temporarily blocked via preliminary injunction (as of 5.15.25). The Trump administration has until July 1 to file a response. The judge has ruled that the plaintiffs are likely to succeed.
15% Cap on Facilities and Administrative Cost at NIH	This policy from the National Institutes of Health seeks to limit reimbursement for institutions' indirect research costs—which covers expenses such as laboratory maintenance and administrative support—to 15% for current and new grants.	If this policy is implemented, it would negatively impact institutions' financial sustainability and ability to conduct scientific research.	Blocked via permanent injunction (as of 4.4.25). The Trump administration has appealed this ruling, so the policy remains in flux.

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Financial Aid

The policy changes below represent shifts in federal student financial aid. Overall, these changes limit access to higher education, particularly for low-income students. Given the passage of the 2025 budget reconciliation bill, plus potential changes in the Education Department’s Fiscal Year 2026 Budget Request, institutions should prepare now for how to handle these seismic financial aid shifts.

Policy	Description	Implications for Institutions and Students	Current Status
Capping Loan Programs and Eliminating Grad PLUS Loan Program	Federal student loans will be capped at $100K/borrower for graduate programs, at $200K/borrower for professional programs such as for law or medical school, and at $65K/student for Parent PLUS loans for undergraduate students. The Grad PLUS loan program is eliminated.	These changes may lead to potential borrowers—particularly from low- and middle-income families—not pursuing higher education or taking out private loans, which could be riskier or harder to obtain. Such a decrease in enrollment would financially impact institutions that rely on graduate tuition. Additionally, Black and Latino families have disproportionately used the Parent PLUS loans, and thus will be more impacted by this cap. Advocates are also concerned that these changes will lead more borrrowers to default, which could lead to potential rises in institutions' cohort default rates.	Passed (7.4.25). Student loan changes will take effect in July 2026. Current borrowers enrolled in a program by June 30, 2026, are excluded from the borrowing caps for three years.
Consolidation of Student Loan Repayment Options	New student loan borrowers will only have two repayment options: a new standard plan and a new income-driven repayment plan, known as the Repayment Assistance Plan (RAP). RAP includes loan forgiveness after 30 years, which is longer than any current plan. This consolidation phases out the Income Contingent Repayment (ICR), Pay As You Earn (PAYE), and Savings on a Valuable Education (SAVE).	The average monthly payments of many borrowers will increase, particularly those enrolled in PAYE and SAVE, according to advocacy groups. For example, a New York Times analysis showed that borrowers with a college degree and annual income of $80,300K will pay an additional $2,929 per year.	Passed (7.4.25). The two repayment options will take effect in July 2026.
Delays to Biden-era Regulations Protecting Student Borrowers	Two Biden-era regulations are delayed for 10 years: borrower defense to repayment (which made it easier for students whose colleges defrauded them to receive loan forgiveness) and closed-school discharges (which gave student loan relief to students whose institutions suddenly closed).	Even before these delays, the Biden-era borrower defense and closed school discharge rules had been blocked by a federal court; thus, the Department of Education had not been using the rules.	Passed (7.4.25)
Changing Pell Eligibility	Students who receive full-ride scholarships to an institution will not be eligible for Pell. In other words, students will be ineligible if their total aid from other sources equals or exceeds their cost of attendance for that period.	Students with full-ride scholarships use Pell Grants for other expenses, so eliminating this source of funding may create difficulties for full-ride students who have traditionally received Pell.	Passed (7.4.25). This change will take effect in July 2026.
Creation of Workforce Pell	Workforce Pell Grants can be applied to short-term workforce programs at accredited institutions. The amount of aid given will be prorated based on the number of clock hours, credits, or weeks of the program. Students who have obtained a graduate credential will not be eligible.	Before the creation of Workforce Pell Grants, federal grant aid for lower-income students could only be applied to programs that were at least 600 clock hours and 15 weeks long. This meant that lower-income students often could not receive federal financial aid to pursue short-term training programs, but with Workforce Pell Grants, they now can. The Department of Education will also likely hold negotiated rulemaking on the details and implementation of Workforce Pell.	Passed (7.4.25). Workforce Pell is planned to go into effect on July 1, 2026. Please note that the timeline for implementation is aggressive, and it is possible the Department of Education may not be able to implement by this date.
Changes to Student Loan Deferment, Forbearances, and Loan Rehabilitation	Borrowers will no longer be able to defer loans due to unemployment or economic hardship. Discretionary forbearances will be shortened to no more than 9 months during any 24-month period; borrowers currently have 36 months of forbearance available to them for up to 12 months at a time. Additionally, borrowers will be given the ability to rehabilitate defaulted loans twice. Currently, borrowers can only rehabilitate defaulted loans once; however, the minimum required monthly rehabilitation payment amount increases from $5 to $10.	Borrowers who are experiencing a hardship or unemployment may face more difficulties than previously because they will not be able to defer under the Repayment Assistance Plan, which requires a minimum monthly payment. Critics are concerned this requirement will lead to a spike in defaults.	Passed (7.4.25)
Cuts to Medicaid, Medicare, the Affordable Care Act, and the Supplemental Nutrition Assistance Program (SNAP)	$930B in cuts over a decade are planned for Medicaid, Medicare, and the Affordable Care Act, with over 11 million people losing coverage by 2034. The two main Medicaid-related provisions include: 1) Medicaid will include work requirements to qualify for and remain on Medicaid, and 2) the amount of money the federal government sends to states to fund Medicaid will be reduced. Additionally, $186B in cuts to SNAP are planned over a decade. Over a third of these savings would come through expanding work requirements for eligibility, and another third would come through shifting costs to states.	Public institutions could be at risk of receiving less state funding. States rely on federal funding to maintain Medicaid and SNAP programs. If funding for these programs is cut, states will then either 1) shrink the number of constituents served via these programs or 2) pull funding from other areas of the budget. Historically, public higher education funding has been targeted when state lawmakers need to move funds from one sector to another. Therefore, these cuts may lead to increased tuition, reduced services and programs, and decreases in state financial aid. Additionally, due to Medicaid cuts, teaching hospitals and health systems—particularly in rural and underserved areas—could face increased financial pressure. Finally, students will be impacted by these cuts: almost 1 in 6 students depend on Medicaid, and 1 in 4 students face food insecurity and could benefit from SNAP. Without these programs, students could face more financial strain, potentially leading to worse academic and health outcomes.	Passed (7.4.25)
Increased Identity Verification To Receive Federal Student Aid	In an attempt to reduce student aid fraud, this new requirement calls for institutions to collect and review government-issued photo IDs—either in person or via live video—for approximately 125,000 first-time aid applicants this summer. This change is in place until the Office of Federal Student Aid finalizes a permanent screening process, planned for Fall 2025.	This increased identity verification may increase administrative workload for financial aid offices, particularly at underresourced schools. For impacted students, this increase in identity verification could hamper college access, particularly if they have difficulty providing the required documentation.	Active (as of 6.6.25)
Reductions to and Contribution Changes for Federal Work Study	Federal work study funding would be reduced to $250M, a loss of $980M. While the federal government currently covers 75% of federal work study and employers cover 25%, the Education Department would flip the ratio such that employers would cover 75% while the federal government would cover 25%.	These changes would likely limit the number of students able to participate in work study due to the reduction in funds, which would disproportionately affect lower-income students and institutions that rely the most on these funds.	Introduced (as of 5.31.25 in Education Department's FY26 budget request)
Cutting Pell Grants	Maximum Pell Grants would be cut by about 23%, or $1,685, such that the maximum award would be $5,710 for the 2026-27 award year.	Families with lower incomes have a higher chance of receiving Pell. If Pell is cut, it is possible that these lower income students may choose not to enroll in higher education or would need access to other funding sources.	Introduced (as of 5.31.25 in Education Department's FY26 budget request)
Elimination of Federal Programs Supporting Disadvantaged Students	The Federal Supplemental Educational Opportunity Grant program would be eliminated, losing all $910M in funding. TRIO and GEAR UP programs would be eliminated.	These cuts are targeted at programs that support low-income students' access to and retention in higher education. If such programs are eliminated, these students' access to and success in higher education will be hindered.	Introduced (as of 5.31.25 in Education Department's FY26 budget request)
Mandatory Collections on Defaulted Loans	The administration announced in April it would begin collecting on defaulted loans starting 5/5/25, ending a pandemic-era pause. The Education Department also stated that this summer, it would begin sending notices via the Office of Federal Student Aid ordering administrative wage garnishments in certain cases.	The resumption of student loan repayments and collections could mean that institutions will face potential rises in cohort default rates (CDRs), which could jeopardize their eligibility for federal student aid programs. As of April 2025, around 5.3 million borrowers were in default (i.e., at least 270 days behind on payments), and the Education Department estimated this could grow to 10 million within a few months.	Active (as of 5.5.25)

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Accreditation and Accountability

The policy changes outlined below represent initial ways that the Trump administration is working to overhaul higher education accreditation and institutional accountability. The administration views accreditation as a system in need of reform and wants to hold accreditors accountable for enforcing what it calls “unlawful discrimination” tied to diversity, equity, and inclusion (DEI) initiatives. Institutions should prepare for stricter scrutiny of accreditation standards and new accreditation criteria.

Policy	Description	Implications for Institutions and Students	Current Status
Earnings Test for Institutional Access to Federal Student Loans	If graduates' earnings in a particular academic program are too low (i.e., at the undergraduate level, graduates earn less than a median worker in that state with a high school degree; at the graduate level, graduates earn less than the median worker with a bachelor's degree working in the same field and/or state) for two out of three consecutive years, the program will lose eligibility for student loans. Undergraduate certificates are excluded from the requirement.	One analysis reviewing earnings data indicates that most programs will easily pass the test, and those that could fail are concentrated in the for-profit sector. There is concern that undergraduate certificates are excluded, given that they hold a disproportionate share of the low-value programs, and concern that this test does not consider high-value programs where students make more money but still take on high amounts of debt that they will struggle to repay.	Passed (7.4.25)
Endowment Tax Rate	The new tax rates will be as follows: 8% for institutions with over $2M in endowment value per student, 4% for institutions with $750K-2M in endowment value per student, and 1.4% for institutions with $500-750K in endowment value per student. Institutions are exempt if they have fewer than 3,000 tuition-paying students. International students are also now included in the total enrollment when calculating endowment value per student.	The current endowment excise tax is 1.4%, but it only applies to a few dozen private institutions that have at least 500 tuition-paying students and at least $500K endowment assets per student. The proposed changes will benefit small, wealthy colleges since they are now not subject to the endowment excise tax. Larger wealthy institutions will still be impacted. The majority of institutions’ endowment spending has gone towards financial aid plus academic programs and research; thus, these areas could be impacted under the new tax rates.	Passed (7.4.25). The new tax rate will be enacted after 12.31.25.
Accrediting Bodies' Suspension of Diversity Requirements	The WASC Senior College and University Commission announced a temporary "stay" on DEI requirements. The American Bar Association, the American Psychological Association, and the Accreditation Council for Graduate Medical Education have also suspended their DEI standards.	These suspensions, prompted by pressure from the Trump administration's executive order, may slow or reverse progress on campus diversity initiatives, reduce support for underrepresented groups, and create uncertainty for institutions navigating federal and state compliance.	Active (Policy changes were made from Feb.-May 2025.)
Expediting Switching Accreditors	According to a Dear Colleague Letter, institutions can change accreditors for reasons such as religious beliefs or objections to diversity standards, with approvals granted within 30 days or automatically, and the Education Department will no longer scrutinize institutions' reasons for changing accreditors.	See above.	Active (as of 5.1.25)
Recognizing New Accreditors	According to an Executive Order, the Trump administration wants to "resume recognizing new accreditors" in order to create a more competitive accreditation marketplace and help institutions avoid having to meet DEI standards to become accredited.	Critics note that institutions could more easily seek out less rigorous accreditors to avoid stringent oversight, which could compromise educational quality, politicize accreditation, erode public trust, and negatively impact students, as students could enroll in subpar programs at institutions that have lenient accreditors. Supporters state that this process would allow institutions to select accreditors that better align with their values and mission. Importantly, institutions must be accredited in order to be eligible for participation in federal student aid programs.	Active (as of 4.23.25)