Federal Policy Status Index for Higher Ed

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
• Belonging and Campus Culture
• Research Enterprise
• Financial Aid
• Accreditation and Accountability

This index was last updated on February 4.

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 targeted international students in 2025, with 6,000 international student visas revoked. Given these policy changes, some institutions have seen decreases in new international enrollment this academic year.

Policy	Description	Implications for Institutions and Students	Current Status
H-1B Weighted Lottery	The Trump administration published a final rule—Weighted Selection Process for Registrants and Petitioners Seeking to File Cap-Subject H-1B Petitions—that would fundamentally change the H-1B lottery by prioritizing applicants with higher salaries. Under the rule, U.S. Citizenship and Immigration Services (USCIS) would replace the current random selection process with a weighted lottery that favors applicants with higher Department of Labor wage levels.	Though DHS has argued that this rule will not significantly harm international students, the Presidents’ Alliance on Higher Education and Immigration warns that this new rule will disadvantage new international students, making it more difficult for them to stay and work in the United States post-graduation. By shifting the H-1B selection process toward mid-career professionals, the rule could weaken the pipeline from U.S. higher education to the domestic workforce.	Proposed (12.29.25). Unless blocked by the courts, this new rule will take effect on February 27, 2026, ahead of filings for the FY27 H-1B cap.
$100,000 Fee for H-1B Nonimmigrant Visa Program	The Trump administration issued a proclamation restricting entry of H‑1B workers unless their petition is accompanied or supplemented by a $100,000 payment. Applicability is limited to new petitions filed abroad, the charge does not apply to in-country renewals and current H‑1B holders.	Institutions use H‑1B to hire international faculty, researchers, and specialized staff. Some institutions may not be able to afford the fee, leaving them unable to fill certain roles on campus.	Active (9.21.25). The order took effect on Sept. 21 and is set to expire after 12 months unless extended. Lawsuits have been filed to halt the fee's enforcement, but as of February 2026, the fee remains in effect.
Barring Federal Funding for Certain Programs Serving Undocumented Students	The Department of Education has issued an interpretive rule asserting that certain postsecondary education benefits (including dual enrollment, adult education, and certain career and technical education (CTE) programs) qualify as “federal public benefits” under PRWORA and thus may no longer be supported with federal funds if participants are undocumented. This rescinds parts of a 1997 Dear Colleague Letter that had previously allowed access to those programs for undocumented students.. The notice was written in response to President Trump’s February executive order to end taxpayer subsidization of education for undocumented individuals.	Undocumented students already do not have access to federal financial aid, so this change could make access to workforce development programs harder for undocumented students, impacting workforce development. The notice reminds grantees and subgrantees that they must verify the eligibility of participants to ensure funding is not being improperly distributed.	Blocked via preliminary injunction (9.10.25). Multiple federal courts (Rhode Island and Washington) have issued injunctions blocking implementation of certain restrictions (for example, on Head Start). The interpretive rule itself remains “active” as the Department of Education’s official stance, but enforcement is currently paused or blocked pending further litigation.
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 (8.28.25). DHS and ICE published a Notice of Proposed Rulemaking (NPRM) in the Federal Register on August 28, 2025. Public comments on the proposed rule were due by September 29, 2025, with a separate comment period on information-collection changes ending October 27, 2025. Duration of status remains in force until any final rule is issued and implemented, which has not yet occurred as of January 2026.
Student Visa Revocations	The State Department announced that it has revoked more than 6,000 international student visas in 2025. Officials cited violations ranging from alleged support for terrorism (200–300 cases) to assault, burglary, and DUI. It remains unclear whether students whose visas were revoked on these grounds were convicted of crimes.	Visa revocations marked an escalation in enforcement and created concerns about international recruitment, enrollment, and retention, as well as campus climate and community.	Active (as of 8.18.25)
Travel Bans	Full travel bans apply to the following countries: Afghanistan, Burma, Chad, the Republic of the Congo, Equatorial Guinea, Eritrea, Haiti, Iran, Libya, Somalia, Sudan, Yemen, Burkina Faso, Laos, Mali, Niger, Sierra Leone, South Sudan, and Syria, as well as individuals traveling on documents issued or endorsed by the Palestinian Authority. Partial travel bans apply to the following countries: Angola, Antigua and Barbuda, Benin, Côte d’Ivoire, Dominica, Gabon, The Gambia, Malawi, Mauritania, Nigeria, Senegal, Tanzania, Tonga, Zambia, Zimbabwe, Burundi, Cuba, Togo, and Venezuela. Students and scholars are both included in the full and partial restrictions, which suspends F, M, and J visas. In January 2026, a new travel ban paused the issuance of immigrant visas from 75 countries, but that pause does not apply to nonimmigrant visas, including student visas; of these 75 countries, 23 are subject to the existing travel bans.	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). Immigrant rights groups oppose the order and urged institutions not to make pre-emptive changes. In June 2025, a federal judge approved a DOJ–Texas motion ending in-state tuition for undocumented students, ruling the policy unfair to out-of-state U.S. citizens. The DOJ has since filed similar lawsuits in six other states offering some form of in-state tuition eligibility for undocumented students: California, Illinois, Kentucky, Minnesota, Oklahoma, and Virginia.
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 created significant delays in visa processing and increased denial rates, likely playing a role in the decreases seen in new international student enrollment this year. From Fall 2024 to Fall 2025, there was a 17% drop in new international enrollments. Scholars and researchers have also faced increased scrutiny as well, which could impact US status as a leader in research.	Active (as of 1.20.25). In January 2025, the administration started focusing on enhanced vetting and screening. In June 2025, a new policy requires F, M, and J visa applicants to disclose all social media accounts used in the past five years and to set their profiles to public. As of December 2025, the expanded screening and vetting of online presence also applies to H-1B applicants and their dependents.
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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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
MSI Discretionary Funding Shifts	On Sept. 10, the Education Department announced it would end discretionary funding for seven Minority‑Serving Institution (MSI) grants it labeled “racially discriminatory,” affecting roughly $350M in FY25 grants, while about $132M in mandatory MSI funds would still be disbursed. On Sept. 15, the Education Department unveiled a one‑time $495M increase for HBCUs and Tribally Controlled Colleges and Universities (TCCUs) for FY25, stating the move repurposes funds from programs the department claims are “not in best interest of students and families.” The department pegged FY25 totals at over $1.34B for HBCUs and over $108M for TCCUs.	MSIs have previously used these grants for a variety of purposes to strengthen their institutions, including student services, campus renovations, and establishing endowment funds. Many MSIs impacted by these cuts are already under-resourced. Additionally, this move appears to be pitting institutions against each other through redirecting the funding.	Active (as of 12.18.25). The Admissions and Consumer Transparency Supplement (ACTS) to IPEDS opened on December 18, 2025, and will close to keyholders on March 18, 2026.
Removal of Disparate-Impact Liability	The Justice Department announced that it is removing disparate-impact liability from its Title VI rules, which allows individuals to claim that seemingly race- and sex-neutral policies are discriminatory if such which allows individuals to claim that seemingly race- and sex-neutral policies are discriminatory if such policies disproportionately harm certain groups of people or lead to significant disparities. Though this regulation only affects Justice Department programs, the Justice Department sets legal guidance for the entire federal government, and other departments already have announced plans for similar regulatory efforts.	This ruling will limit the ability of college students, parents, and employees to file discrimination complaints with the Justice Department without clear proof of intent.	Active (as of 12.9.25)
Race-Based Education Programs Deemed "Unlawful"	The Department of Justice released a legal memo concluding that several Department of Education grant programs are unlawful because they rely on race-based eligibility criteria, noting that their continuance would be unconstitutional but that their funding could be redirected.	Critics have argued that the DoJ does not have the authority to declare these programs unconstitutional, given that they are congressionally mandated. It is unclear currently whether the administration will withhold new funding from the programs, rescind current funding, or both.	Active (12.2.25)
Compact for Academic Excellence in Higher Education	Announced by the Trump administration on Oct. 1, 2025, the Compact offers institutions enhanced federal funding in exchange for meeting conditions such as capping international enrollment at 15% (no more than 5% from any one country), freezing tuition for five years, and reviewing or restructuring departments deemed inconsistent with the Compact’s principles.	The compact may limit institutional autonomy and academic freedom through funding-linked conditions; create new compliance and reporting requirements for participating institutions; and raise constitutional questions and uncertainty about future eligibility for federal research support.	Proposed (10.1.25). The Compact was initially sent to nine research universities, then expanded nationwide on October 13. No institution that was sent the compact to review has agreed to its conditions. Only four institutions across the country have expressed interest in signing the compact. Trump officials had wanted to finalize the compact by November 21, 2025, but there has been little movement.
Expanded IPEDS Reporting Requirements (ACTS)	Eligible four-year institutions are now required to submit the ACTS Survey. This requirement follows Trump’s memorandum, Ensuring Transparency in Higher Education Admissions, and Secretary Linda McMahon subsequent directive issued in August 2025. ACTS requires eligible four-year institutions to submit disaggregated data on applications, admissions, enrollment, and aid by race-sex pairings, GPA quintiles, test-score quintiles, family income ranges, Pell-grant eligibility, parental education, application round, and more. The 2025-26 collection will also require historical data going back to 2020-21 or 2019-20.	Data and higher education experts note that the new data is likely to be inaccurate, difficult to interpret, and misused by policymakers because the agency does not have enough funding, expertise, or time to create this new dataset. Additionally, the data that the administration is requesting does not exist at every institution; for example, some institutions do not require students to report standardized test scores.	Active (as of 12.18.25). The Admissions and Consumer Transparency Supplement (ACTS) to IPEDS opened on December 18, 2025, and will close to keyholders on March 18, 2026.
Race-based Classifications Deemed "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."	Vacated (as of 8.14.25). Judge Stephanie Gallagher struck down the Department of Education’s February 14th Dear Colleague Letter (DCL), ruling it violated free speech and due process protections and was therefore invalid. This decision vacates the directive nationwide. In January 2026, Education Department dropped its appeal of this federal court ruling, meaning that the federal court's ruling stands.
Restricting Identity-Based Programs and Practices, Plus "Unlawful Proxies"	This memo builds on the Department of Education's February Dear Colleague Letter, which was temporarily blocked by federal judges in April. The memo targets identity-based programs and practices as well as "unlawful proxies" for race and sex. A few examples in the memo that the administration views as "unlawful practices" include: race-based scholarships or programs, preferential hiring or promotion practices, access to facilities or resources based on race or ethnicity, race-based training sessions, and sex-based or race-based selection for contracts. Examples of "potentially unlawful proxies" in the memo are: "cultural competence" requirements, geographic or institutional targeting based on racial or ethnic composition, and "overcoming obstacles" narratives or "diversity statements." The memo also includes non-binding recommendations for "best practices" to avoid legal risks.	While the memo is nonbinding, meaning it does not carry the force of law, it is likely to have a chilling impact on DEI-related programming and practices at institutions that receive federal funding, as it threatens to cut federal funding from institutions that don't comply with the DoJ's guidance. Some legal experts have noted that they are concerned the memo will force institutions into preemptive compliance, rolling back legal programs and practices because they fear retribution. Additionally, tactics that institutions have relied on to diversify classes since affirmative action was banned, including place-based recruitment, are now being targeted.	Active (as of 7.29.25)
DoE Rules Weakening Civil Rights Protections	The rules would rescind protections under Title IX (sex discrimination), Title VI (racial discrimination), and Section 504 (disability discrimination).	Advocates argued that those four rules were too significant and controversial to go through direct final rulemaking. Additionally, attempting to issue these regulations through the Department of Energy is unusual and may be a way for the administration to attempt to avoid attention.	Proposed (as of 7.15.25). The Department of Energy has now delayed these rules' effective date until March 9, 2026, following significant public opposition.
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)
Digital Content Accessibility Requirements	The Department of Justice finalized new regulations under Title II of the ADA requiring state and local government entities—including public colleges and universities—to ensure their digital content complies with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, developed by the World Wide Web Consortium.	Under the new requirements, PDF documents must be accessible to screen readers; videos must be accompanied by captions and, where required, audio descriptions; images must include alternative text; and audio-only content must be paired with transcripts. Complying with these enforceable digital accessibility standards is a large undertaking for many institutions, particularly given that no federal funding was provided to support implementation.	Active (as of 4.24.24). Public institutions must comply by April 24, 2026 (or April 26, 2027, if located in jurisdictions with a census-defined population of under 50K residents). Private institutions receiving federal funds under Section 504 of the Rehabilitation Act will likely be held to similar accessibility standards.

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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 reductions in federal appropriations for research.

Policy	Description	Implications for Institutions and Students	Current Status
Federal Research Grant Freezes and Cancellations	US federal science agencies canceled billions in current grants and contracts that are misaligned with the Trump administration's agenda. In 2025, more than 7,800 research grants were canceled or suspended. 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. Courts have ordered thousands of grants to be reinstated. About 2,600 grants (amounting to ~$1.4B) have not been unfrozen or reinstated.	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, buyouts, and layoffs.	Active/Blocked (as of 2.3.26). Numerous lawsuits have been filed over the grant freezes and cancellations. In August 2025, the Supreme Court overturned a lower court ruling that had ordered NIH to restore ~900 DEI-related grants, allowing NIH’s cancellation of nearly $800M in funding to stand; plaintiffs must now refile in the Court of Federal Claims to challenge the cancellations. In December 2025, the NIH reached settlements with 16 state attorneys general to review over 5,000 grant applications that were previously paused.
Reviewing NIH Research Grants for Priority Alignment	According to STAT, the National Institutes of Health (NIH) distributed guidance on December 12 titled “Reviewing Grants for Priority Alignment” that orders staff to use a computational text analysis tool to find certain terms in current and new grants that are misaligned with NIH priorities. The guidance notes that funding won’t be provided until “all areas of non-alignment” in “misaligned” grants have been addressed.	The NIH’s new guidance will likely impact health disparities research, although the full list of terms or phrases the tool is supposed to identify remains unclear. This policy represents a shift towards integrating political priorities into scientific funding.	Active (12.12.25)
Expediting NSF Grant Review Process	National Science Foundation (NSF) announced in a December 1 internal memo that changes are being made to the grant proposal review process. The memo notes that as few as one outside review is now allowed (the current minimum is three). Additionally, the routine use of expert panels to discuss individual reviews will end, and program managers will have greater authority to recommend which proposals to fund. Program officers must also shorten their summaries of strengths and weaknesses of each proposal, which are part of the review process.	The changes at the NSF mean that program officers can more easily reject proposals without sending them out for review and can move ahead without convening a panel for proposals aligned with Trump administration priorities. These changes advantage the Trump administration by shifting funding away from university-driven research priorities that rotators (scientists on loan from institutions who serve as program managers and higher level administration, hundreds of whom were eliminated in 2025) have prioritized.	Active (12.1.25)
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.	If this policy is implemented, it would negatively impact institutions' financial sustainability and ability to conduct scientific research.	Vacated (10.10.25). U.S. District Court Judge Brian Murphy vacated the policy in October 2025, declaring it arbitrary and capricious. DoD apealed the ruling in December 2025 to the 1st U.S. Circuit Court of Appeals.
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.	Active (as of 8.21.25). The Supreme Court overturned a lower court ruling that had ordered NIH to restore ~900 DEI-related grants, allowing NIH’s cancellation of nearly $800M in funding to stand. Plaintiffs must now refile in the Court of Federal Claims to challenge the cancellations.
Political Appointees Given Control Over Federal Grants	Trump issued an executive order, “Improving Oversight Of Federal Grantmaking,” that gives political appointees the power to review and approve funding decisions made by federal agencies, including the National Science Foundation and the National Institutes of Health. Under previous administrations, career civil servants and subject-matter experts have played central roles in the federal government’s grant funding decisions and priorities. This directive mandates that agencies appoint senior political officials to review grant awards and funding opportunity announcements, ensuring grant decisions align with national interests and agency priorities.	Researchers have expressed concerns that this directive will negatively impact the integrity of American research through placing too much control in the hands of appointees who lack relevant expertise and can be easily swayed by political and business agendas. Additionally, these changes may delay grant review, approval, and disbursement, which could then slow scientific progress. The fact sheet accompanying the directive also suggests that the Trump administration may look beyond research heavyweights within the higher ed sector when awarding grants.	Active (as of 8.7.25)
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.	If this policy is implemented, it would negatively impact institutions' financial sustainability and ability to conduct scientific research.	Vacated (as of 6.30.25). In June 2025, a federal judge had already vacated the policy, which the Trump administration has appealed.
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.	If this policy is implemented, it would negatively impact institutions' financial sustainability and ability to conduct scientific research.	Vacated (as of 6.20.25). A federal judge struck down this policy on June 20, 2025. The Trump administration originally appealed this ruling striking down the policy in August 2025, but then dropped the appeal in September 2025.
NIH Forward Funding Shift	The NIH will fully fund at least 50% of new, non-competing external research awards upfront in a single lump sum rather than incrementally.	The shift to forward funding was a reason behind fewer new grants being awarded in FY2025, with the NIH issuing 24% fewer grants in 2025 compared with the average of the previous 10 years. This policy will result in a fewer number of investigators receiving rewards, which could force university labs to close.	Active (6.1.25)
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 nationwide via permanent injunction (as of 4.4.25). A federal appeals court upheld this ruling in January 2026. The NIH has not announced it will appeal this ruling.

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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 OBBBA in July 2025, institutions should prepare now for how to handle these financial aid shifts.

Policy	Description	Implications for Institutions and Students	Current Status
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 July 2025, 5.4M borrowers were reported to be 90+ days past due on their student loan repayments. At 270 days past due, borrowers enter default status and become subject to collection actions.	Proposed (as of 1.16.26). The Education Department has not announced when wage garnishments or tax refund seizures will resume.
Public Service Loan Forgiveness (PSLF) Employer Restrictions	The Department of Education issued a final rule to bar borrowers from PSLF eligibility if their employer is “engaged in activities such that it has a substantial illegal purpose.” The proposal stems from Trump’s March 2025 Restoring Public Service Loan Forgiveness Executive Order. The final rule limits “substantial illegal purpose” to: aiding or abetting violations of federal immigration laws; supporting terrorism; providing transgender youth with, or helping them receive, gender-affirming medical care; engaging in a pattern of aiding and abetting illegal discrimination; or engaging in a pattern of violating state laws.	This rule could exclude public service workers from PSLF, particularly those employed by nonprofit, advocacy, or legal aid organizations that fall out of favor with the administration. This change would heighten uncertainty of loan forgiveness for graduates who want to pursue certain public service careers. The ED did note in its final rule that it “expects that it will only take action to remove PSLF program eligibility for less than ten employers per year," which indicates that around 2,300 borrowers would lose PSLF access each year.	Proposed (as of 10.31.25). The final rule will take effect in July 2026. Lawsuits have been filed against the Department of Education challenging PSLF eligibility restrictions.
Publication of Borrower Nonpayment Rates by Institution	On July 23, 2025, the Department of Education began publishing institution-level data on student loan borrower nonpayment rates. The data covers Direct Loan borrowers who entered repayment since January 2020 and were more than 90 days delinquent as of May 2025. This release follows the administration’s restart of collections on defaulted loans earlier in the year.	The public release of nonpayment rates raises accountability stakes for colleges and universities. Institutions with high nonpayment rates risk reputational damage and increased scrutiny from policymakers, accreditors, and the public. If delinquency levels remain elevated, some colleges could lose eligibility for federal aid programs under cohort default rate (CDR) rules. Even institutions with relatively low rates may need to invest in borrower outreach and repayment support to avoid future sanctions. The visibility of these data may also intensify media and political narratives about institutional quality and value.	Active (as of 7.23.25). The Department has begun publishing data and indicated that institutions should prepare for continued monitoring and potential consequences tied to high delinquency and default rates.
90-10 Rule Revision on Online Program Revenue	For-profit institutions can count revenue from online programs ineligible for federal student aid toward their 90-10 calculation.	This change is unlikely to affect most students, but critics argue it sets a precedent for advancing major regulatory shifts in service of the administration’s political priorities without following the standard rulemaking process.	Active (7.7.25). Because interpretive rules such as this one do not have effective dates, the Department of Education says that institutions may revise their revenue calculated for previous fiscal years.
Capping Graduate and Professional Loans	Federal student loans will be capped at $20.5K per year/$100K per lifetime for graduate programs and at $50K per year/$200K per lifetime for professional programs, such as for law or medical school. Loan amounts are prorated based on enrollment intensity (e.g., half-time students eligible for half the maximum loan). Additionally, borrowers will face a new lifetime limit for combined undergrad and graduate loans of $257,500, excluding borrowed Parent PLUS loan amounts.	These caps could likely 1) drive students to private lenders, whose loans may be riskier or harder to obtain, 2) force institutions to lower prices (for reference, an MBA costs at least $200K over two years at 23 of the top 25 business schools), or 3) decrease demand for graduate and professional programs, particularly demand from lower-income families (such decreases would then likely disrupt professional degree pipelines). The extent to which each of these will occur is unknown. Institutional leaders should also have a clear understanding of which programs the Department of Education considers “professional,” as this classification affects allowable loan amounts.	Passed (7.4.25). Caps will take effect in July 2026. A legacy borrowing provision allows current borrowers enrolled in a program prior to July 1, 2026, to be excluded from the borrowing caps for three years (or until completion of their credential, whichever is less).
Capping Parent PLUS Loans	Parent PLUS loans will be capped at $20K per year per student. The lifetime limit is $65K total per student. Parents can borrow for multiple children.	Parent PLUS limits will affect both students at high-cost institutions and students from low-income families. Additionally, Black and Latino families have disproportionately used the Parent PLUS loans, and thus will be more impacted by this cap.	Passed (7.4.25). Caps will take effect in July 2026. For borrowers with a Parent PLUS loan made prior to July 1, 2026, parents may continue to borrow under the current loan limits for three academic years (or until completion of the student's credential, whichever is less).
Elimination of Grad PLUS Loan Program	The Grad PLUS loan program is eliminated entirely starting in the 2026-2027 academic year.	The elimination of this program may lead to potential borrowers (particularly from lower-income families) not pursuing graduate education or taking out private loans, which could be riskier or harder to obtain. For context, more than 1 in 5 borrowers graduating with a master’s degree (and 1 in 4 STEM program graduates) currently leverage Grad PLUS.	Passed (7.4.25). Grad PLUS loans will no longer be available for the 2026-2027 academic year. Borrowers with a Grad PLUS loan made prior to July 1, 2026, may continue to borrow from the program for three academic years (or until completion of their credential, whichever is less).
Institutionally Determined Loan Limits	Institutions will be able to set their own lower loan limits at the program level. The caps can be equal or less than federal limits, but not higher.	This change will give institutions more control regarding program-level federal borrowing. Limits must be applied to entire programs and not applied on a student-by-student basis.	Passed (7.4.25). This change will take effect in July 2026.
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. Current borrowers must transition to new plans between July 2026 and July 2028. Additionally, pending court approval, a joint settlement will end the SAVE plan, so SAVE borrowers will likely have to change plans before 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. Additionally, students must now include foreign income in their financial aid calculations when determining Pell Grant eligibility, and families with a Student Aid Index more than twice the maximum Pell Grant are excluded from receiving Pell Grants.	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. This is likely to impact student athletes who receive full-ride scholarships.	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. Programs must be between 150 to 599 clock hours and between 8 to 15 weeks. The amount of aid given will be prorated based on the number of clock hours, credits, or weeks of the program. Programs must meet state and federal quality standards and demonstrate high completion rates, job placement rates, and earnings outcomes. Students who have obtained a graduate credential will not be eligible, and students cannot receive traditional Pell and Workforce Pell at the same time.	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. Workforce Pell may give institutions a new opportunity to engage non-consumers and potentially reengage stop outs. However, due to the requirements that programs must meet in order to qualify, Workforce Pell implementation could be a heavy administrative and operational lift for institutions.	Passed (7.4.25). Workforce Pell is expected to go into effect on July 1, 2026.
Changes to Student Loan Deferment, Forbearances, and Loan Rehabilitation	Borrowers who take out loans 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). These changes take effect 7.1.27.
Changes to 529 Plans	The annual withdrawal limit for K-12 expenses will be increased from $10,000 to $20,000. Qualifying K-12 expenses are expanded to include expenses such as textbooks, online educational materials, tutoring, standardized testing fees, dual enrollment fees, and educational therapies for children with disabilities. Additionally, 529 funds now cover professional certification examination and licensing fees, as well as tuition, books, fees, and exam costs for workforce credentials, trade schools, and certificate programs.	This shift means that students do not have to attend college in order to use 529 plans, with the intention of reducing families' fears that 529 savings will be "trapped" if their children do not attend college. However, it is unclear if increasing the number of uses of 529 plans will lead to more people saving in the accounts.	Passed (7.4.25). The addition of credentialing programs and expanded list of eligible K-12 expenses took effect on 4.5.25. The $20K limit took effect January 1, 2026.
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)

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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 accreditors entering the market.

Policy	Description	Implications for Institutions and Students	Current Status
Earnings Test for Institutional Access to Federal Student Loans	In alignment with OBBBA, a new earnings accountability framework will be established for all postsecondary programs that participate in federal student loan programs. For undergraduate programs, the median earnings of graduates must exceed the median earnings of working adults ages 25-34 who are high school graduates. For graduate programs, median earnings must exceed those of working adults ages 25-34 who hold a bachelor’s degree. Programs that fail to pass the earnings benchmark for two out of three consecutive years will lose access to federal student loans.	The earnings test requires expanded program-level reporting and monitoring. Institutions should review programs that may not pass the earnings test, though these programs make up a small percentage of total programs. According to an analysis of Department of Education data by Robert Kelchen, around 5.9% of programs are estimated to fail the earnings tests, although there is variation by institution type, credential type, and field of study. For example, undergraduate certificates have a much higher rate of failure than other credentials.	Passed (7.4.25). The earnings accountability test is set to take effect in July 2026. The proposed regulations will be finalized following a public comment period.
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 previous endowment excise tax was 1.4%, but it only applied to a few dozen private institutions with at least 500 tuition-paying students and at least $500K endowment assets per student. The endowment 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 was enacted starting January 1, 2026.
Accrediting Bodies' Suspension of Diversity Requirements	The WASC Senior College and University Commission and the Accreditation Council for Graduate Medical Education dropped their DEI accreditation standards. The American Bar Association and the American Psychological Association have suspended their DEI standards.	These suspensions and removals, 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.-Oct 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.	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 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)