In July 2025, Congress passed the One Big Beautiful Bill Act (OBBBA) enacting significant changes to federal higher education policy (see NAICU's bill summary). For independent institutions of higher education, three changes matter most:
The new "Do No Harm" program-level accountability framework
New graduate lending reforms, including annual and aggregate borrowing limits and professional and non-professional program classifications
The new Workforce Pell Grant program
To implement these changes, the Trump Administration launched a series of negotiated rulemaking sessions in 2025 with the goal of finalizing regulations for implementation beginning July 1, 2026. Although litigation and other delays have postponed some provisions, the Department of Education remains on track to fully implement Congress's framework by July 1, 2027.
In addition to the three rulemakings to implement the One Big Beautiful Bill Act, the Department of Education also embarked on a regulatory journey to reform the higher education accreditation model in spring 2026. Details regarding the accreditation rulemaking process can also be found below.
These pages provide updates on the regulatory process, including individual rulemakings, along with NAICU's analysis, comments, and practical tools and resources to help campuses assess the impact. To make it easier to understand what has changed and what lies ahead, NAICU has created a Regulatory Roadmap to highlight of the regulatory changes that took effect on July 1, 2026, and those scheduled for July 1, 2027.
In Progress
Accreditation, Innovation, and Modernization (AIM)
When finalized, this rule is expected to make substantial changes to the regulations governing the Title IV accreditation process. Key proposed changes would revise how accreditors apply their standards, establish new transfer-of-credit requirements, strengthen protections for civil rights and civil liberties, and make it easier for institutions to gain recognition from new accreditors, change accreditors, or hold accreditation from multiple accrediting agencies.
Docket: ED-2025-OPE-1042
Agency: Dept. of Education
Published: TBD
Completed
AHEAD 2.0: Student Tuition and Transparency System (AKA Do No Harm)
The Student Tuition and Transparency System (STATS) and Earnings Accountability framework would implement the Working Families Tax Cuts Act's new statutory earnings accountability measure. The framework is designed to determine whether students leave a program financially better off than when they entered and penalize programs that do not. As proposed, the regulation will consolidate three overlapping systems across all sectors by replacing Financial Value Transparency (FVT) with STATS, updating Gainful Employment (GE) regulations, and implementing the new earnings-accountability requirement.
Docket: ED-2026-OPE-0100
Agency: Dept. of Education
Published: July 1, 2026
This rule implements the Workforce Pell Grant program established by the Working Families Tax Cuts Act (P.L. 119-21) - legislation the Department of Education previously referred to as the One Big Beautiful Bill Act - and a related provision that excludes students from Pell Grant eligibility when nonfederal grant aid covers their full cost of attendance. The rule takes effect July 20, 2026, with institutions permitted to implement them as early as July 1, 2026.
Docket: ED-2026-OPE-0133
Agency: Dept. of Education
Published: May 19, 2026
Reimagining and Improving Student Education (RISE)
The RISE final rule implements the student-loan provisions of the Working Families Tax Cuts Act (P.L. 119-21), the law the Department previously referred to as the One Big Beautiful Bill Act. It establishes new loan limits for graduate students, professional students, and parents, phases out the Grad PLUS Program, and consolidates the existing repayment plans while creating a new statutorily authorized income-driven repayment plan.
Docket: ED-2025-OPE-0944
Agency: Dept. of Education
Published: May 1, 2026