New Title VIII Incorporates the Senate Parliamentarian’s Directives On Some Proposals, Modifying Others To Pass Byrd-Rule Approval
Overview
Earlier this week CSPEN shared with the higher education community information regarding decisions made by the Senate Parliamentarian regarding all of the Sections of Title VIII – The Committee on Health, Education, Labor, and Pensions (HELP) Budget Reconciliation proposals. At that time we highlighted the proposal that the Parliamentarian had rejected and also those that were “still open” per her decision-making authority. During our Thursday CSPEN Federal Legislative and Regulatory Update webinar we noted that the HELP Committee, along with all other Committees would now begin a process of making necessary revisions to their portions of the mega-bill.
Early this morning, a comprehensive rewrite of the entire budget reconciliation bill was released, incorporating recissions and/or modifications to the proposals previously rejected, for review by all Senators prior to Senate floor consideration of the entire package which Senate Majority Leader Thune intends to begin as soon as possible.
A copy of the full text of the bill can be accessedhere – (www.budget.senate.gov/imo/media/doc/the_one_big_beautiful_bill_act.pdf) Title VIII begins on page 755).
CSPEN has provided the HELP Committee’s summary verbatim below following our own brief summary of noteworthy changes and unfortunately omissions from the Senate proposal.
CSPEN Quick Summary
The Good News
The Senate HELP proposals made modifications to the Federal Workforce Pell Grant program, resurrected the proposal from the list of rejected proposals. The reworked proposal maintains institutional eligibility for all sectors of the higher education community, but was revised to exclude unaccredited programs and correspondence programs. The reworked proposal maintains the integrity “guardrails” and focus on States’ determination of “high demand” jobs – issues will be the focus of considerable future deliberations as part of Federal Negotiated Rulemaking.
The Senate HELP proposal also made accommodations delaying the effective date of implementation of the two Seante “Regulatory Relief” repeal proposals on BDR and Closed School Discharges. Instead of repealing the provisions, the revised language prohibits implementation of the Biden regulations prior to July 1, 2035.
The Seante HELP proposal maintained, with modification limits on the ability of the current Secretary and future Secretary’s of Education to develop and implement regulations on FSA beyond the current statutory guidance.
The Bad News
The Senate HELP proposal fails to include the two additional “Regulatory Relief” provisions – Repeal of the 90/10 and Financial Value Transparency/Gainful Employment Rules –included in the House passed Budget Reconciliation bill.
The Senate HELP proposal maintains a complex and problematic “Low-Earnings Outcome” accountability regime. Under the revised proposal, all Title IV programs awarding an undergraduate degree, graduate or professional degree, or graduate certificate, for which the median earnings (as determined by the Secretary) of the programmatic cohort of students who received funds under this title for enrollment in such program, who completed such program during the academic year that is 4 years before the year of the determination, who are not enrolled in any institution of higher education, and who are working, are, for not less than 2 of the 3 years immediately preceding the date of the determination, less than the median earnings of a working adult (24-35 year old high school individuals for undergrad assessment/baccalaureate degree holders for graduate/professional, who are not currently enrolled in an institution of higher education.
A more comprehensive assessment will follow later this weekend or early next week.
HELP Committee’s Section-by-Section Summary
HELP Committee Provisions of the Senate’s One Big Beautiful Bill Act
Section by Section (June 27, 2025)
Subtitle A—Student Eligibility
Sec. 80001. Exemption of Farm and Small Business Assets
* Farm fix: Exclude farm, small business, and fishing business assets from aid eligibility formula
Subtitle B—Loan Limits
Sec. 81001. Establishment of Loan Limits
* Cap graduate lending: Eliminate Grad PLUS loans and cap unsubsidized graduate (e.g., masters) borrowing at $20,500 per year ($100,000 lifetime) and professional (e.g., law, medicine) borrowing at $50,000 per year ($200,000 lifetime); graduate limits are in addition to undergraduate limits
* Cap parent borrowing: Cap loans to parents of undergraduates (parent PLUS) at $20,000 per student per year ($65,000 per student lifetime; parents can borrow for multiple students)
* Prorate loans: Set lower limits for part-time students (e.g., half-time student eligible for half the maximum loan); this aligns with how the Pell Grant is distributed
* Institutional discretion: Allow institutions to set lower loan limits as long as they do so consistently within programs
Subtitle C—Loan Repayment
Sec. 82001. Loan Repayment
* Simplify repayment for new borrowers: Loans made starting July 1, 2026, can be repaid using only two plans: a new standard plan and a new income-driven repayment (IDR) plan; existing plans (SAVE, PAYE, ICR, graduated, extended, alternative) are eliminated
* New standard plan: borrowers make fixed payments for 10-25 years based on amount borrowed
* Repayment Assistance Plan: New income-driven plan where payments are 1-10% of income depending on income level, with a minimum monthly payment of $10; payments are reduced by $50 per dependent; borrowers who make on-time payments always see their balance go down, as unpaid interest is waived and there is a principal match of up to $50; any remaining balance is forgiven after 30 years
* Streamline income-driven repayment for existing borrowers: Beginning July 1, 2028, existing borrowers (with loans taken before July 1, 2026) will have access to the Repayment Assistance Plan and the income-based repayment (IBR) plan created by Congress; under IBR, pre-2014 borrowers pay 15% of discretionary income (income above 150% of the Federal Poverty Line) with forgiveness after 25 years; post-2014 borrowers pay 10% of discretionary income with forgiveness after 20 years
Sec. 82002. Deferment and Forbearance
* Streamline deferments: Eliminate economic hardship and unemployment deferments to encourage borrowers to use options (such as income-driven repayment) that are better for them
* Limit forbearances: Limit availability of discretionary forbearances to no more than 9 months during any 24-month period
Sec. 82003. Loan Rehabilitation
* Loan rehabilitation: Allow borrowers to rehabilitate defaulted loans twice instead of once; set required monthly payment for rehabilitation at $10 instead of $5
Sec. 82004. Public Service Loan Forgiveness
* Repayment Assistance Plan: Allow payments made under the Repayment Assistance Plan to count toward PSLF eligibility
Sec. 82005. Student Loan Servicing
* Additional funds: Provide funds to the Department of Education for costs associated with returning borrowers back into repayment on their loans and to help with the costs of building the new repayment plans
Subtitle D—Pell Grants
Sec. 83001. Eligibility
* Foreign income: Require foreign income to be included in the income calculation for the purposes of calculating Pell Grant eligibility
* Exclusion of higher-income families: Exclude families with a Student Aid Index more than twice the maximum Pell grant from receiving Pell
Sec. 83002. Workforce Pell
* Workforce Pell Grants: Expand eligibility for Pell Grants to students enrolled in short-term (150-599 clock hours), high-quality, workforce aligned programs; include guardrails for student outcomes including earnings, completion rates, and job placement rates; limited to accredited institutions
Sec. 83003. Pell Shortfall
* Reduce shortfall: Provide additional funding for the Pell Grant program in FY26 to address the funding shortfall
Sec. 83004. Limits for Students with Full Scholarships
* Limit Pell for full-ride Students: Exclude students receiving full cost-of-attendance scholarships from Pell eligibility
Subtitle E—Accountability
Sec. 84001. Ineligibility Based on Low Earning Outcomes
* Establish “do no harm” standard: End federal loan eligibility for programs that leave students worse off than if they had never gone
* Prohibit new federal student loans from paying for undergraduate degree programs where the majority of completers earn less than the median high school graduate in the same state
* Prohibit new federal student loans from paying for graduate programs where the majority of completers earn less than the median bachelor’s degree recipient in the same field in the same state
* Programs lose eligibility if they fail to meet the standard for two years in a three-year period.
Subtitle F—Regulatory Relief
Sec. 85001. Borrower Defense to Repayment
* Rule repeal: Delay Biden expansion of Borrower Defense to Repayment regulation for 10 years, restoring regulation from first Trump Administration
Sec. 85002. Closed School Discharge
* Rule repeal: Delay Biden expansion of Closed School Discharge regulation for 10 years, restoring regulation from first Trump Administration
Subtitle G—Limitation on Authority
Sec. 86001. Limitation on Regulations
* Limit regulations: Restrict the Secretary of Education’s ability to issue regulations and executive actions that increase costs, or subsidies, in the Federal Student Loan program
What’s Next
CSPEN will do a much deeper dive into not only Title VIII – HELP Committee, but also Title VII – Finance and other portions of the bill which, as we have noted in prior emails, also have an impact on students, institutions, and employers in relation to higher education. For example, we will look at the Finance proposals related to exclusion of portions of tip income from taxable income, revisions to student 529 accounts, et. al. will be provided.
