The Financial Aid Community Needs Clarity From ED (letter)
To the editor,
I am writing in response to the recent article, “ED Clarifies How Current Students Can Access Uncapped Loans” (Aug. 17, 2026).
In the article, a Department of Education spokesperson stated that using completed credits to calculate Expected Time to Credential (ETTC) under the One Big Beautiful Bill Act is “not new” and should “not come as a surprise.” As a financial aid administrator with more than 20 years of experience, I found that statement both astonishing and inconsistent with the guidance institutions have been given to date.
In the Department’s own May 2026 FAQ document, ETTC is described as “the expected time for a student to complete a program that is equal to the lesser of three academic years … or the period determined by calculating the difference between the program length for the program of study in which the individual is enrolled and the period of such program of study that such individual has completed prior to July 1, 2026.” Nowhere was it clearly communicated that institutions should determine ETTC using completed credits in the manner recently described by the department.
This latest clarification is not occurring in a vacuum. Since the enactment of OBBBA, the financial aid community has struggled through shifting interpretations, delayed guidance and significant uncertainty surrounding implementation. Colleges and universities have been asked to operationalize sweeping regulatory changes affecting students’ ability to borrow and finance their education, often without the clear and timely direction necessary to do so responsibly.
What makes this situation particularly troubling is the timing. Many institutions began awarding aid packages months ago. Schools have already notified students of their eligibility, finalized financial aid offers and in many cases disbursed funds. Revising a fundamental interpretation of eligibility requirements midway through August, after academic terms have already begun at some institutions, creates unnecessary disruption for students and administrative chaos for schools.
Financial aid professionals are not resisting change. We are asking for clarity, consistency and accountability. Our responsibility is to accurately implement federal policy on behalf of students. That task becomes nearly impossible when guidance evolves without acknowledgment of prior interpretations and institutions are told they should have anticipated changes that were never clearly communicated.
I was disappointed that the article did not more critically examine the discrepancy between the department’s prior guidance and its current position. Multiple voices quoted in the piece described a significant shift in interpretation, yet the department’s assertion that this approach was always understood went largely unchallenged.
The financial aid community deserves coverage that reflects the reality of what institutions have experienced throughout the implementation of OBBBA: uncertainty, moving targets and an ongoing struggle to obtain clear answers. Most importantly, students deserve better than policy changes and reinterpretations that occur after schools have already built their aid processes around the guidance provided.
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