Update on April 23, 2026: We are sharing additional details about the transition to the updated ISIR layout on Sunday, April 26:
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The last batch of ISIRs using the existing layout will be delivered on the morning of Friday, April 24, per normal delivery processes.
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NSLDS post-screening will be paused for one week to simplify the transition to the new ISIR layout. This means that ISIRs delivered on Monday, April 27, will not include updated post-screening codes. NSLDS post-screening will resume the following weekend (May 3) on the regular schedule.
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The first batch of ISIRs using the new layout will be generated on Monday, April 27 and delivered to school and state SAIG mailboxes on Tuesday morning, per the regular schedule.
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Please note: FSA will closely monitor ISIR generation post-launch to ensure that the system is operating as expected. The Department may choose to pause ISIR delivery if there are issues that need to be resolved. If this happens, we will notify partners as an update to this EA and via the FSA Tech Listserv.
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Loan limit exception flags are managed by the Common Origination and Disbursement (COD) System. Changes to this flag will trigger an updated NSLDS post-screening transaction on the regular post-screening schedule. If you have questions about which students have loan limit exceptions, please refer to the new COD <LoanLimitException> field, which will be set with an initial value on Sunday.
This electronic announcement describes updates to several Federal Student Aid (FSA) systems and the Free Application for Federal Student Aid (FAFSA®) processing experience resulting from the One Big Beautiful Bill Act (P.L. 119-21) (OBBBA), which established Federal Pell Grant (Pell Grant) eligibility for eligible workforce programs and modified loan limits. In anticipation of the program changes to Title IV programs under OBBBA that are required to be implemented on July 1, 2026 or later, these system changes will go live on April 26, 2026.
All student- and contributor-facing FAFSA form changes related to OBBBA were made in September 2025 in advance of the general availability of the 2026–27 FAFSA form (see APP-25-23). Following the April 26, 2026, changes to the processing elements, FSA does not anticipate that any additional changes related to OBBBA will be made to the FAFSA application.
The Department of Education (Department) is currently engaged in rulemaking on numerous OBBBA provisions. While final regulations are forthcoming, we are providing the technical guidance below to support institutions, states, and vendors in preparing their systems to implement these changes in April. If the forthcoming regulations result in changes to these technical updates, we will provide additional guidance at that time.
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We are updating the FAFSA Processing System (FPS) to account for the OBBBA change that extends Pell Grant eligibility to a student enrolled in an eligible workforce program even if the student has already obtained a bachelor’s degree. Before OBBBA, students with a bachelor’s degree could only receive a Pell Grant to enroll in certain teacher certification programs.
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A new field, "Enrolled in Eligible Workforce Program," will be added to the FAFSA Partner Portal (FPP), Electronic Data Exchange (EDE) batch corrections system. This field will also be added to the end of the “Matches and Other Processing Information” block in the Institutional Student Information Record (ISIR). The options for this field are:
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1 = Yes
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2 = No
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<blank> = Null
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When a student submits a FAFSA form for the first time, the value of this field will be set to ‘blank’ for the initial transaction. Pell Grant eligibility will be calculated on this initial transaction consistent with existing practice. If the student has indicated that they have already received a bachelor’s or graduate degree or are currently enrolled in a program leading to a graduate degree, the Pell eligibility flag will be set to ‘No’.
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A financial aid administrator (FAA) must manually set this field to 'Yes' via a correction in FPP or via EDE batch correction to indicate that this student is enrolled, or accepted for enrollment, in an eligible workforce program that has been approved by the Department.
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Once the indicator is set to ‘Yes', FPS will process a new ISIR transaction that includes updated Pell Grant eligibility. A student who meets all requirements to qualify for a Pell Grant except that they have obtained a bachelor’s degree will then become eligible for a Pell Grant. Schools must still confirm that students enrolled in eligible workforce programs meet all eligibility criteria, including not having a graduate credential or currently being enrolled in a graduate program.
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All schools listed on the FAFSA form and state agencies will receive this new transaction, even if they did not update the “Enrolled in Eligible Workforce Program” indicator. We will update the FAFSA Submission Summary to make this clear to students. Partners should note that this new transaction may include additional corrections unrelated to Workforce Programs.
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To help prevent schools from incorrectly disbursing a Pell Grant to a student who qualifies for Pell Grant funds due to enrollment in an eligible workforce program at another institution, the Common Origination and Disbursement (COD) system will generate a new warning edit. This warning will prompt schools to confirm that the disbursement is for an eligible workforce program whenever they attempt to disburse funds on a transaction with the “Enrolled in Eligible Workforce Program” indicator selected and for which tuition and fees were not reported.
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If the student ceases to be enrolled in the program, the institution must make a correction to set the field to 'No'. If the school initially set the indicator to ‘Yes’ because the student was accepted into an eligible workforce program, but the student never enrolls in the program, the institution should change the field to blank. If a student is never accepted into and never enrolls in an eligible workforce program at an institution, the institution may leave the field blank.
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We are updating the National Student Loan Database System (NSLDS®) match process to account for a new lifetime maximum loan limit, limits on Direct PLUS loans for parent borrowers, and the elimination of eligibility for Direct PLUS loans for graduate and professional students.
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The NSLDS Information block on the ISIR has been updated to accommodate new aggregate loan limits, academic levels, and loan limit exception flags. This includes several new fields, as well as 12 additional NSLDS post-screening reason codes.
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FPS has extended existing logic for FPS-C flags, edits, and comments to align with these changes. For example, FPS-C flags will be set for new indicators such as the NSLDS Professional Combined Limit Indicator when the value of the indicator is set to E (Exceeded). See the 2026–27 FAFSA Specifications Guide for full details.
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All changes to the FPS, NSLDS, and COD systems described above will be released on April 26, 2026. As previously communicated, eligibility changes and modified loan limits will go into effect on July 1, 2026.
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This release will include a mid-cycle update to only the 2026–27 ISIR format. The 2025–26 ISIR format will not change. Any 2026–27 ISIR generated on or after April 26 will be generated in the new format.
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A draft version of the updated 2026–27 ISIR layout and Volume 4A of the 2026–27 FAFSA Specifications Guide are now available. Updates to Volume 1, Volume 4B, Volume 5, Volume 6, and Volume 7 of the guide will be published over the next month. We will post an update here when they are available.
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There won’t be a large-scale reprocessing effort as part of this launch. Changes to student records in NSLDS may trigger a post-screening NSLDS system generated transaction using the existing process.