Q1) Is the student considered an interim exception borrower for 2026-27 and subject to the pre-July 1, 2026, parent PLUS limits?

A1) Yes. This student‘s parents would be eligible for PLUS under the interim exception because the student’s estimated time to credential (ETTC) equals the lesser of three years or the period determined by calculating the difference between the program length for the program of study in which the individual is enrolled (program length = 4 years) and the period of such program of study that such individual has completed as of the date of the determination (completed 1 year). This borrower has 3 years of interim exception eligibility (4 − 1 = 3).

Q2) When would the student lose interim exception eligibility and be subject to the new parent PLUS limits?

A2) After the 2028-29 academic year. If this borrower enrolled in 2029-30, the interim exception would have expired and they would no longer be eligible for the exception. Additionally, this student would lose interim exception eligibility earlier if they withdrew or otherwise ceased to be enrolled in the program of study at any point after receiving the interim exception.

Q3) If the parents borrowed at least $65,000 aggregate total in parent PLUS when the student reaches the period where they lose interim exception eligibility, what is the student’s eligibility for parent PLUS funds when the student returns to school at that time?

A3) During the student’s estimated time to credential (ETTC), the parents are not subject to the aggregate loan limit of $65,000; however, when the exception expires, the limit kicks in and looks at all that has been borrowed. If the parents borrowed at least $65,000 on the student’s behalf, they have exhausted their eligibility.

Q4) Is the student considered an interim exception borrower for 2026-27 and subject to the pre-July 1, 2026, parent PLUS limits?

A4) Yes. This student‘s parents would be eligible for the PLUS under the interim exception because the student’s ETTC equals the lesser of three years, or the period determined by calculating the difference between the program length for the program of study in which the individual is enrolled (program length = 4 years) and the period of such program of study that such individual has completed as of the date of the determination (completed 2 years). This borrower has 2 years of interim exception eligibility (4 − 2 = 2).

Q5) When would the student lose interim exception eligibility and be subject to the new parent PLUS limits?

A5) After the 2027-28 academic year. If this borrower enrolled in 2028-29, the interim exception would have expired and they would no longer be eligible for the exception. New loan limits would apply. Additionally, this student would lose interim exception eligibility earlier if they withdrew or otherwise ceased to be enrolled in the program of study at any point after receiving the interim exception.

Q6) If the parents borrowed at least $65,000 aggregate in parent PLUS when the student reaches the period where they run out of interim exception eligibility, what is the student’s eligibility for parent PLUS when the student returns to school at that time?

A6) If the parents have already borrowed $65,000 or more on the student’s behalf, the parents do not have any additional PLUS eligibility.

Q7) Is the student considered an interim exception borrower for 2026-27 and subject to the pre-July 1, 2026, parent PLUS limits?

A7) Yes. This student‘s parents would be eligible for the PLUS during the interim exception because the student’s ETTC equals the lesser of three years, or the period determined by calculating the difference between the program length for the program of study in which the individual is enrolled (program length = 4) and the period of such program of study that such individual has completed as of the date of the determination (completed 3 years). This borrower has 1 year of interim exception eligibility (4 − 3 = 1).

Q8) When would the student lose interim exception eligibility and be subject to the new parent PLUS limits?

A8) After the 2026-27 award year. If this borrower enrolled in 2027-28, the limited exception would have expired and the parents would no longer be eligible for the exception. Additionally, this student would lose interim exception eligibility earlier if they withdrew or otherwise ceased to be enrolled in the program of study at any point after receiving the interim exception.

Q9) If the parents borrowed at least $65,000 aggregate in parent PLUS when the student reaches the period where they run out of interim exception eligibility, what is the student’s eligibility for parent PLUS when the student returns to school at that time?

A9) During the interim exception, parents are not subject to the new aggregate loan limit of $65,000; however, when the exception expires, the limit kicks in and parent PLUS borrowers who have borrowed at least $65,000 on the student’s behalf have exhausted their eligibility.

The student in this case does not lose aid eligibility due to their parents now exceeding the PLUS aggregate loan limit. The student can continue to borrow student Direct Loans within the applicable aggregate and lifetime loan limits based on their dependency status and grade level.

Q10) Is the student considered an interim exception borrower for 2026-27 and subject to the pre-July 1, 2026, parent PLUS limits?

A10) No. This student is no longer eligible for the interim exception because student’s ETTC equals the lesser of three years, or the period determined by calculating the difference between the program length for the program of study in which the individual is enrolled (program length = 4) and the period of such program of study that such individual has completed as of the date of the determination (completed 4 years). This  borrower is not eligible for the interim exception (4 − 4 = 0).

Q11) When would the student lose interim exception eligibility and be subject to the new parent PLUS limits?

A11) This student never qualifies for the interim exception.

Q12) What is the student’s eligibility for parent PLUS when the student returns to school at that time, as the parents have already borrowed $80,000 in parent PLUS?

A12) There is no remaining eligibility because the post-July 1, 2026, parent PLUS aggregate limit becomes effective for this student on July 1, 2026, and the parent has already borrowed more than the $65,000 aggregate limit.

Q13) What if this student struggled in a few classes in the past, went part time in the past, or just needs to return for one more semester in Fall 2026 to obtain their degree/credential? Because the regulations begin by saying “From July 1, 2026…,” some believe that the three-year clock starts on July 1, 2026, giving current students an off-ramp because they were already in school. Some cannot imagine Congress intended to cut them off suddenly without a way to finish the last semester.

A13) If the student was still enrolled on June 30, 2026, they will get the benefit of the interim exception for the lesser of three years or the time it takes to complete the program if the length of time in the program is less than four years. During the interim exception, if eligible, the student’s parents will not be subject to parent PLUS annual or aggregate loan limits. Students who have completed four years of a four-year program will not be eligible for parent (or graduate) PLUS under the interim exception. The student’s ETTC is zero. The new PLUS limits are effective July 1, 2026 (unless they are in the interim exception); such students no longer have PLUS eligibility.

The student in this case does not lose aid eligibility due to their parents now exceeding the PLUS aggregate loan limit. They can finish their program of study using student Direct Loans within the applicable aggregate and lifetime loan limits based on their dependency status and grade level.