CBO: 15 Credit Full-Time Estimate Costs $7.1B, How Does It Impact States?

By Bill DeBaun, Senior Director, Data and Strategic Initiatives, and Catherine Brown, Senior Director, Policy and Advocacy

Reading time: Seven minutes

The House of Representatives’ reconciliation bill narrowly passed before Memorial Day and it’s now up to the Senate to respond to that bill or propose their own version. As we’ve noted, the House reconciliation bill increases the number of credits per semester required for students to receive a maximum Pell Grant from 12 to 15.

The Congressional Budget Office (CBO) “estimates that enacting this provision would reduce direct spending outlays by $7.1 billion over the 2025‑2034 period.” That’s nationwide, but this analysis examines what states stand to lose under this proposal.

The estimated $7.1 billion in outlays over 10 years (which represents a savings to the US Treasury and a cost to students pursuing postsecondary education) calculated from this provision by CBO is an underestimate for at least two reasons:

• First, CBO assumes that the maximum Pell Grant will remain the same as it is today for the coming decade even though the maximum Pell Grant has risen by about 3% annually in nominal terms over the last decade, during periods of bipartisan leadership in Congress. While the maximum Pell Grant, which is set annually by Congress, may remain the same, it may also fall, as the President proposed in his fiscal year 2026 budget, or rise to reflect inflationary increases, as it has in the recent past.
• Second, this provision will also result in discretionary savings that are impossible to estimate given currently available public information. The mandatory "add-on" funding included in CBO's score disproportionately funds Pell Grants for students from the lowest income families who are receiving the maximum award, but the distribution of credit hours that students are currently taking by award level is not available. Nevertheless, millions of students whose Pell Grants are funded largely or entirely by discretionary funds will see their awards drop if this provision is enacted, significantly increasing the savings to the US Treasury and cuts to Pell for students trying to afford college.

The table below shows states’ shares of Pell Grant recipients, their proportionate share of the $7.1 billion that CBO estimates states will lose annually and in total over the next 10 years, and the estimated number of students in the 24-29 credit range who could be impacted by this policy change. A methodology section appears at the end of this post.

The Center for American Progress also examined the potential impacts on Pell Grant recipients resulting from changes in the reconciliation bill. Dr. Sara Partridge estimates that 4.4 million Pell Grant recipients, representing “nearly two out of three recipients” who “could lose some or all their federal grant aid.” The analysis above borrows Dr. Partridge’s methodology to identify the number of Pell recipients taking 24-29 credits (“part time, formerly full time”) by state.

The National College Attainment Network (NCAN) opposes the proposal to require students to take 15 credits to receive a full time Pell Grants. Increasing the credit requirement from 12 to 15 would result in a $1,479 cut to the maximum Pell Grant of $7,395 for any student taking 12 credits, approximately a quarter of Pell recipients. Those students’ Pell award would drop to $5,916 if this bill is enacted. This proposal takes effect during the 2026-27 school year and continues for the 10 subsequent years, changing the value of student aid offers made throughout this year.

While there is evidence that students who take 15 credits per semester complete a degree faster than those who do not, millions of students are unable to do so due to work or caregiving obligations, or because taking 15 credits is too heavy a load, especially in their first semester as they adjust to college. According to the US Department of Education, 40% of full-time college students work while enrolled to afford the full cost of attendance. NCAN’s 2024 Growing Gap analysis found that the average Pell student faces an affordability gap of $1,690 and two-thirds of BA-granting institutions are not affordable for these students. 

Methodology

The table above estimates the amount of Pell Grant dollars lost and the number of Pell Grant recipients impacted by moving the definition of “full-time enrollment” to 15 credits from 12. We first estimate the share of Pell Grant recipients by state using the number of Pell Grant recipients by home state from the Office of Federal Student Aid’s “Pell End-of-Year Reports: Table 22: Distribution of Federal Pell Grant Recipients by State of Legal Residence and Control of Institution Award Year 2022-2023” and dividing each state’s total number of recipients by the national total of recipients for AY 2022-23. We multiply that resulting percentage of Pell Grant recipients by the number of students by home state by the total number of Pell Grant recipients for academic year 2024-2025 (6,852,746) from the “Aid Recipients Summary: Award Year 2024-2025 Recipient Summary.” This yields an estimated number of Pell Grant recipients by state.

To obtain an estimate of the number of Pell Grant recipients impacted specifically by the move to a 15-credit full time definition, we multiply the estimated number of Pell Grant recipients in 2024-25 by the 28.5% of Pell Grant recipients taking 24-29 credits in the 2011-12 academic year. This figure comes from the Center for American Progress’ analysis of National Center for Education Statistics, “Beginning Postsecondary Students (BPS): 2012/2017” (retrieval code ‘wjdqqk’) and data from the Integrated Postsecondary Education Data System (IPEDS). See Table 1: https://www.americanprogress.org/article/congressional-republicans-proposed-budget-reconciliation-bill-imperils-4-4-million-pell-grant-recipients/.

To obtain an estimate of the number of Pell Grant dollars lost over the period 2025-34, we multiply the calculated share of Pell Grant recipients by state by the $7.1 billion CBO estimates will be lost in direct spending outlays over this period.

Assumptions we make in this analysis include:

• National enrollment patterns by credit hour from the 2011-12 academic year are still applicable in 2024-25 nationally and across states.
• States’ shares of Pell Grant recipients in the 2022-23 award year are the same in the 2024-25 award year.

Acknowledgments

The authors are grateful to Dr. Sara Partridge at the Center for American Progress for her work in this area, from which this analysis draws sources and inspiration. The authors are also grateful to Nick Lee at Bellwether for his insight in the development of this post.

Read More:

• Judge Orders Restoration of AmeriCorps Funding in Lawsuit Challenging Grant Cancellations
• Talking Points: Act Now to Save Pell Grants
• House Reconciliation COA Proposal Raises Questions