Summary of AB 2251 (2025-2026) – California Cal Grant Program: Cost of Attendance
Purpose and intent
- AB 2251 would require qualifying postsecondary institutions participating in California’s Cal Grant Program to develop and implement a formal cost of attendance (COA) policy and adjustment process that aligns with federal standards (specifically, references to 20 U.S.C. 1087ll and Title 34 CFR).
- The bill sets a deadline for implementation: by the start of the 2027–28 academic year for the COA policy and adjustment process, and for certain COA disclosure requirements to be in place at that time.
Key provisions and changes
- Qualifying Institution COA policy and adjustment process
- By 2027–28, institutions must develop and implement a COA policy and an adjustment process to estimate and adjust COA information consistent with federal standards.
- The COA policy must be publicly displayed, with data sources and assumptions used to calculate each component of the COA budget clearly disclosed on the institution’s COA webpage.
- The adjustment process must cover adjustments to any COA expense category (housing, food, transportation, books, supplies, personal expenses, dependent care, etc.).
- Eligible adjustment circumstances include: housing costs above the COA allowance, computer purchases, uninsured medical expenses, transportation costs above allowance, dependent care, disability-related expenses, and other reasonably incurred costs.
- Institutions must accept both electronic and hard-copy adjustment requests, complete reviews within 30 business days after all required documents are submitted, and notify students of decisions. Denied requests must include reasons; a second review can be requested if denied.
- Institutions must allow adjustments at any time during enrollment, with a prohibition on deadlines earlier than three weeks before the end of each term and without limiting the total number of adjustment requests.
Satisfactory Academic Progress (SAP) framework
- By the start of 2027–28, institutions must adopt SAP policies aligned with federal standards (Title 34 CFR 668.34), including:
- Minimum GPA and pace of completion standards.
- Student orientation and clear communications about SAP standards and the appeals process (including on syllabi and loan/aid letters).
- Notification to students after each term if SAP standards are not met.
- Cumulative (not term-by-term) evaluation for SAP; ability for students on financial aid probation to follow an academic plan.
- Provisions for transfer students’ maximum timeframe calculations.
- Acceptance of both electronic and hard-copy financial aid appeals; broad consideration of special circumstances (e.g., death, illness, pregnancy, homelessness, loss of childcare, employment changes, transportation issues, crime victimization, natural disasters, major changes).
- Timelines: appeals reviewed within 45 days of a complete submission; no disenrollment for nonpayment while an appeal is pending; a second review option if requested.
- Policies must also ensure that remedial coursework, if offered, is excluded from maximum timeframe calculations and that students on an approved academic plan may continue to receive aid during terms they meet plan terms.
Disclosure and accountability
- Institutions must disclose COA data sources, assumptions, and adjustment procedures publicly.
- The bill emphasizes alignment with federal COA standards and the federal framework for professional judgments and adjustments (COA adjustments on a case-by-case basis for individual students).
Financial and regulatory considerations
- No new state appropriations are attached to AB 2251 (the bill’s Digest notes “Appropriation: NO”).
- The measure would be overseen by the Student Aid Commission as the administering body for Cal Grant requirements, in coordination with participating institutions.
Who is affected
- Qualifying California postsecondary institutions participating in the Cal Grant Program (public, private nonprofit, and certain for-profit institutions meeting the statute’s criteria).
- Cal Grant recipients and prospective applicants, whose COA budgets, financial aid eligibility, and SAP-related aid decisions may be affected by COA policy changes and adjustment processes.
- Institutions’ financial aid offices, which would implement COA policies, adjustment workflows, and SAP-related procedures.
Timeline and procedural notes
- Key deadlines:
- By the start of the 2027–28 academic year: institutions must have COA policies and adjustment processes in place, and SAP standards in line with federal rules.
- By the same period: COA data disclosure requirements must be implemented as described.
- The bill has been amended and re-referred to the Assembly Committee on Appropriations, with prior referrals to Higher Education and related committees noted in the action history.
Bottom line
AB 2251 seeks to modernize and standardize how COA is calculated and adjusted for Cal Grant eligible students, ensuring transparent data, timely consideration of adjustments, and clearer SAP standards that match federal expectations. The measure aims to reduce gaps between students’ actual costs and their financial aid awards, potentially increasing aid accuracy and affordability for California students.
