When Donald Trump was elected president in November, many borrowers wondered how his administration would impact student loan policies. Concerns grew that Trump might impose stricter regulations on programs like Income Driven Repayment (IDR). Borrowers have also questioned which policies from the Biden Administration might be at risk of being eliminated.
The Biden administration had a mixed record on student loan policies. Over the past four years, some changes included more than a million borrowers achieving Public Service Loan Forgiveness (PSLF), six pauses on payments due to the COVID-19 pandemic, the introduction of the generous SAVE plan, and attempts at large-scale student loan forgiveness. However, widespread forgiveness faced significant legal challenges and ultimately failed (twice). Additionally, the SAVE plan has been tied up in the courts since July 2024, and it is unlikely to proceed.
As the second Trump administration begins its term, many feel it will try to inhibit future and existing student loan programs. Trump is not a big fan of loan forgiveness, and he could try to roll back some of the previous administration's initiatives. But we've yet to see him specifically address student loans since his inauguration. Unlike his first term, Republicans now control all three branches of government. Their majority is slim with a 218-215 margin in the House and a 53-47 split in the Senate. This narrow majority could complicate efforts to pass changes through Congress, particularly with the possibility of a filibuster requiring 60 votes to overcome in the Senate.
To navigate these challenges, Republicans could turn to strategies like budget reconciliation, the Congressional Review Act (CRA), or administrative rulemaking through the Department of Education—all of which require only a simple majority or fall under executive authority.
During this period of uncertainty, here are key considerations for student loans.
Will Trump Try to End Public Service Loan Forgiveness?
The PSLF program is safe right now. More than 1 million public servants have reached forgiveness, and applying for PSLF is now more streamlined. The once cumbersome process involving dark ink, faxes, and multiple wet signatures has been replaced with a simple-to-use electronic application portal on studentaid.gov/pslf. Processing times for applications have decreased from months to a matter of weeks. Consequently, the frequent horror stories about PSLF rejections that were once common in major publications have largely diminished due to the program's recent improvements.
I feel confident PSLF will be around for those who are currently enrolled. The master promissory note you signed for your federal student loans has PSLF included.
PSLF could not be eliminated or modified without an act of Congress. And for those already enrolled, I’d expect you to be grandfathered in if there were significant changes to the program.
Recently, there has been discussion online about how this new government may try to tweak PSLF or make it harder to achieve. There’s a memo out now by the House Budget Committee that could become relevant. It is trying to eliminate nonprofit status for many hospitals.
This could be a huge deal for those on PSLF or who are interested in pursuing it. It would basically convert many nonprofit hospitals into for-profit institutions and limit a borrower’s employment options for PSLF. For docs to continue to qualify for PSLF, they may need to work for the VA, Federally Qualified Health Centers (FQHC), etc. I’ll continue to monitor this to see if it gains traction. If this possibility strongly makes you reconsider PSLF, you can start a PSLF Side Fund.
More information here:
The Politics of Student Debt Forgiveness
Is Public Service Loan Forgiveness Worth It for Doctors?
Income Driven Repayment Plans May Be Subject to Change
Income Driven Repayment plans have been around for 30 years. Over the years, the government has created new programs. Each new iteration has been more generous than the previous, thus far.
- 1994: Income Contingent Repayment (ICR)
- 2007: Income Based Repayment (IBR)
- 2012: Pay As You Earn (PAYE)
- 2015: Revised Pay as You Earn (REPAYE)
- 2023: Saving On a Valuable Education (SAVE)
The REPAYE plan was modified and renamed as the SAVE plan in 2023. This was the most generous repayment plan for borrowers—particularly those in residency and fresh out of training—with its interest subsidy and lower monthly payments. But in July 2024, about a year into its existence, multiple states sued the government to stop SAVE. As a result, the courts have put 8 million borrowers into a legal forbearance, with no payments or interest accruing. But those borrowers also aren't accumulating credit toward any loan forgiveness program—at least initially (this time may count through PSLF Buyback)—making it problematic for many who are pursuing forgiveness.
SAVE is likely to be eliminated in 2025, possibly as early as the summer. We are just waiting on the Eighth Circuit Court of Appeals to release a decision. In the wake of SAVE’s demise, it’s important to consider alternative IDR plans and the implications for your student loan plan.
A question I’ve been receiving a lot lately: with SAVE in doubt and likely to be eliminated, will all the IDR plans go away?
Of the existing IDR plans, it’s important to consider how each was created. ICR, PAYE, and SAVE were all created through a similar process known as administrative rulemaking. Like SAVE, the others could be on the chopping block as well or phased out to new entrants.
By contrast, IBR was passed by Congress. It is much safer and likely to stand the test of time. While it could be modified, such changes would require congressional approval and would likely affect future borrowers rather than those currently enrolled. IBR remains a viable fallback option, although it is generally more expensive and requires a partial financial hardship to qualify.
More information here:
3 Backup Plans If SAVE Is Eliminated
Income Certification Resumes
For many borrowers, income certification is resuming for the first time in years. During the COVID-19 pandemic, certification deadlines were postponed, and some borrowers in the SAVE plan have had their deadlines extended into late 2025 or early 2026. However, these dates could be adjusted (again) by the Trump administration, possibly moving them forward.
If you completed your training in 2019 or 2020, you could now be 4–5 years into practice with virtually zero payments on IDR. I've worked with many doctors who haven’t had to certify their income for years and still have those low monthly payments ranging from $100-$400. This has been a catalyst for many docs to stay with PSLF vs. privately refinancing.
Borrowers should prepare for income certification this year, especially if transitioning to a new repayment plan (i.e. they're kicked out of SAVE) or consolidating loans. Certification requires the documentation of current income, such as a recent tax return or pay stub. If your income has increased since you last certified, expect a jump in payment. It’s important to factor in how much you’ll be paying in IDR when you certify this year. Another consideration is if you are applying for a repayment plan, such as PAYE or IBR, you need to qualify for a partial financial hardship. In general, your income needs to be lower than your student loan balance to be eligible to enroll in either (PAYE has more wiggle room than IBR). If your income has drastically increased since you last certified, you may need to run the numbers to see if you qualify for the IDR plan you’re choosing.
Should I Stay or Should I Go (Exit SAVE Now?)
Many borrowers are wondering if they should wait out the legal proceedings with SAVE before switching repayment plans. From July 2024-December 2024, even if you tried to apply for another IDR plan, applications weren't being processed. As of January 2025, the government has reopened applications to switch repayment plans. The answer depends on individual circumstances—what my accountant friends often summarize as, “it depends.” Some borrowers might benefit from staying in forbearance and saving money to make a future lump sum payment. Others, particularly those still in training, might not want to lose valuable months that count toward the 10-year PSLF requirement.
Now, for who should stay put vs. who should change plans.
If you’re planning to refinance your loans, stay in SAVE for now and ride out the 0% interest rate. Start saving what you would be putting into these loans if you were on a fixed monthly payment program so you’re prepared to kick off your repayment when the government turns back on the interest. When it does, get some quotes and refinance your loans. I’ve seen a handful of clients recently with nice quotes in the mid to low 4% range.
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If you’re planning on PSLF, it’s a little more nuanced when deciding should I stay or should I go?
- If you’re less than a year out from PSLF, I’d wait this out and then apply for PSLF Buyback.
- Consider switching repayment plans now if you're worried about not qualifying for a partial financial hardship in the next year (i.e. income increasing significantly).
- If you’re in training, I’d switch IDR plans now as payments won’t vary much.
I’ve erred in moving back into repayment sooner rather than later to not potentially delay your forgiveness further into the future. There is no guarantee these months in SAVE legal forbearance will count toward PSLF. There’s no guarantee the PSLF Buyback program will be around seven years from now when you're eligible to apply for it. But you could end up paying a higher amount overall on your student loans if you start your payments now. Dr. Jim Dahle has a more positive take on this SAVE legal forbearance and thinks it may count just like it did during COVID. Then, I'd be looking really silly telling people to start making payments now. I'd rather hedge my bets and ensure my forgiveness date is not postponed.
I anticipate some student loan headwinds with the Trump administration now in the White House. But it’s unclear what policies will be implemented or previous plans that could be rolled back. Programs like PSLF are safe for now. For those in SAVE, you need a backup plan and to decide whether you will wait this out or switch now. While this landscape may feel overwhelming, being informed and prepared will go a long way in helping you manage your student loans effectively during this period of change.
Unsure about your next steps or need a second opinion? Schedule an appointment with StudentLoanAdvice.com today!
What do you think? Are you still planning on PSLF? Are you going to switch payment programs now? Were you one of the lucky ones still in PAYE or IBR?
Thank you for this excellent overview of the current state, Andrew.
One nuanced area where I’m not seeing a path forward is for folks like me – 100 qualifying payments into PSLF, moved to SAVE as part of the REPAYE phase out, currently on an attending salary and not eligible for (old) IBR or PAYE due to not meeting the qualifications for partial financial hardship. As it stands, those of us in this situation have no available avenues to make qualifying payments.It also doesn’t feel like a safe bet to assume that buyback will be an option in when I hit 120 eligible months in 2026, given the current environment.
Do you anticipate new IDR avenues/qualifications will emerge for those of us in this situation? I fear that a convenient way to quietly phase out PSLF would be to ensure it is difficult/impossible to qualify for an IDR plan.
I think your path forward will become obvious in the next few months. Sorry you have to deal with the uncertainty in the meantime, but I do think this is going to work out fine for you.
I agree. I work in lending at Georgetown University and considering the PSLF is listed in promissory notes, students are likely to be grandfathered in to IDR programs and PSLF. The gridlock in Congress may also delay many changes to payment plans. I would say if you are eligible at 120 or 240 payments, apply now. Otherwise, it’s probably best to wait and let this play out.
Good luck!
Miriam
MSCO,
You still have ICR. It has not income threshold or partial financial hardship requirement to enroll into it. It’s a high payment (20% of income + a multiplier) and I really despise that plan but you can use that as a last resort. You may be able to go into REPAYE again or some other GOP plan later on. You should run the numbers with ICR. I’d assume it still makes sense but it’s a shockingly high payment.
Andrew SLA
I’m currently in the SAVE plan, paying $0. I have 279 payments made out of 300 for 25 years of payment forgiveness.
Studentaid.gov says if I switch to IBR plan, I would qualify for forgiveness right away as I have made 279 payments out of 240 payments for 20 year forgiveness.
I just applied, a week ago, to switch to IBR. Hopefully, I’ll get approved and get forgiveness right away.
Income is $100k. Balance of loan is $70k. Interest rate is 2.25% fixed.
Any thoughts on this? Is this too good to be true?
Midwest Doc,
Old IBR is 25 years or 300 payments (you’re not eligible for new IBR which is 20 years, it’s only for those who started borrowing student loans after July 1 2014). PAYE is 20 years or 240 payments. You’ll need to double check which plan you’re enrolling into.
In addition, if you reach IDR forgiveness this year it is exempt from taxes (usually known as the tax bomb).
Andrew SLA
Similar situation… but I can’t find anywhere the exact number of payments I have. I refinanced around 2004 but not private and not in SAVE right now. Have been tempted to switch to IDR but for the life of me I can’t find out how many qualifying payments I would have toward the 25 year forgiveness. It’s confusing because some deferment and some forebearance in there. I currently am on a conventional 30 year payback I believe. Fixed rate fixed payment amount at 1.6%. I know for a while I could switch over to IDR and get credit for the past payments. Not sure that’s still an option at this point.
Where did you get that exact number of qualifying payments? Studentloan.gov?
Eye doc,
There is a tracker for 20/25 year forgiveness now listed in your dashboard for studentaid.gov. If it’s not showing you can call studentaid and ask for the forgiveness department to give you an update or inquire as to when your credits will be visible. I’d think you’re still shy of your 25 years and need to look at entering an IDR plan now. There has been a number of waivers retroactively that should give you forgiveness credit for forbearances, deferments and any months you’ve made a payment. I wrote all about this in a previous post.
https://www.whitecoatinvestor.com/idr-waiver-who-qualifies/
Andrew SLA
I hope that works out great for you. Congrats if it does. Any reason you didn’t switch to IBR before?
My IDR payment counter is NOT showing on my dashboard. Studentaid also says they cant see my IDR payment progress. My oldest loan went into repayment in Jan 1999, 26 years ago. I found a site that allows you to see the payment counter API:
Step 1) Log in to studentaid.gov
Step 2) Open a new browser tab and go to https://studentaid.gov/app/api/nslds/payment-counter/summary
According to this, I have 5 months of payments remaining to reach IDR forgiveness. I’m currently in the SAVE plan forbearance, waiting it out with zero payments and zero interest. My question is, when this is resolved, will I be able to enroll in the old IBR plan, make my five payments and get forgiveness? I also notice, when I look at total payments showing in the PSLF payments counter, only one on my payments was counted in 2001. Not sure why eleven payments were not counted. Those uncounted payments would put me well past 25 years repayment.
You seem like a great person to schedule a visit with studentloanadvice.com. I’m not sure you will even need to make 5 more payments.
Thanks for the update Andrew. Any news or thoughts regarding the recent-ish changes for California and Texas, where physicians are not allowed to work directly for hospitals, but do (currently) qualify for PSLF if they work indirectly for non-profit hospitals? Is this going to change?
Hi Russ,
No update on the California & Texas PSLF changes. Haven’t heard anything about this rule being modified back to how it previously was. Will keep an eye on that.
I have personally seen hundreds of clients in CA and TX receive PSLF though.
Andrew SLA
For physicians who haven’t got into those forgiving programs or only make fewer than 30% of the number of qualified payments, maybe for mental health reasons, look really hard at the current work conditions and make the worst predictions on how long you could last on that position, adjust lifestyles to pay off the loans ASAP within 2 to 3 years at most. Mental and life freedom worths a lot more than the forgiven amount. If you are half way or more into the programs and find it overwhelming to navigate due to possible policy changes etc., the bloggers service would be valuable. It would not be a bad idea to prepare for the possibility to pay it off ASAP and cut your loss, especially for physicians with high income potentials. There is no need to be tied up to any workplace to get the forgiven amount if you could afford to pay it off yourself.
April,
PSLF is an all or nothing program. It’s a decision that shouldn’t be taken lightly. But, it can be a very powerful approach to pay down your loans if it makes sense for your career.
Andrew SLA
So if one enrolls in PSLF, do they have to stick to a certain type of employment for qualified payments? Would the individual have the option to pay off the loans faster to forgo the forgiveness? Or as long as enough payments are made, whatever left would be forgiven so long as it is approved?
April,
PSLF has four rules
1.) Qualifying repayment plan (PAYE, ICR, SAVE, IBR)
2.) 120 qualifying payments (1 qualifying pmt is 1 month) while employed at
3.) a non-profit/501c3 working at least
4.) 30 hours p/wk
After a decade of public service if the requirements are met they discharge the outstanding student loan balance tax-free. You can’t receive PSLF in less than a decade.
Andrew SLA
Yes, one has to be employed full time by a non profit or government employer.
Yes, one can pay off their loans any time they want instead of waiting for forgiveness.
Whatever is left after 10 years of qualifying payments is forgiven tax-free. If you overpay, you just get less forgiven. Maybe better to overpay into your brokerage account as a PSLF side fund.
Yes, taking a job that you hate just for PSLF is probably not a great idea for the average doc with the average loan amount. But lots of docs happen to like jobs that just happen to qualify for PSLF and may not even pay less than other jobs. Might as well get the PSLF.
My husband looked into those programs almost 10 years ago during residency, and thought about it. But his instinct of not being tied up to any institutions prompted us to pay off 200k student loans during residency years. It was a lot of effort but in the end the mental freedom worth a lot more. He used to work in non profit organizations that would have been qualified for any of those programs, but quickly these institutions turned toxic during covid times and accelerated his retirement. Can’t imagine what life would have been if you are stuck in a toxic work place and half way or most way into loan forgiven program, either sticking to it or walking away would take a huge mental toll that no amount of money would make it worthwhile.
$200K as a resident is pretty impressive. Lots of moonlighting or a working spouse I guess.
Speaking now from experience as a financial aid director: PSLF (at least outside of the medical profession) tends to encourage abuse. When it was originally written in 2007, the average loan was $19,000 and most of the IDR plans did not exist. IBR was first available in 2009. It was never the intention when originally conceived that the average beneficiary would be receiving nearly six figures of debt cancellation, while paying pennies on the dollar. The original estimate was that borrowers would pay down a significant percentage (e.g. at least half) of what they borrowed prior to receiving cancellation and would use this for one or maybe two degrees needed to go into public service. They did not anticipate the ability to borrow unlimited amounts, for an unlimited number of degrees and receive unlimited forgiveness.
What we see now are students taking on extra and unnecessary degrees (typically online) and extra debt which they fully expect to get forgiven (3rd, 4th, 5th, 6th degrees or credentials, ad infinitum). Most of the borrowing that I see is also for “living expenses” not tuition and fees, which in the online world, means expenses that have nothing to do with the school, going to working adults who are not living on campus. This means students will borrow to do things like remodel their home, pay a business loan, purchase a vehicle, pay off other debts, you name it. It may sound anecdotal, but trust me, this type of abuse is rampant, particularly at non-traditional online programs with open admission policies. Since graduate borrowing is limitless, this is all too easy. All this to say that PSLF, or certainly graduate lending limits and standards (and the lack thereof) certainly needs reining in, at least outside of the medical field.
Without a doubt it is being optimized/maximized/abused/whatever. Congress should write better laws that align with their intentions.
Technically it’s fraud to take out student loans and use them for non educational expenses (room and board count, transportation doesn’t). Doubt it’s prosecuted very often though given the challenges due to the fungibility of money.
I’m not sure why you think medical is different. In fact, when people ask me these days what they should do, I tell them to borrow (at 8-9%) and leave their own money invested until they know if their job will qualify for PSLF.
If I was in Congress, I’d put a limit on forgiveness. Maybe something like $100,000 total. But I’m not and don’t plan to be and will continue to tell docs how the system works. They can optimize/abuse as they see fit.
I allude to the medical field as being different because it’s the one field where an advanced degree is truly required (nobody wants to see a doctor who doesn’t have an MD from a highly respected institution) and actually takes six figure debt to get through. In other fields such as teaching or social work, the requirement for an advanced degree is more questionable, and while costs much less (in tuition and fees) we often see students piling on credentials simply to get a raise, whether it improves their job knowledge or performance at all, and pocket the room and board money which they anticipate will be cancelled. It has really turned the notion of responsible borrowing on its head.
I went to school for RN later in life. Graduated at 63 years old and am in PSLF. I have made 8 years of payments. When seeing the possibility of removing non for profit status for hospitals, I am not sure where that would leave me. I’m assuming transition to another repayment plan. I would hate to start over on another plan after paying for eight years. I guess it’s all in limbo for now.
Yes, it’s in limbo, but most informed people think you’re going to be fine and “grandfathered” in.
I am in a similar boat to MSCO. I am three payments shy of 120 and would have qualified for forgiveness in the forbearance months. I have submitted a buyback request however it’s very tempting to switch to ICR plan and make 3 payments and just be done. My payment amount would be significantly higher for those months, but a small cost compared to the possibility of owing my full loan amount. Not knowing when buyback requests will even be processed combined with an uncertain PSLF/SAVE future make it hard to sit still and wait. Any thoughts?
Don’t do anything in a panic. What you should do will likely become obvious in the next few months.
Thank you for this. I currently have 108 qualifying months with 10 (or more) months I can buyback. On SAVE pause. I recently submitted a buyback request online and just waiting, like many folks posting on r/PSLF who are really concerned. What are your thoughts on how long buyback requests will take to process? Can Trump change the buyback option for those of us ready to do it?
Hi TLG,
I am usually seeing buyback take 2-6 months. Can buyback go away? Yes absolutely. Have I seen it work? Yes. Buyback was not created by Congress. It was created by the executive branch during the Biden admin. There’s no guarantee that program survives in the future or the Trump admin.
In the meantime be prepared to go back into IDR with a different plan like IBR.
Andrew SLA
Similar situation. I’m in SAVE. I have 309 payments. First loans taken out in 1991. Last consolidation was in 2014. Im trying to switch to IBR plan but currently being blocked. What happens to us if we’re part the 300 payments, stuck in SAVE but also cannot get forgiveness on any IDR plans except IBR? They can’t give me a payment because I’m past the 25 year payment period. If I can’t get out of SAVE, it seems I will be stuck in an admin forbearance for the rest of my life since they cannot calculate a payment for someone who is already eligible for forgiveness. They have no legal authority to recalculate payments based on another repayment term. I get the court is saying that for future loans, the IDR (no IBR) plans must set the payment so that the loan is paid in full after the 20 or 25 years. I get it. But I don’t get how they will handle my situation since I’m grandfathered in but blocked from forgiveness due to injunction. Let’s assume that SAVE is forever blocked and forgiveness on all other non IBR plans is also struck down. What will they do with me and my one consolidation loan for over $200K? StudentAid shows my correct payment counts and also shows all 309 as “qualifying” for IDR forgiveness. When using loan simulator it shows I’m already past forgiveness with a -9 payments. It shows forgiveness eligible Feb 2025. If I switch to any other plan, in the simulator, the counts all change to ZERO and it shows that I’d need to make 240 payments and that I will eligible for forgiveness in those any of those other plans, PAYE, ICR and IBR in Feb 2045. So this is a mess. Any thoughts? I’ve already contacted every party involved at least 5 times, including Ombudsman and CFPB. I’m thinking about my US rep or senator at this point.
Hi Brian,
Why don’t you apply for ICR. ICR doesn’t require a partial financial hardship. They won’t start you over by switching plans. They carry over your previous payments when you switch IDR plans. If you can’t figure out how to switch you may need to wait until the SAVE legal injunction is over.
Andrew SLA
Hi. Did you mean IBR? I have a financial hardship so I qualify for IBR. Why would I want to enroll in ICR? The issue isn’t that I can’t figure out how to switch plans. My servicer is blocking me from doing so. Their logic is that since I already have more than 300 payments, any plan they put me in would force them to calculate a payment. They cannot do so because I’ve exceeded the full term of repayment on any plan so my payment is just zero. But I don’t know what legal basis they have for blocking me from switching out of SAVE into IBR. It makes no logical sense. Even if I wait until the case is settled, what happens to those of us who already have more than 300 payments? If they get rid of SAVE and all forgiveness under all other IDR plans, what is left for me to do? How do I get forgiveness? If I can’t, how do they calculate a payment for someone who is already past 300 payments? It’s a catch 22.
Brian,
I would contact the student loan ombudsman and let them know about your dilemma. If they can’t do anything at this point, you may have to wait for the lawsuit on SAVE to finalize before being switched plans and receiving forgiveness.
Andrew SLA
I was at 118 payments when the forbearance went in effect in Aug. 2024. I applied for buyback for Aug. and Sept. and I’m currently still waiting on a response. I’m getting anxious that they may put a halt to PSLF and I may lose the opportunity for forgiveness. I have filed a complaint due to the length of processing time being past the expected time frame of 45 business days. I’m also waiting on that response. Any feedback would be appreciated. TIA!
Hi Rachel Walker,
I’d contact FSA. They have a loan forgiveness hotline now. I’m honestly not suprised you’ve been waiting six months, but that’s longer than i’ve seen it take for a couple of clients. I would be prepared to go back into repayment with PAYE or IBR in case buyback does not work. Good luck.
Andrew SLA
The IBR application processing has been haulted. Would I be able to change to the standard repayment plan and pay the remaining 2 months of the 120 and be eligible for forgiveness?
Rachel,
Standard repayment is no good at this point. You can apply for IBR. While the online application is down there is a workaround. You just need to fill out a paper IDR application and upload it to your servicer website.
Andrew SLA
I missed the deadline to apply for pslf because I have FFELP loans and my loan amount on the federal website was incorrect. By the time it is fixed in the website after many phone calls and emails, the deadline passed. I have made close to 240 payments (20 years) and would have had my loans forgiven since my employer qualifies as well. Is it too late now to consolidate to direct loans and apply for pslf?
I’m not sure what deadline you’re referring to exactly but I bet Andrew, the author of this post knows and will respond to you in the next day or two. I think you’re referring to the subjects covered in these posts though:
https://www.whitecoatinvestor.com/pslf-changes-limited-waiver-benefit-ffel-borrowers/
https://www.whitecoatinvestor.com/changes-to-public-service-loan-forgiveness/
Thank you so much. It was the limited waiver deadline to count the payments made through FFEL program. Would appreciate any advice from Andrew.
You can always buy advice from him too.
https://studentloanadvice.com/
Hi CL,
The deadline to consolidate your loans for the one-time account adjustment (aka IDR Waiver) was June 30, 2024. Now that the deadline has passed, it’s highly unlikely you would be able to have your FFEL loans forgiven via PSLF. Reason being, they require a direct federal consolidation now to get them from FFEL to direct. By consolidating your FFEL loans to direct, it will erase your prior payment history. Meaning, you’ll need another decade of repayment in an IDR plan. Under the IDR waiver when you consolidated your FFEL loans, it allowed you to carry over previous payment history. This provided an avenue for many borrowers to have their loans forgiven immediately.
If you did try to apply prior to the deadline you could file a complaint with the student loan ombudsman or even consult a student loan attorney to get a second opinion.
As far as other forgiveness programs, you loans can be forgiven if you have 25 years of payments in the IBR plan.
Andrew SLA
Thank you so much Andrew. Appreciate it
Hi Andrew,
I just checked the federal student loan website. It says that if you consolidate your FFEL loans after September 1, 2024 and the dates of your employment are prior to the consolidation, a weighted average will be applied to determine your qualifying payments from the loans included in your consolidation loan. This sounds like some of my prior payments through FFEL may count towards PSLF?
Hi CL,
That’s my understanding for Direct not FFEL. Here’s guidance from the dept of education page on this.
I also re-read the newest direct federal consolidation application and is does explicitly mention Direct Loans would carry over payments post consolidation in a weighted average fashion for PSLF. But it does not explicitly state FFEL loans would carry over payments made prior to direct federal consolidation.
If you have a source that says differently, let us know.
Andrew SLA
This is the response I received when I filed a complaint on the federal student loan website:
Thank you for contacting the U.S. Department of Education’s office of Federal Student Aid (FSA). In reviewing your complaint, it appears you are seeking additional credit through the Payment Count Adjustment towards income-driven repayment (IDR) and Public Service Loan Forgiveness (PSLF). We will track this complaint until your request is reviewed. Your FSA is currently in the process of automatically applying Payment Count Adjustment credit across certain borrower accounts. Borrowers will automatically receive payment credit on their loans for the following periods:
– any months in a repayment status, regardless of the payments made, loan type, or repayment plan;
– 12 or more months of consecutive forbearance and/or 36 or more months of cumulative forbearance;
– any months spent in economic hardship or military deferments in 2013 or later;
– any months spent in any deferment (with the exception of in-school deferment) prior to 2013; and
– any time in repayment (or deferment or forbearance, if applicable) on earlier loans before consolidation of those loans into a consolidation loan.
After the automatic adjustments are completed in 2024, the FSA Ombudsman Office will begin the
process of reviewing requests for manual adjustments. Please note that manual account reviews cannot be conducted before the automatic account adjustments are completed. However, we will keep your complaint open until we can complete the manual review. That means your complaint may remain open for several months.
You can learn more about the IDR Account Adjustment at StudentAid.gov/announcements-events/idr-account-adjustment.
Keep in mind that the federal payment pause has ended. You should plan to resume making payments, even if you are still waiting to receive credit under the Payment Count Adjustment. After the Payment Count Adjustment is applied to your loans, you will receive a refund for any payments made beyond what is needed for loan forgiveness.
It’s unclear what this manual adjustment means. I’m debating if I should consolidate now or wait for more information.
This doesn’t list FFEL anywhere. It’s simply a boiler plate response listing information on the One-Time Account Adjustment waiver. To qualify for the waiver, you had to apply for consolidation by June 30th 2024. All of the criteria it lists is applicable to Direct Federal Student loans.
Thank you for clarifying Andrew
I am graduating medical school and beginning residency this June. I have ~$200,000 in federal student loans. I am planning on a 3 yr residency and 3 yr fellowship. I am planning on pursuing PSLF. Given the current state of SAVE … should I consolidate loans and apply for PAYE now? What is my best option? Thank you for the help.
It’s in flux and seems to change week to week. You can’t do anything until you graduate so let’s see if we can answer that question then. If you want advice today, consider booking a consult at StudentLoanAdvice.com.