Public Service Loan Forgiveness

*Some permanent, beneficial changes to PSLF became effective July 1, 2023.  We have noted them below.   We have also maintained the information about the temporary PSLF waiver however that waiver ended October 31, 2022.

If you are an employer or association looking to provide PSLF education and support to your constituency please reach us through our contact page.  We offer robust PSLF webinars as well as more extensive PSLF support programs such as our PSLF Peace of Mind program. 

Public Service Loan Forgiveness (PSLF) tends to be the most commonly known federal student loan forgiveness program. Some also call it the “Obama Forgiveness Program” although you should note that nobody with any real knowledge of the student loan programs will ever call it that. In fact, this misnomer is one of the clues we use to identify potential student loan scams. You should too.

On July 5th, 2023 the Department of Education updated their PSLF page and added some extensive FAQ.

Basic Eligibility

To be eligible to get the balance of your loan forgiven under PSLF, the borrower will need to make 120 payments under an eligible repayment plan, on eligible loans, while working full time for an eligible employer. It’s important to note that all three of these things have to happen at the same time. Once you complete the 120 payments, the balance of your loans are forgiven, tax free.  Note that the one time IDR adjustment could get you credit for prior payments that don’t meet all of these criteria.

Although the three requirements sound simple, there are some additional details that can trip borrowers up.  We make sure to cover all of those below.   And don’t worry if you don’t have the right kind of federal loans or aren’t on the right repayment plan, we’ll tell you what you can do to get on the path to forgiveness.

One last thing – PSLF isn’t for everyone.  The name of the game is paying the least amount over time.  For some people that means pursuing a program like PSLF, but for others that might mean paying your loans off aggressively.  PSLF was never intended for all borrowers.

What is an Eligible Loan for PSLF Purposes?

Only Federal Direct Loans are eligible for PSLF.  These can be Direct Stafford, Direct Graduate Plus, Direct Parent Plus and Direct Consolidation loans.

The following loans can be made into Direct Loans and become eligible for PSLF by consolidating through the Direct Loan program at www.studentaid.gov :

• Federal Family Education Loan (FFEL) Program Loans including
  • Subsidized and Unsubsidized Stafford loans
  • Parent Plus Loans
  • Graduate Plus loans
  • FFEL Consolidation Loans
  • Supplemental Loans for Students (SLS)
• Federal Perkins Loans
• Federal Nursing Loans
• Health Education Assistance Loans

If you must consolidate to gain access to PSLF, do so as soon as possible. Any payments made prior to consolidation on a FFEL or Perkins loan will not count towards PSLF and cannot be made to count. Once you consolidate, you will, effective July 1, 2023, be given the weighted average of the underlying loan PSLF counts on underlying Direct loans unless you consolidate prior to April 30, 2024.  See the link for the one time IDR adjustment for more information about this temporary exception.

If you have a mix of Direct and some other type of federal loan, such as FFEL, Perkins or HEAL, consolidate only your non-Direct loans if you are consolidating after December, 2023. The Direct loans are already eligible for PSLF and consolidating them with the ones that aren’t will mean reducing any PSLF eligible payments you may already have on the Direct Loans.

Remember, the name of the game is to pay the least amount over time. Sometimes this means pursuing forgiveness, and sometimes it means aggressively repaying the loans in full. If you have been paying your loans for some time,  or have a fairly decent income compared to your loan balance, you should use this calculator to determine if pursuing PSLF is the smartest strategy for you before going through the consolidation process.  You can also use the loan simulator here.

Private loans, state loans, institutional loans and other higher education financing tools are never eligible for PSLF. Defaulted Direct Loans are also not eligible for PSLF, but can be brought out of default.

For Those with Parent Plus Loans

 Although Direct Parent Plus Loans are technically eligible for PSLF if the parent borrower is engaged in eligible employment, you cannot truly benefit from PSLF unless you convert them to a Federal Direct Consolidation Loan. See the section on payments for details.

If you aren’t sure what kind of loans you have, contact your loan holder or go to www.studentaid.gov

What Is An Eligible Payment?

For PSLF purposes, an eligible payment is one made after October 1, 2007, on time (no later than 15 days after the due date), on an eligible loan (see above for a list of eligible loans), while working full time for an eligible employer (see below for eligible employer definitions) under one of the following repayment plans:

• Standard 10 year repayment plan
• Income based repayment
• Income contingent repayment
• Pay As You Earn (PAYE)
• Revised Pay as You Earn (REPAYE)/SAVE

You can learn more about each of these plans here.

When you are on an income-driven repayment plan, you must certify your income once a year. The servicer will be in contact with you when you need to recertify. (Note that IDR recertification dates are postponed during the COVID waiver period.  Borrowers will be notified by their servicer when they are required to recertify) If you have a drop in income, you can ask your servicer to reset your payment based on your new income without waiting for your recertification date.  The servicer will tell you what kind of documents are required to verify your new income.

There are a Few Other Things to Know to Ensure your PSLF Payment is Eligible

You do not need to be under the same plan for all 120 payments, but only payment made under the 10-year standard plan or an IDR will be counted.

Payments don’t need to be consecutive to count.  The only thing that will wipe out prior eligible payments is loan consolidation.  Consolidation will NOT reset the count if submitted before December 31, 2023 due to the temporary waiver and one time IDR adjustment.  Consolidation after that will result in a weighted average of the counts from the underlying loans.  So if you consolidated one $20K loan with a PSLF count of 50 and one $20K with a count of 100 the consolidation would have a count of 75.  But if you consolidated a $100K loan with a count of 50 with $20K with a count of 100 your consolidation would have a count around 60 because they are doing a weighted average.

Payments made under a standard plan that is longer than 10 years, such as what is generally given to consolidation loans, do not count towards PSLF

Parent Plus loans are only eligible for the income contingent repayment (ICR) plan and only if they are consolidated under the Direct Loan program. Parent Plus borrowers pursuing PSLF should consolidate as soon as possible and apply for ICR right away to take advantage of PSLF.  Note that Parent Plus loans, even if consolidated, were not eligible for the October 6th, waivers unless they are consolidated with non-Parent PLUS loans such as Stafford or Graduate PLUS that were taken out for the parent borrowers own schooling.  They are however eligible for the one time IDR adjustment.

Lump sum payments  count up to 12 payments or until the borrowers next IDR recertification date, whichever comes first.  Only lump sum payments made when the loan is under the PSLF servicer will be treated this way.  Note that this does not mean borrowers can achieve forgiveness any sooner with this new treatment of lump sum payments as you must still submit proof of eligible employment covering the months these lump sum payments were credited to.  These payments cannot be counted for delinquent months as payments must still be made on time to count for PSLF.

It is possible to have a zero dollar payment under the income driven plans. Zero dollar payments that are due under these plans do count towards PSLF. Not being due for a payment because you are in forbearance or deferment or in school does not count towards PSLF unless it’s one of the following (effective July 1, 2023:

• Cancer treatment deferment
• Economic hardship deferment
• Military service deferment
• Post-active-duty student deferment
• AmeriCorps forbearance
• National Guard Duty forbearance
• Department of Defense Student Loan Repayment Program forbearance
• Administrative forbearance or mandatory administrative forbearance

Note you still have to meet the PSLF employment requirements during these deferment periods for them to count.

Other deferments and forbearances not on the above list may be subject to a “hold harmless” period that would allow the borrower to “buy back” those periods.  We are still waiting for additional guidance for this provision.  Note that in no case will periods where the borrower was not working eligible employment count for pslf.  The ED has also clarified that you will not be able to “buy back” periods of deferments etc that occurred prior to a consolidation.  The hold harmless is not available yet and there is no word as to when it will be at this point.

During COVID-19, payment waivers were applied to all federally held federal loans.  This meant that no payments were due on any Direct Loans.  This period does count for PSLF purposes if the borrower submits proof of eligible employment during this time.  There is no value to making payments during the COVID waiver period if you are pursuing PSLF.  If you have you should call and request a refund.

Payments made on a defaulted loan do not count towards PSLF. If you rehabilitate a defaulted loan to get out of default, the payments made after loan rehabilitation will count.

It does not matter who is making the payments for them to count for PSLF purposes.

Payments made under a graduated or extended repayment plan generally do not count towards PSLF, unless that payment is in an amount equal to or larger than what the payment would be under a 10 year standard plan. This is a rare occurrence.  These will count with the one time IDR adjustment.

Note that while 10 year standard plan payments do count towards PSLF, if you are under that plan, after you make the full 120 payments the loan will be paid in full with nothing to forgive.

It does not matter who is making the payments for them to count for PSLF purposes.

What is Eligible Employment?

Eligible employment depends on who you are working for, not what your job is. An eligible employer is one that is US based and meets one of the following criteria:

• Is a government employer. This includes:
  • Federal
  • State
  • City
  • Local
• Is a Tribal college or university
• Is a 501(c)(3) non-profit
• Is a 501(a) as long as the activities that qualify the organization for this status are unrelated to religious instruction, worship services, or any form of proselytizing

Serving full time for AmeriCorps or the Peace Corps is considered eligible employment.  So is serving full time in the military as that is a government employer.

There are other types of non-profits that also count as eligible employers for PSLF purposes.  Those are employers whose primary function is one of the following:

• Emergency management
• Military service: service on behalf of the U.S. armed forces or the National Guard
• Public safety
• Law enforcement: crime prevention, control or reduction of crime, or the enforcement of criminal law
• Early childhood education: includes licensed or regulated childcare, Head Start, and state-funded prekindergarten
• Public service for individuals with disabilities and the elderly
• Public health: includes nurses, nurse practitioners, nurses in a clinical setting, and full-time professionals engaged in health care practitioner occupations and health support occupations, as such terms are defined by the Bureau of Labor Statistics
• Public education: includes services that provide educational enrichment or support directly to students or their families in a school or a school-like setting
• Public library services
• School library or other school-based services

Here are some online lists that may help you determine if your employer fits these criteria. This list is most government agencies and departments. This list is the IRS database of non-profit organizations. Note that for this second list, you’ll also need to determine if the employer is a 501(c)(3) or other type of non-profit. If it’s the latter, you’ll need to review the activities above to determine if it qualifies.

You must be full time for the employment to qualify. Full time is defined as whatever your employer defines it as, or 30 hours per week, whichever is greater. You can work part time for two eligible employers as long as the hours add up to at least 30 hours per week.

For non-tenure track college employees (effective 11/1/2022) – the equivalent of 30 hours per week determined by multiplying each credit or contact hour by 3.35

Note that hours worked at religious activities used to be excluded from hours worked for PSLF purposes, but this is no longer the case. If you submitted proof of employment in the past that was denied due to the exclusion of hours spent on religious activities you should resubmit proof of employment for those time periods.

You do not need to work for the same employer for the full qualifying time for PSLF. Your eligible employment also does not need to be consecutive. So if you work in eligible employment and make eligible payments during that time, then leave for the private sector, or to go to school, etc, and then return to qualifying employment, those prior payments you made will still count towards the 120 needed for PSLF.

For the vast majority of borrowers, the employer listed on your W-2 is who is considered your actual employer.  Most contractors, unless the contractor themselves is an eligible employer, won’t be considered engaged in eligible employment.  There are some, rare, exceptions where a third party is issuing the employees paycheck despite the employee actually working for an eligible employer.  To be considered eligible, the employer must have hiring and firing authority over the employee.

Effective July 1, 2023, borrowers who work as contractors for qualifying employers can have that employment count only if state law prohibits the employer from hiring them directly.  So far, that only applies to doctors working at non-profit hospitals in California and Texas.

Only the employment of the borrower on the loan counts for PSLF purposes. So for Parent Plus loans, it must be the borrower of the loan, rather than the student or spouse, who is working in qualified employment, regardless of who is actually making the payments. The borrower on the loan cannot be changed.

**Temporary PSLF Waiver (now expired)

On October 6, 2021, the Department of Education announced several, significant, but temporary changes to PSLF eligibility.  Below are the changes.  We have created an FAQ document that you can find here.  Read all the things and still confused as to how to apply?  See this step by step infographic.

• Payments made under the Federal Family Education Loan program or Perkins will count as long as the loan is consolidated into the Direct Loan program (via www.studentaid.gov) and a PSLF form has been submitted prior to 10/31/2022.  This does not include Parent Plus loans unless those Parent Plus loans are consolidated with non-Parent Plus loans. (Parent Plus remain eligible for traditional PSLF and the TEPSLF)  See the FAQ for more details.
• Payments made under any repayment plan on or before 10/21/2021 will count as long as the borrower has a Direct Loan and has filed at least one approved PSLF form as of October 31, 2022.  This includes the alternative repayment plan.
• You do not need to submit proof of payment.  The Department of Education will be reviewing data they already have.  While we are using the term “payments made” for clarity reasons, in reality the ED is only looking at months the loan was in a repayment status, not whether you actually paid or how much you paid or when.
• Payments made while in default will continue not to count
• Payments made on or before 10/21/2021 that were less than what was due or a few days late will be counted as long as the borrower was working in eligible employment at the time, has a Direct Loan and has filed at least one approved PSLF form as of October 31, 2022.  This includes payments made under the FFEL or Perkins programs.  The feds are reviewing months in repayment status, nothing else.
• Borrowers with periods of active duty military service, which can count as eligible employment for PSLF purposes, will have those months count even if they were in military deferment or forbearance, but not until later in 2022.  This is a permanent change and not part of the temporary waiver.
• Months in an administrative forbearance, other forbearance, grace, in-school or deferment status will not count (other than military deferment or forbearance)
• Beginning next year, most federal workers, including those serving full time in the military, will have their employment automatically certified.  This is a permanent change and not part of the waiver
• None of these changes apply to loans that have been paid in full
• These changes do apply to Stafford and Graduate PLUS loans as well as consolidation loans
• The Department of Education will also be reviewing ALL denied PSLF applications in the coming months
  • This is a separate process from the initial review for eligible months in repayment
• If you already have all Direct Loans you likely do not need to consolidate to take advantage of these changes.  See the FAQ for more information
• If you have all Direct Loans and have already submitted at least one approved employment certification form you do not need to take any actions – the Department of Education will do the update automatically in the next few months
• If you have FFEL or Perkins loans you need to consolidate prior to 10/31/22 and submit a complete PSLF form by that date to take advantage of this – no exceptions.
• Periods of eligible employment used for Teacher Loan Forgiveness will be counted under the PSLF waivers
• Loans consolidated more than once will receive credit for all months in repayment, regardless of the number of times the loan was consolidated.  See the FAQ document for examples
• Consolidation will NOT reset the PSLF count, but only if done before the end of April, 2024

Updates from October 25, 2022 Announcement

The Department of Education (ED) issued a press release and fact sheet about another upcoming waiver that the industry is calling the Income Driven Plan (IDR) Waiver.  This waiver can also result in providing additional credits for those pursuing PSLF.  You can find the announcement here

There is also more information on our repayment plan page.

What the IDR Waiver Does

The IDR waiver gives credit toward the 20/25 years needed for forgiveness under the IDR Plans for:

 

• Any month in which a borrower was in a repayment status, regardless of whether payments were partial or late, the loan type, or the repayment plan;

 

• Any month in which loans were in an eligible repayment, deferment, or forbearance status prior to consolidation;

 

• Months while a borrower spent at least 12 months of consecutive forbearance;

 

• Months while a borrower spent at least 36 cumulative months in forbearance; and

 

• Any month spent in deferment (exception for in-school deferment) prior to 2013.

 

 

Parent Plus Borrowers

Parent Plus loans were included in the IDR adjustment, which means that such loans can get credit for otherwise ineligible past payments per the below.

Dovetail with PSLF

Borrowers who have months converted to IDR months under this adjustment can have those months also count for PSLF if they provide proof they were working eligible employment at the time. It is unclear how consolidation loans containing PP loans will be treated.

Deadline

Under this, most of the PSLF waiver has effectively been extended. Based on the language however, we still STRONGLY encourage borrowers who haven’t already done so to submit proof of at least one period of eligible employment by October 31st. Or generate a PSLF form via the PSLF tool that is eventually approved. Or has a PSLF form signed by a PSLF eligible employer that is eventually approved.

Those that do not submit proof of eligible employment by October 31st will still get credit under the IDR waiver (assuming they have eligible loans and if they don’t who consolidate by May 1, 2023) and credit for corresponding periods of eligible employment once they submit proof of that employment. They will not be able to double dip for teacher loan forgiveness and will still have to be working for eligible employment at the time they are reviewed for forgiveness as is required under traditional PSLF rules.

How to Apply for PSLF

There are a few things you need to do to apply for PSLF. First, you need to ensure the loan holder has proof that you have worked for a qualifying employer during the time you made your 120 eligible payments. You do that by submitting the PSLF Certification and Application to the address listed on the form. We strongly recommend you do this on an annual basis and keep copies in your files.  Note that as of Fall of 2020, the PSLF ECF and Forgiveness application are contained all within the same form. It is solely your responsibility to prove your eligible employment so if you wait to submit ten years worth of forms, you could run into a situation where your prior employer is out of business or no longer has records of your employment. You CAN submit all ten years of employment forms at the same time, we just recommend against it for the reasons previously stated.

Once your loans are being held by MOHELA, you can upload future EFC forms here. You can also find out how many qualifying payments you’ve made at that link by logging in and clicking on loan details.  In the fall of 2020, the ED released a new PSLF Help Tool that can be used to help determine eligibility and complete the required forms.  The ED has linked this tool to a database that contains all previously eligible employers.  If you employer appears on the tool, but the address is different than the one you work at, allow the tool to populate the form without changes.  The address is not relevant to your eligibility and allowing the tool to pre-populate your form will likely significantly hasten the approval of your application.

The first time you submit the ECF, your loans will be transferred to MOHELA. Nothing will change about your loan terms, only who you make payments to and who you communicate with. They will also begin counting your eligible payments for you at that point.

After you’ve made your 120th payment, you no longer have to submit an application for forgiveness, it will be processed automatically.  Note however that you do need to be working PSLF eligible employment at the time you submit that final application that gets you to the 120 payments.  You no longer need to be working for qualifying employment at the time of actual forgiveness, effective July 1, 2023.

On your request,  they will place your loans in forbearance while they review it. This can take up to 90 days. If you make more than the required 120 payments they will return the excess to you as long as the extra payments weren’t all made before a consolidation. This can take additional time.

The amount forgiven under PSLF is not taxed.

The Department of Education has published some Frequently Asked Questions here. Most of that information is covered above, but we wanted to ensure you had a back-up source in case something wasn’t clear.

Upcoming Permanent PSLF Changes

 

The announcement made by the Department of Education on October 25th, 2022 also mentioned some of what’s coming in the final regulations regarding PSLF. Those are due out next week.

 

One BIG question still outstanding is whether these changes will be retroactive or prospective. Meaning will any of it apply to months prior to July 1, 2023 or months prior to the final regulation publication date of next week? Or will some or all of it only be for months after one of those dates? We don’t know and won’t know until those regulations come out.

 

Borrowers with all Direct Loans who consolidate after the effective date will get a weighted average of PSLF payments if the loans they are consolidating have different counts. Under traditional rules consolidating means resetting to zero.

 

Periods of military, cancer treatment, economic hardship deferments will count assuming the borrower is working eligible employment at the time. So will AmeriCorps, national guard, department of defense, administrative and mandatory forbearances. Voluntary forbearance taken after the IDR adjustment will NOT count!!!!

 

Late and lump sum payments will count.

 

Full time will mean at least 30 hours per week regardless of whether your employer considers you full time or not (and again – we don’t know if this is retroactive or not and won’t until next week most likely)

 

Adjunct professors will be given credit for 3.35 work hours for every credit hour taught – they still need at least 30 hours per week to qualify for pslf

 

Contractors will count – but ONLY if they are providing a service that state law doesn’t allow an employee of the actual organization to perform. This is going to benefit a very small number of borrowers.

 

Borrowers will be able to make payments later for forbearance and deferment periods where they were working eligible employment.

 

As mentioned, once additional guidance is received, we will update this page.

Temporary Expanded Public Service Loan Forgiveness (TEPSLF)

If you have been making payments under a plan that is ineligible for Public Service Loan Forgiveness (PSLF), you may still have hope.

Congress included a provision in the Consolidated Appropriations Act of 2018 that would allow payments made on a Direct Loan under a graduated, extended or standard consolidation repayment plan to potentially count towards PSLF.  To qualify these payments, the borrower must complete the following steps:

• Make 120 qualifying payments while working for a qualifying employer as outlined above
  • Some or all of these payments may have been made under a graduated, extended or standard consolidation repayment plan
  • The payment you made 12 months prior to applying for the TEPSLF, as well as the last payment made, must have been at least as much as you would have paid under an income driven repayment plan.  See details below.
• Submit the PSLF/TEPSLF combined application.

The Last 12 Payments Under the TEPSLF

The payment you make 12 months prior to applying for the TEPSLF, as well as the final payment you make, must be at least as much as you would have paid under an income driven plan.  Just those two payments. You do not need to be on an IDR plan or be billed this amount, you just need to make two payments of at least this amount – one payment of this amount 12 months before the final payment and then one final payment of the same amount 11 months later. The 10 payments in between should be in the amount you are billed those 10 months.

If the difference between your current payment and your income driven plan payment is minimal, it’s easier just to get on an income driven plan for your final 12 months before you apply for forgiveness under the TEPSLF.  You can do this through your loan servicer. If the IDR amount is much higher than your current payment, just make the two payments – the one 12 months before and the final amount in the necessary amount (at least as much as the IDR payment amount).

To determine what your IDR amount would be, we suggest getting 3 estimates of the necessary amount. Use the Department of Education’s repayment estimator at www.studentaid.gov, our calculator here   https://studentloanplans.app, and ask your servicer for the amount.  To be on the safe side, we strongly recommended you round up to the next dollar from the highest amount given.  If you have Parent Plus loans you must use the amount shown under the income contingent repayment plan.  If you don’t have Parent Plus, you may use  the IDR payment amount for any of these IDR repayments plans: IBR (Income Based Repayment), PAYE (Pay as You Earn), REPAYE (Revised Pay as You Earn), or ICR (income contingent repayment).

It’s important to note that Congress allotted a finite amount of funds for this program.  These funds will be allotted on a first come, first serve basis.  Once these funds are used up, this fix will no longer be available.  For that reason, we strongly recommend that any borrower in this situation switch to an income driven plan as soon as possible.

Payments made to a Federal Family Education Loan (FFEL) do not qualify under this provision, nor can ever qualify for PSLF.  There is no remedy for this currently, nor is there expected to be one.  If you have FFEL loans, you can consolidate under the Direct Loan program and start the PSLF process from scratch.  It is strongly recommended you determine if you would pay less over time by taking this step, or by simply paying the remainder of your loans off aggressively.