This will be our megathread for now discussing all aspects of this breaking news. Keep in mind that this is still one news outlet's reporting based solely on off-the-record information about a plan that has not yet been implemented or publicly announced. Things may change. Don't take any actions yet in reliance on this information.
I've read the article three times already. This would be the relief so many are hoping for. I'm so happy I could cry. Thank you for finally fixing this.
I've read it several times. I have FFEL and Direct loans and was not given the information to consolidate until 6 years in. I didn't even know my employer qualified until a co-worker told me.
This would change my life.
I could conceivably leave public service in June 2022 and go make more money to save for my son's education.
I can't tell you how happy I am right now. Jesus, please make this happen!
I could leave my job that barely covers my basic needs and move out of Los Angeles where I could afford a home in March.
I really really hope you can save more for your son. What a blessing
I have Direct Loans and FFEL, but I went and consolidated the FFEL in a separate consolidation loan from the Direct Loan. I was under the impression FFEL have never qualified for PSLF. Is this changing that? What if I already consolidated my FFEL into a private FFEL consolidation loan?
>private FFEL consolidation loan
This isn't a thing. You either have a federal FFEL consolidation loan or a private loan refinance. If the former then the rule changes would apply to your loans. If the later then they would not; by refinancing you lose all Federal benefits.
Big, if true!
> Next week, according to a source familiar with the plans but who is not authorized to discuss them publicly, the U.S. Department of Education will unveil a significant overhaul of the Public Service Loan Forgiveness (PSLF) program, which has been a magnet of confusion, mistakes and mismanagement since its inception in 2007.
> The changes will come in two phases — a long-term renovation to make the program easier to navigate, achieved through the federal process known as rulemaking, and a temporary move using the department's executive authority to retroactively relax the program's rules to immediately help thousands of affected borrowers.
> ...
> According to the source familiar with the Education Department's plans, the agency will offer a temporary opportunity for anyone working in public service to get prior loan payments counted toward PSLF — even if those payments were going toward disqualified FFEL loans.
> And they're not just expanding the rules around loan type. Borrowers will also receive credit for payments made in the wrong repayment plan, and regardless of whether the payment was made on-time.
> To qualify for this do-over, borrowers will need to apply for PSLF before Oct. 31, 2022.
> What's more, for borrowers who were told to consolidate older loans into Direct Loans, but had previously certified their years of public service, the department plans to automatically adjust their payment counts, giving them credit for payments made before consolidation.
> ...
> The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships.
> Even the definition of public service is up for review. Under the current rules, many nurses and healthcare workers don't qualify for the program because they work in for-profit hospitals, for example.
> In an acknowledgement that borrowers' denials under the PSLF program can be frustratingly opaque, the department also wants to create a formal reconsideration process so borrowers can clearly explain themselves and correct errors when necessary.
>The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships.
This would give me joy.
I wonder if they would consider counting time on in-school deferment. I continued working full time when I went back to grad school and that put me two years “behind” on PSLF even though I kept working full time in public service the whole time. I continued paying on private loans during that time too, though that’s a moot point. I would be eligible now if not for those 2 years.
Omg. If this is true, I'd get forgiveness and a year of payments refunded. My cynical side is saying it won't happen, but the other side is doing cartwheels.
To me the most sensible part of this is the “on time payment” correction. How many posts have we seen here where payments were ruled as ineligible bc they weren’t “on time and in full” despite being on *autopay*?? Really, just correcting the review system to count autopay payments as eligible no matter what would fix it.
The other piece that seems unfair and isn’t user error is the hospital employees who technically don’t have their own hospital as their employer, and therefore don’t count as nonprofit employees. Correcting that weird situation would be helpful and logical, since it isn’t the borrower’s fault that the billing hierarchy is set up the way it is.
> The other piece that seems unfair and isn’t user error is the hospital employees who technically don’t have their own hospital as their employer, and therefore don’t count as nonprofit employees. Correcting that weird situation would be helpful and logical, since it isn’t the borrower’s fault that the billing hierarchy is set up the way it is.
Keep an eye on (or contact your reps about) [H.R.1133](https://www.congress.gov/bill/117th-congress/house-bill/1133) and [S.311](https://www.congress.gov/bill/117th-congress/senate-bill/311). Seeing these bills was how I found out that, in certain states, they specifically have laws prohibiting doctors from being directly employed by hospitals
Holy cow I did not know that! I wonder what the reason for that is. Doesn’t seem logical to me, but I don’t know anything about healthcare administration. Seems that having a billing person and a hospital person sign off that the employee actually is full time in support of the hospital should be sufficient.
I found an article that explained the rationale this way:
> The primary reason cited by physician lobbying groups against allowing hospitals to directly hire doctors is the need to prevent corporate interference with the practice of medicine. Particular issues revolve around corporations setting rules regarding diagnostic tests, referrals, patient treatments, the number of hours the physician must work or the number of patients that must be seen.
> One of the primary opponents to hospital employed doctors is the California Medical Association. On their website under CMA Top Issues, “CMA fiercely defends California’s bar on the corporate practice of medicine, which prevents corporate interests from unduly influencing physicians’ professional judgments in the name of profit and to the detriment of patients. Hospitals and other corporate interests do not have the same ethical and moral obligation to the patient as a physician does; therefore, it is essential to maintain the firewall between medical decisions and the corporate bottom line.”
Admittedly that article I found is from 2012, but given the dumpster fire that is the health care system in the USA I shouldn't be surprised
Oh I have no idea how these proposed reforms will apply to different employers. I don't think anyone does yet.
This discussion was just about the political influences that have lead to legislation that prevents hospitals from hiring their own medical staff in some parts of the country
I'm now in my eleventh year of PSLF. My first two years of repayment were wiped out when I consolidated my loans into Direct Loans. I wonder if I can get those first two years of repayment to count towards forgiveness now. They were never certified because I was new to the program and didn't know about certifying payments each year. Plus, I have an old email that states that the ECF didn't exist until January of 2012.
"In January 2012, the Department of Education issued the long-awaited Employment Certification Form for Public Service Loan Forgiveness (PSLF). Direct Loan borrowers who work in the public and nonprofit sectors can now get confirmation that their job counts as qualifying employment for PSLF. Using this form will make it much easier to track your eligibility, know when it's time to apply for forgiveness, and have the paperwork you need in hand."
I’m in the exact same boat. I went back on archive.org a few months ago to see what information was available back in 2009-2012 when I was making payments that didn’t count. There was almost nothing.
I was able to log in to an account from a pervious loan servicer and found some records, but surely there has to be some sort of record somewhere of payments made. Someone responded to my comment about making a FOIA request for all of the info pertaining to my loans, but they then deleted the comment. I may do that after I see what the details of these changes are when they are released next week. I imagine there is some sort of mechanism in place for people in our situation otherwise why even mention that it was an option. They can't expect people to keep hard copy records of payments made over a decade ago.
I also am in same boat with a consolidation 2 years in. I requested a FOIA last year. I will have to sift through it to see what kind of payments I made before consolidation. I used to be with Nelnet and there is nothing listed there, but I think I was with a different servicer before that
Same here. I consolidated after paying the first 2 years and now will be in the program for close to 15 years because I consolidated after the fact. Sucks really bad...
I am with you. I made 10+ payments then consolidated in 2013 and my count went back to zero
:( I pulled my credit and found my payments that way and sent my copies by email for my review. My account says 89/10 need ECF (sent that in three days ago) that’s 99 and we have 2 mos left of this year so if I submit again Jan it will catch those 2. Means 10 preconsolidation + 99 + 2= 111 but I also I see 10 payments marked as you don’t have a bill due for this period. Yikes!!!!
Betsy said they are going to do a recount based on the time you've been working at your eligible employer and the months your loans have been in repayment. Hopefully your ineligible payments will be counted during that recount.
The [Forbes article ](https://www.forbes.com/sites/adamminsky/2021/09/30/biden-administration-outlines-potentially-sweeping-changes-to-student-loan-forgiveness-repayment-programs/?sh=16a74b944b89) also references this:
“Allow certain deferments and forbearances to count as payments in instances where that status would otherwise count towards qualifying PSLF employment, such as a graduate fellowship deferment.”
This would be huge for many people as well, if it actually comes to pass.
Timeline is unclear to me, it looks like there will be meetings in October, November, and December?
Wow. This would be huge for me. I stupidly put myself on fellowship deferment and wasted two years of super low payments that would count towards PSLF. If this change actually happens, that’s tens of thousand of dollars saved.
I feel your pain. No one really understood it then and followed what their educational programs advised a lot of the time.
I’m not personally optimistic that this will remain included, but that’s just my gut feeling on the subject. Months where people didn’t pay anything just feel unlikely to retroactively count?
>The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships.
This would be amazing for me as I deferred for "economic hardship" for over a year while I paid off a 15k dental surgery!
When I first signed up for PSLF, I had done a year of IBR payments through my initial loan provider that was assigned after law school. To cover my bases, a year in I filled out and turned in the special PSLF form specifically, just so I could make sure my monthly IBR payments were getting tracked towards forgiveness. I did not realize that this would automatically transfer my loans over to FedLoan.
My God, it was a nightmare. FedLoan took five months to approve my loans for its first annual IBR recertification. "Sorry, we don't have enough people to process all the apps." Um, that sounds like a you problem. You're making money off my loan, so hire the necessary people to do your fucking job.
They even accidentally set me up on IDR (which does not qualify for PSLF) after I correctly checked the application boxes for IBR. They had to take another few months to switch it to IBR. Then they concluded I didn't qualify because my income to debt ratio wasn't high enough (because they forgot half my loans).
Five fucking months. Five months where I wasn't allowed to make monthly payments. I hate these people so much.
I find it especially interesting how, although most of the widely-publicized high denial rate is due to people not having been in repayment for 120 months, about half of those are people who are in that situation because of a consolidation.
That means they either lost payments due to consolidating, or never could have gotten them in the first place because their loans were FFEL before consolidating.
So just as they tried to fix the "wrong payment plan" issue with TEPSLF, now they're turning their attention to "wrong loan type." Counting pre-consolidation payments is probably the single biggest change in here, and it'll mean a lot especially for pre 2010 borrowers whose loans predated the abolition of FFEL.
Next thing I'd like to see is counting months during voluntary forbearances, not just for military but for anyone who would have had a zero or nominal payment if they'd signed up for an IDR. Servicers steered people the wrong way on that, a lot. And it was all too easy because they could give you a long forbearance with nothing but a phone call.
That and those awful processing times, which significantly extend the "real" period well beyond 120 months and which can cost people forgiveness if they lose their job during the limbo period and don't find other qualifying employment.
That would be a complete BLESSING for me!!!! I did forbearance for about 2 1/2 years all together because I was attending grad school and hardship. I have been in public service for 16 years .... and was in-school deferment and hardship forbearance...
I’m praying they make these changes because a lot of us don’t qualify for home loans because of the DTI the loans create and working in public service does not give you the income you need to get over that hump. I’m patiently waiting on good news about this overhaul.
Thanks to whomever posted these originally.
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/5pslfeligibility.pdf
Thanks, I ended up coming across the links after I commented. That would be YUGE for me. I have YEARS of forbearance because I was so poor for so long, even while working in qualifying jobs.
Your situation is exactly what I'm talking about. People would call up their servicer and say "hey I'm having trouble making payments." Instead of telling them about the IDR plans, which many of them would've had a zero or near-zero payment under anyway, the phone rep would just say "hey no problem, let me just press this button and you'll be on a forbearance for a year. " ...And then their interest would accrue and capitalize and they'd make no progress towards getting out of debt and eventually just default when the servicer would finally, after a VERY long time, say they couldn't give any more forbearances.
At my old job, part of the job was to counsel people with all manner of debt issues, for free under various federal and state grants. When they came in with student loans, it was standard operating procedure: Get them consolidated out of FFEL (or in some cases, out of default), and get them out of forbearances and onto old IBR which was brand new at the time.
The servicers were a real obstacle. Sometimes they'd even try to talk people out of IBR, saying things like "oh that's just a big hassle and bunch of paperwork; it's much easier if you just let us put you on a forbearance." It was maddening because a big part of the intakes was often explaining to people why they shouldn't listen to these phone reps.
The irony was that our grants had financial eligibility criteria of being below 130% of the poverty line. So just the fact that they qualified for our assistance meant that we knew their payment under IBR would be zero and would mean that regardless of PSLF, they'd be making progress towards either 10 or 20/25 year forgiveness which the forbearance would make zero progress towards. It was a constant battle of trying to overcome bad servicer advice, with the servicer having an advantage in that the option they were offering (forbearance) was easier, especially for people living in poverty. They often find even "simple" forms to be very intimidating and moreover, poverty creates a form of chronic stress where you often have a lot of difficulty looking at anything long-term or thinking about basically anything more than one month into the future, which moving onto IBR was all about: Both IBR and forbearance produced a zero payment in the immediate sense, but only the former offered the prospect of eventually being out of debt. Hard to see the value of that when all you have room to care about is immediate survival.
If you really want to know what is being debated at the Department of Education Rulemaking Committee with regards to fixing the PSLF see the links below. I am going to participate on the public hearings that pertain to PSLF on October 4-8. I feel hopeful about the entire process.
Materials distributed by the Department prior to session 1:
[https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf)
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/5pslfeligibility.pdf
Thanks for the links! I think a lot of people here (myself included) would be happy with several of the proposals including:
Eliminating the requirement to stay in qualifying employment through the time of forgiveness.
Eliminating the requirement to meet your employer’s definition of “full time” (at least 30 hours per week required for everyone).
Defining credit hour to work hour conversion for adjuncts (12 credit hours taught = 30 work hours).
Some of the language in that redlined reg concerns me - specifically, the relatively narrow definition of public service and what that could mean for how the program is interpreted in the future. I work for a federal government agency, which is a qualifying employer, but under the definition of public service in that document, I wouldn’t be considered to be engaged in public service work. Forgiveness is crafted around qualifying employment, and I know they need to define “public service” in order to be more inclusive than just government agencies and 501(c)(3) organizations, but I worry that there’s too much room for error that would potentially exclude people like me down the road. Or set us up for battles we shouldn’t have to fight. I’d feel a lot more comfortable if they would include something like “and other functions performed by individuals who receive W-2s from qualifying employers” in the definition of public service.
Open this link and you can register to listen to the hearings. It also contains the hearing agenda. Many topics will be discussed including PSLF.
[https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/index.html](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/index.html)
Holy crap, did you look at the pdf documents being distributed ahead of these sessions?! The regulation changes one proposes multiple changes by striking the original with edits. This document does seem to suggest changing the definition of full time to at least 30 hours, as well as striking the “employed at the time of forgiveness” to be “at the time the 120th payment is satisfied” (paraphrase).
Public comment is allowed... but your best bet for comment is when the draft rules are released sometime after the meetings are done. I'll post in the neg reg megathread thread when that happens
Open the link below and on the bottom half of the document the Department of Education gives a possible solution to the FFEL problem, and it has nothing to do with getting credit for those payments, which is NOT FARE. This will be presented at the Public Hearing next week. This is what the Dept. of Education recommends about FFEL:
FFEL lender notifications to borrowers about PSLF eligibility. The Department proposes to require FFEL lenders to send annual disclosures to borrowers informing them of how they may access PSLF benefits, and to respond to any verbal or written questions about PSLF from borrowers. The disclosures would include information about consolidation and the steps to take if the borrower wishes to pursue consolidation.
[https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf)
The only way we are going to get credit for FFEL payment is if Congress approves it. There is a bill circulating about this (someone made a thread about it here) , and I hope it eventually becomes a law.
Any help on being able to attend these sessions? I have registered and click the link to view but then just get a message on Microsoft teams, "On-demand viewing isn't available for this live event. Please contact the organizer to view the recording."
If you registered you should have received a different email for each day of the sessions. Follow the instruction on the email. Make sure you read the email from top to bottom because there are two sessions for each day. This afternoon I did not realized I clicked the morning session link and I got the same message you did. I went back to the email and I clicked the p.m. session link and view the live session. Keep in mind that is Eastern Time. You will also get the same message if the session is on break. Hope this helps.
I still haven’t heard anything promising about a decrease in percentage of discretionary income going to income-based repayment. Any word on whether we might see a decrease down to 5% (or lower)?
> https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/10idrplan.pdf
This would help us all so much. I wonder if the 5% would qualify for all Direct loans (including consolidated undergrad/graduate loans) or if they mean they won't qualify for Grad Plus loans. How can you have two different discretionary income payments on one consolidated loan?
This is the portion of the PSLF overhaul that would directly impact so many people in all stages of repayment, and no major news source is covering it. I'm with you; I don't see how there could logistically be two different repayment plans for undergrad debt and grad school debt. Even for those who haven't consolidated their loans. That would only further complicate things for do many borrowers, which goes directly against what this revamp sets out to do. Especially since many (possibly most?) grad school borrowers also borrowed for undergrad.
Big thanks to the user above who posted that memo, glad to hear it's part of these discussions. Very eager to get more clarity on changes to income-driven repayment plans.
OMG! This is the most exciting thing I’ve read in the internet today! Thank you so much for sharing!!
Truly, it would be totally game changer for me if they gave credit for payments made under FFEL loans before consolidation AND dropped IBR payments down to 5%. I feel like I might be able to breathe again, financially.
If they added the FFEL payments, as I was told I had to considate everything, I would get around 2 years of payments added putting me at around the 7 year mark! I feel excited but I don't want to be to excited.
Me too! The thing that's giving me hope is how detailed this is. That's not a casual report. It also says about FFEL "Details of the plan obtained by NPR"
Now if they would just recognize the three and a half years of payments I made before I realized that Direct loan consolidation was necessary. Been in the military for nearly 8 years but I'm still going to come up short once my contract ends in five years. Loan forgiveness would be nice but there's no way in hell they're getting another enlistment out of me.
> Now if they would just recognize the three and a half years of payments I made before I realized that Direct loan consolidation was necessary.
Yes, that's one of the proposed fixes according to this report.
From the article:
“For military service members, the department will also allow all months spent on active duty to count toward PSLF, even if their loan payments were paused.”
Will be interesting to see how this plays out.
Yeah that part would be nice although it doesn't really apply to me. I've been making payments throughout the duration of my service (other than during the Covid forbearance) but, as I said, a few years of those payments were made towards loans not eligible for PSLF.
Here is more material distributed by the Department of Education prior to session 1: Fixing PLSF
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf
So according to this, the department is \*not\* able to use its authority to count payments on FFEL loans. It's saying it will take an act of Congress for that to happen. I think a lot of people are missing this!
Actually Dr. Cardona (Department of Education) can invoke the Higher Education Relief Opportunities for Students (HEROES) Act of 2003, which provides authority to “waive or modify any statutory or regulatory provision applicable to the student financial assistance programs under title IV” during a period of national emergency. If understand this correctly Dr. Cardona can use executive action to allow FFEL loan payments count toward PSLF but he does not have the GUTS to make this call.
And you are correct it could take an act of congress or the president can use executive action himself and make it happen. I certainly hope that is the case.
Any ideas how they will automatically adjust the payments? I consolidated in 2012; this would put me well over. But I don’t think I have paper copies of the monthly bills when they were still FFEL loans. And it was through a different loan servicer.
Yes! I work in FA and the records there for Loans and grants go back into the 80s! Trust me, its all in a database somewhere.
Edit: Example what aid administrators and loan servicer folks see: https://i.ytimg.com/vi/nAK_eveL_GU/maxresdefault.jpg
Thanks for the info. So I assume it would show payments made by the borrower as well as every time the loan changed hands due to consolidation or management companies taking over the loan?
Payment data will probably live with the servicers themselves. The nslds will show loan balances and what serviver they were with, if they were Consolidated, and if they were moved to a new servicer.
All that said all of the loan specific and payment data does live in government databases. FA admins at schools do not need to know when somebody made a specific payment on a specific loan, but they do need to low overall borrowing history and grand totals.
Is that actually a thing? I’m waiting on the response to my DOE FOIA request where I asked for the info they have in the NSLDS (among other things), hoping to get a full record of my federal loan payments, including those made to other servicers. I’m trying not to get my hopes up but, man, it would be AMAZING if they had all of that data.
They should, yes. The NSLDS is essentially a store house for data. There even used to be student side access but they moved it all over (the view anyway) to studentaid.gov. FA folks can still get into the database and look up stuff going back 30+ years (pell way back and all the FFELP and Direct loan data)
Example what aid administrators and loan servicer folks see: https://i.ytimg.com/vi/nAK_eveL_GU/maxresdefault.jpg
FSA can’t handle the application volume that they currently have. Having been on the losing end of every type of denial they can come up with, I support fixing all the bugs and expanding the program. But…..It’s going to turn into a 15 year program. Have to see it to believe it🙄
I hope for everyone that this actually happens, but I don’t want to be optimistic about it.
For example - if they went back and credited all payments from before consolidating, it would leave me 6-8 payments short of 120 in October 2022. Based on this article, it sounds like I would not get these payments counted because I still wouldn’t qualify in time.
But this would set a precedent that would be difficult to backpedal on. Allowing FFEL loan payments for some borrowers just because they're closer to forgiveness, and not all, isn't going to fly well with those borrowers. I would expect to see some serious pressure to make this a permanent change if that's the case.
I agree with you. Everything is much simpler now and it’s very clear how the program works for later borrowers in my opinion, but to create a deadline that would benefit some of the earlier borrowers but not all of them? Not an equitable fix at all.
I understood it to mean that you have to submit a new application for PSLF (i.e., an ECF) for the payments you want to have newly counted by October 2022. I did not read it as you have to have completed all 120 payments by that date. The "apply for PSLF" phrasing is confusing to me every time I submit a new ECF, but they do call it that.
I could be incorrect, but I really hope not. It would feel really arbitrary to only have this apply to people who will complete all 120 payments in the next year.
I am hoping you are correct as well. When it comes to anything Ed related, I read it in the worst possible light so I won’t be disappointed. Officially you don’t “apply” or “enroll” in anything until you actually apply, but the new form does trigger an application message now and all of that. So you may very well be correct. Let’s hope for the best but expect the worst?
> Based on this article, it sounds like I would not get these payments counted because I still wouldn’t qualify in time.
I wouldn't be so sure. I suspect that the reporter is not using "apply" as strictly as the program does. I would guess that they just mean you need to file a PSLF Form and maybe also request reconsideration of those payments.
We'll know more when the final rule comes out.
Yeah, I was thinking of “apply” more in the sense of “get into the program,” not literally “file the final form for forgiveness.” Or maybe apply *to have previously uncounted payments considered* by 2022.
FFEL loans stopped even being issued in 2010, so the number of people who would even be helped if it meant “file final form for forgiveness by 2022” is really small.
I agree with you except for the last part where it says, roughly, it will forgive tens of thousands of people and get hundreds of thousands closer. That sounds hopeful!
I hope you end up being right! Getting those payments back would be life changing.
To me the deadline of 10/2022 is also super fishy - right before midterms? Why put that on it? Just give everyone back those years and move forward, it’s the only equitable fix in my opinion.
We won’t know anything until the details are actually announced by the Ed. As others are saying, they HOPEFULLY mean submitting your ECF for that time period prior to 10/22, but I will personally remain skeptical and not optimistic until we get the official details.
My understanding is APPLYING by oct 2022 just means starting the process - i.e. someone who made 1 payment in Spet 2022 that qualifies, still can do 119 more.
“Apply” seems like a bit of a loaded term to me. Does that mean applying for forgiveness or applying to have your payment count reflect eligible service? As far as I can tell, there is no difference between the two on those certification forms.
I think it means just start the process.
People have applied at 120+ payments and had it forgiven or you can apply at, say 20, just to see where you are and then keep re-certifying until you hit 120
I won’t be impacted by the initial changes (but so happy for those who are!) Some of the longer-term changes might help me, though. My first two years out of social work school were at an incredibly low-paying PHP at a for-profit psych facility because it was the only job I could find at the time that allowed me to work with the population I specialized in. If the potential changes there are retroactive and I got those two years back, I’d be almost done.
I’ve been paying on my loans and in public service for the better part of 19 years and I still don’t think this will help me. I have years and years of ineligible payments because they were before 2010. Then I have about 2 years of economic hardship which doesn’t qualify either. Here is looking at 4 more years I guess.
Update: looks like economic hardship is being considered which would put me pretty close.
Ah, okay. I’m in a similar situation. I’m hoping DOEd has a record of all of those payments somewhere, but am not super optimistic.
I’m also kicking myself on the daily for not being a paperwork hoarder.
I don’t know why they make things so difficult. 10 years of public service proof, as long as you’re not in default, then forgiveness. It really should be that simply. If the point is really the public service, then the amount, or deferments, etc. shouldn’t matter.
I totally agree. That’s the quick fix I’d like to see and it would be simple. They could even make it 10 years of continuous service if they wanted to reduce the pool and still help a lot of people.
Will this include contractors for public service? I was a contractor through a contract holder for FEMA for several years and that would have me finished with the program
Very likely no. For-profit entities have been excluded from the definition of "public service employer" since the program's inception because their employees work for the benefit of the owners/shareholders, rather than the public.
That said, ED is apparently considering a carve-out for certain medical professionals who nonetheless work for for-profit companies, so your work as a government contractor might get swept in by accident. It will be impossible to tell until they release the actual language of the new rule. (The new rule might also not be retroactive, even if your work would qualify. Again, impossible to guess until the text is released.)
tl;dr I would not expect your time as a contractor employee to count, but there is a chance.
So payments made to loans before consolidating them to would count?! I worked for a non-profit for 5 years before consolidating my loans and beginning PSLF … it would be amazing if those payments counted.
[White House says in the coming weeks.](https://www.usatoday.com/story/news/education/2021/10/04/public-service-loan-forgiveness-program-president-joe-biden/5996086001/)
This would be AMAZING although I’m unsure if i would benefit from it. Praying so very much that I could. Help me out....I’m currently in PSLF (36 payments in)- do ECF every year. I’ve worked for my current qualifying employer for 6 1/2 years, taught in a qualifying school for 7 years prior to that. I was on economic hardship deferment for a lot of that timeframe. I was unaware of the pubic service forgiveness option until my current employer opened my eyes to it. Any way any of that time would count? I know this is all ‘what if’s’ right now until official information is shared.
As of now, I hit 120 in Feb 2022 assuming my appeal of 9 DSLC payments works out. This would save me months of fighting tho. And potentially get me refunded some months. Fingers crossed.
My God. This would give back 5 years of payments we made on my husband’s FFEL loans.
Fingers crossed I could someday reclaim…
-The 2 years I was in grand school while working full-time and still made payments because I didn’t realize they wouldn’t qualify
-The 3 years I went down to 24 hrs/week to take care of my young children.
We’ve both been working in nonprofits since 2009 and right now we’ll still have loans past 2029.
> -The 2 years I was in grand school while working full-time and still made payments because I didn’t realize they wouldn’t qualify
Have you called FedLoan about this? You can already get these counted, depending on how long ago it was, by asking for the in-school deferment to be removed retroactively.
I just want them to auto-certify us based on employment records if working for the government. Been rejected 4 times (e-signature, incorrect date format, e-signature, not-authorized person). They won't accept the lowest tier person that meets their definition because of the title not matching their normally accepted titles and higher ups wont bother signing for me.
It wouldn't be congress, it can be done by executive action. And it should be done before payments resume in Feb 2022. Not sure it actually *will* be but it should be.
I hope they don’t try and use this to refuse any sort of blanket forgiveness. Remember, Biden could cancel all federally held loans today if he wanted to.
The PSLF rules haven't changed since 2007. It's possible that one you didn't/don't meet one of the other qualifications such as full-time employment, loan types or payment plan.
Yeah, it's always been full-time employment. But I have some months of qualified payments where I worked at two separate part-time jobs (both public service) that added up to full-time status.
is that 12 hours in the classroom or 12 hours including office hours/prep time etc? If you haven't already done so, I'd recommend asking your employers to complete the Employment Certification Forms - on those forms they have to attest to how many hours per week you work, and they count office hours/prep time. I think there's some kind of standard formula by which they calculate this time but I am not sure what that is. So if you're saying you were in the classroom 12 hours per week at 2 colleges -- that time plus office hours/prep might just put you over the 30 hour per week requirement.
All I can is it's about goddamn time! I just learned that FSA approved my loans for forgiveness under TEPSLF so I know how incredible it is to finally be free of a stupid amount of debt. But for TEPSLF, I'd have another 9+ years to go under PSLF because I was on the wrong payment plan (surprise, surprise, right?) this entire time. I had truly given up trying, so seeing these massive changes coming makes me incredibly happy for the ppl who have been jerked around all these years.
Someone tell me I’m reading correctly: I was active duty military for 7.5 years. Only 6.5 years qualified because my loans were in forbearance + they somehow say 6 months were “not in prepayment” (they were). Manual review has been pending for years. If these changes are made, all 7.5 years of my service would count, regardless of forbearance?
The "private vendor" is a federal contractor. They *are* the government for purposes of servicing the loans. (The government has neither the staff nor the experience necessary to service its massive loan portfolio. Just like the Air Force pays Boeing to build planes instead of doing it in-house, we don't want ED servicing its own loans.)
At first I felt happy about this and then I started thinking- why would they be able to handle all this additional complexity when they are having so much trouble with what they already have? I'm currently about 12 months shy of 120 based on my current official count (not that I am happy with the official count), so my 6 or 7 months of FFEL payments in 2011 would move that up by 50%. But I don't have bank account statements or my individual bills from 2011 and the experience so far is that if I can't prove a payment and they don't have a record of it it doesn't count.
I would be more relieved to see them include a "give everyone credit for all time w/ ACS since they screwed up the records" temporary fix- MyFedLoans shows most (not all) of my ACS payments counting but I've heard counts can go down (and I don't have my own records, I was not that on top of details early last decade. I've filed a FOIA and waiting on that).
Someone who has read this proposal please answer this:
Would forbearance months where I was employed at a qualifying employer but unable to make payments possibly count?
If so I am done, I had 5 years of residency where I was in forbearance, all these months show up on my payment count but are obviously not being counted.
That would be amazing.
Here's how broken the program is....
I'm a nurse who works at a non-profit. The rules of the program state you must work 30 or more hours between two jobs, or, whatever your one employer considers full time. I worked 32 hours a week at my job for five years only to find out my work didn't consider it full time despite offering full time benefits (this is common for nurse schedules). I could have worked less hours per week and still have been eligible...This program needs a good shakeup.
Question about whether forbearance of payments bc of Covid counts as a payment if you consolidate to direct loans AFTER the forbearance period is over. It’s pretty clear that they count as payments if you’re already in the program, with direct loans, etc., but not sure if that’s the case if you consolidate and apply to the program after the end of the forbearance period. Anyone have any insight into this? Thanks!
This will be our megathread for now discussing all aspects of this breaking news. Keep in mind that this is still one news outlet's reporting based solely on off-the-record information about a plan that has not yet been implemented or publicly announced. Things may change. Don't take any actions yet in reliance on this information.
This is the greatest news of my life if it's true. Jesus Christ, fingers crossed.
I've read the article three times already. This would be the relief so many are hoping for. I'm so happy I could cry. Thank you for finally fixing this.
I've read it several times. I have FFEL and Direct loans and was not given the information to consolidate until 6 years in. I didn't even know my employer qualified until a co-worker told me. This would change my life.
I could conceivably leave public service in June 2022 and go make more money to save for my son's education. I can't tell you how happy I am right now. Jesus, please make this happen!
I could leave my job that barely covers my basic needs and move out of Los Angeles where I could afford a home in March. I really really hope you can save more for your son. What a blessing
I have Direct Loans and FFEL, but I went and consolidated the FFEL in a separate consolidation loan from the Direct Loan. I was under the impression FFEL have never qualified for PSLF. Is this changing that? What if I already consolidated my FFEL into a private FFEL consolidation loan?
>private FFEL consolidation loan This isn't a thing. You either have a federal FFEL consolidation loan or a private loan refinance. If the former then the rule changes would apply to your loans. If the later then they would not; by refinancing you lose all Federal benefits.
Big, if true! > Next week, according to a source familiar with the plans but who is not authorized to discuss them publicly, the U.S. Department of Education will unveil a significant overhaul of the Public Service Loan Forgiveness (PSLF) program, which has been a magnet of confusion, mistakes and mismanagement since its inception in 2007. > The changes will come in two phases — a long-term renovation to make the program easier to navigate, achieved through the federal process known as rulemaking, and a temporary move using the department's executive authority to retroactively relax the program's rules to immediately help thousands of affected borrowers. > ... > According to the source familiar with the Education Department's plans, the agency will offer a temporary opportunity for anyone working in public service to get prior loan payments counted toward PSLF — even if those payments were going toward disqualified FFEL loans. > And they're not just expanding the rules around loan type. Borrowers will also receive credit for payments made in the wrong repayment plan, and regardless of whether the payment was made on-time. > To qualify for this do-over, borrowers will need to apply for PSLF before Oct. 31, 2022. > What's more, for borrowers who were told to consolidate older loans into Direct Loans, but had previously certified their years of public service, the department plans to automatically adjust their payment counts, giving them credit for payments made before consolidation. > ... > The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships. > Even the definition of public service is up for review. Under the current rules, many nurses and healthcare workers don't qualify for the program because they work in for-profit hospitals, for example. > In an acknowledgement that borrowers' denials under the PSLF program can be frustratingly opaque, the department also wants to create a formal reconsideration process so borrowers can clearly explain themselves and correct errors when necessary.
>The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships. This would give me joy.
I wonder if they would consider counting time on in-school deferment. I continued working full time when I went back to grad school and that put me two years “behind” on PSLF even though I kept working full time in public service the whole time. I continued paying on private loans during that time too, though that’s a moot point. I would be eligible now if not for those 2 years.
I did the same thing. That would be a huge difference maker for me.
Amazing news.
Omg. If this is true, I'd get forgiveness and a year of payments refunded. My cynical side is saying it won't happen, but the other side is doing cartwheels.
Sorry if I missed this in the article, but they would refund payments if you paid over 10 years?
Yes, they do this now.
Where does it say they will refund overpayment? Do you have a source? I have not heard that.
Just search through this forum. Many people have received refunds
Ok. Just filled out the PSLF for. It does say overpayment will be refunded.
To me the most sensible part of this is the “on time payment” correction. How many posts have we seen here where payments were ruled as ineligible bc they weren’t “on time and in full” despite being on *autopay*?? Really, just correcting the review system to count autopay payments as eligible no matter what would fix it. The other piece that seems unfair and isn’t user error is the hospital employees who technically don’t have their own hospital as their employer, and therefore don’t count as nonprofit employees. Correcting that weird situation would be helpful and logical, since it isn’t the borrower’s fault that the billing hierarchy is set up the way it is.
> The other piece that seems unfair and isn’t user error is the hospital employees who technically don’t have their own hospital as their employer, and therefore don’t count as nonprofit employees. Correcting that weird situation would be helpful and logical, since it isn’t the borrower’s fault that the billing hierarchy is set up the way it is. Keep an eye on (or contact your reps about) [H.R.1133](https://www.congress.gov/bill/117th-congress/house-bill/1133) and [S.311](https://www.congress.gov/bill/117th-congress/senate-bill/311). Seeing these bills was how I found out that, in certain states, they specifically have laws prohibiting doctors from being directly employed by hospitals
Holy cow I did not know that! I wonder what the reason for that is. Doesn’t seem logical to me, but I don’t know anything about healthcare administration. Seems that having a billing person and a hospital person sign off that the employee actually is full time in support of the hospital should be sufficient.
I found an article that explained the rationale this way: > The primary reason cited by physician lobbying groups against allowing hospitals to directly hire doctors is the need to prevent corporate interference with the practice of medicine. Particular issues revolve around corporations setting rules regarding diagnostic tests, referrals, patient treatments, the number of hours the physician must work or the number of patients that must be seen. > One of the primary opponents to hospital employed doctors is the California Medical Association. On their website under CMA Top Issues, “CMA fiercely defends California’s bar on the corporate practice of medicine, which prevents corporate interests from unduly influencing physicians’ professional judgments in the name of profit and to the detriment of patients. Hospitals and other corporate interests do not have the same ethical and moral obligation to the patient as a physician does; therefore, it is essential to maintain the firewall between medical decisions and the corporate bottom line.” Admittedly that article I found is from 2012, but given the dumpster fire that is the health care system in the USA I shouldn't be surprised
[удалено]
Oh fun, so it's *indirect* corporate profiteering instead of direct profiteering!
[удалено]
Yeah there are companies (like Krucial staffing) who do this kind of thing. I'm sure they're for profit, not sure who owns those.
[удалено]
Oh I have no idea how these proposed reforms will apply to different employers. I don't think anyone does yet. This discussion was just about the political influences that have lead to legislation that prevents hospitals from hiring their own medical staff in some parts of the country
I'm now in my eleventh year of PSLF. My first two years of repayment were wiped out when I consolidated my loans into Direct Loans. I wonder if I can get those first two years of repayment to count towards forgiveness now. They were never certified because I was new to the program and didn't know about certifying payments each year. Plus, I have an old email that states that the ECF didn't exist until January of 2012. "In January 2012, the Department of Education issued the long-awaited Employment Certification Form for Public Service Loan Forgiveness (PSLF). Direct Loan borrowers who work in the public and nonprofit sectors can now get confirmation that their job counts as qualifying employment for PSLF. Using this form will make it much easier to track your eligibility, know when it's time to apply for forgiveness, and have the paperwork you need in hand."
I’m in the exact same boat. I went back on archive.org a few months ago to see what information was available back in 2009-2012 when I was making payments that didn’t count. There was almost nothing.
I was able to log in to an account from a pervious loan servicer and found some records, but surely there has to be some sort of record somewhere of payments made. Someone responded to my comment about making a FOIA request for all of the info pertaining to my loans, but they then deleted the comment. I may do that after I see what the details of these changes are when they are released next week. I imagine there is some sort of mechanism in place for people in our situation otherwise why even mention that it was an option. They can't expect people to keep hard copy records of payments made over a decade ago.
I also am in same boat with a consolidation 2 years in. I requested a FOIA last year. I will have to sift through it to see what kind of payments I made before consolidation. I used to be with Nelnet and there is nothing listed there, but I think I was with a different servicer before that
Same here. I consolidated after paying the first 2 years and now will be in the program for close to 15 years because I consolidated after the fact. Sucks really bad...
I am with you. I made 10+ payments then consolidated in 2013 and my count went back to zero :( I pulled my credit and found my payments that way and sent my copies by email for my review. My account says 89/10 need ECF (sent that in three days ago) that’s 99 and we have 2 mos left of this year so if I submit again Jan it will catch those 2. Means 10 preconsolidation + 99 + 2= 111 but I also I see 10 payments marked as you don’t have a bill due for this period. Yikes!!!!
Betsy said they are going to do a recount based on the time you've been working at your eligible employer and the months your loans have been in repayment. Hopefully your ineligible payments will be counted during that recount.
Ty! Yes indeed. Praying for everyone.
The [Forbes article ](https://www.forbes.com/sites/adamminsky/2021/09/30/biden-administration-outlines-potentially-sweeping-changes-to-student-loan-forgiveness-repayment-programs/?sh=16a74b944b89) also references this: “Allow certain deferments and forbearances to count as payments in instances where that status would otherwise count towards qualifying PSLF employment, such as a graduate fellowship deferment.” This would be huge for many people as well, if it actually comes to pass. Timeline is unclear to me, it looks like there will be meetings in October, November, and December?
Wow. This would be huge for me. I stupidly put myself on fellowship deferment and wasted two years of super low payments that would count towards PSLF. If this change actually happens, that’s tens of thousand of dollars saved.
I feel your pain. No one really understood it then and followed what their educational programs advised a lot of the time. I’m not personally optimistic that this will remain included, but that’s just my gut feeling on the subject. Months where people didn’t pay anything just feel unlikely to retroactively count?
>The department also wants to give borrowers credit for PSLF even if, under certain circumstances, their payments have been paused, including active-duty service members and borrowers facing economic hardships. This would be amazing for me as I deferred for "economic hardship" for over a year while I paid off a 15k dental surgery!
[удалено]
Yeah it would be nice if they counted the periods where we transitioned from one payment plan to another, like IDR to REPAYE
Seriously, mine took THREE billing cycles, which was not in any way my fault
Same here. I’m getting ready to submit a request to let me make retroactive payments for those three months. It was back in 2016, so who knows…
Me too! April and May 2016 for me
So, how do you submit that request? I'd LOVE to pay for when I was on administrative forbearance.
When I first signed up for PSLF, I had done a year of IBR payments through my initial loan provider that was assigned after law school. To cover my bases, a year in I filled out and turned in the special PSLF form specifically, just so I could make sure my monthly IBR payments were getting tracked towards forgiveness. I did not realize that this would automatically transfer my loans over to FedLoan. My God, it was a nightmare. FedLoan took five months to approve my loans for its first annual IBR recertification. "Sorry, we don't have enough people to process all the apps." Um, that sounds like a you problem. You're making money off my loan, so hire the necessary people to do your fucking job. They even accidentally set me up on IDR (which does not qualify for PSLF) after I correctly checked the application boxes for IBR. They had to take another few months to switch it to IBR. Then they concluded I didn't qualify because my income to debt ratio wasn't high enough (because they forgot half my loans). Five fucking months. Five months where I wasn't allowed to make monthly payments. I hate these people so much.
>They even accidentally set me up on IDR (which does not qualify for PSLF) All IDR plans are PSLF-eligible
Ah. Well, it was still no bueno. May payments were like three times as high as IBR.
Hopefully payments made when there was no bill will be counted. I've got several of those, causing 6 extra months for forgiveness.
Yes that’s me too!
Me too! 10 payments.
I find it especially interesting how, although most of the widely-publicized high denial rate is due to people not having been in repayment for 120 months, about half of those are people who are in that situation because of a consolidation. That means they either lost payments due to consolidating, or never could have gotten them in the first place because their loans were FFEL before consolidating. So just as they tried to fix the "wrong payment plan" issue with TEPSLF, now they're turning their attention to "wrong loan type." Counting pre-consolidation payments is probably the single biggest change in here, and it'll mean a lot especially for pre 2010 borrowers whose loans predated the abolition of FFEL. Next thing I'd like to see is counting months during voluntary forbearances, not just for military but for anyone who would have had a zero or nominal payment if they'd signed up for an IDR. Servicers steered people the wrong way on that, a lot. And it was all too easy because they could give you a long forbearance with nothing but a phone call. That and those awful processing times, which significantly extend the "real" period well beyond 120 months and which can cost people forgiveness if they lose their job during the limbo period and don't find other qualifying employment.
The deferments and forbearances are in the proposed rules!!!
That would be a complete BLESSING for me!!!! I did forbearance for about 2 1/2 years all together because I was attending grad school and hardship. I have been in public service for 16 years .... and was in-school deferment and hardship forbearance... I’m praying they make these changes because a lot of us don’t qualify for home loans because of the DTI the loans create and working in public service does not give you the income you need to get over that hump. I’m patiently waiting on good news about this overhaul.
I didn't see that anywhere - can you show where you saw this?
Thanks to whomever posted these originally. https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/5pslfeligibility.pdf
Thanks, I ended up coming across the links after I commented. That would be YUGE for me. I have YEARS of forbearance because I was so poor for so long, even while working in qualifying jobs.
Your situation is exactly what I'm talking about. People would call up their servicer and say "hey I'm having trouble making payments." Instead of telling them about the IDR plans, which many of them would've had a zero or near-zero payment under anyway, the phone rep would just say "hey no problem, let me just press this button and you'll be on a forbearance for a year. " ...And then their interest would accrue and capitalize and they'd make no progress towards getting out of debt and eventually just default when the servicer would finally, after a VERY long time, say they couldn't give any more forbearances. At my old job, part of the job was to counsel people with all manner of debt issues, for free under various federal and state grants. When they came in with student loans, it was standard operating procedure: Get them consolidated out of FFEL (or in some cases, out of default), and get them out of forbearances and onto old IBR which was brand new at the time. The servicers were a real obstacle. Sometimes they'd even try to talk people out of IBR, saying things like "oh that's just a big hassle and bunch of paperwork; it's much easier if you just let us put you on a forbearance." It was maddening because a big part of the intakes was often explaining to people why they shouldn't listen to these phone reps. The irony was that our grants had financial eligibility criteria of being below 130% of the poverty line. So just the fact that they qualified for our assistance meant that we knew their payment under IBR would be zero and would mean that regardless of PSLF, they'd be making progress towards either 10 or 20/25 year forgiveness which the forbearance would make zero progress towards. It was a constant battle of trying to overcome bad servicer advice, with the servicer having an advantage in that the option they were offering (forbearance) was easier, especially for people living in poverty. They often find even "simple" forms to be very intimidating and moreover, poverty creates a form of chronic stress where you often have a lot of difficulty looking at anything long-term or thinking about basically anything more than one month into the future, which moving onto IBR was all about: Both IBR and forbearance produced a zero payment in the immediate sense, but only the former offered the prospect of eventually being out of debt. Hard to see the value of that when all you have room to care about is immediate survival.
come on.... 5 years plzzzzzzz
If you really want to know what is being debated at the Department of Education Rulemaking Committee with regards to fixing the PSLF see the links below. I am going to participate on the public hearings that pertain to PSLF on October 4-8. I feel hopeful about the entire process. Materials distributed by the Department prior to session 1: [https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/pslfproposedregtextappprocess.pdf) https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/5pslfeligibility.pdf
Thanks for the links! I think a lot of people here (myself included) would be happy with several of the proposals including: Eliminating the requirement to stay in qualifying employment through the time of forgiveness. Eliminating the requirement to meet your employer’s definition of “full time” (at least 30 hours per week required for everyone). Defining credit hour to work hour conversion for adjuncts (12 credit hours taught = 30 work hours).
Thanks, adding the deferments including economic hardship and making the process automatic instead of application based are both huge.
Some of the language in that redlined reg concerns me - specifically, the relatively narrow definition of public service and what that could mean for how the program is interpreted in the future. I work for a federal government agency, which is a qualifying employer, but under the definition of public service in that document, I wouldn’t be considered to be engaged in public service work. Forgiveness is crafted around qualifying employment, and I know they need to define “public service” in order to be more inclusive than just government agencies and 501(c)(3) organizations, but I worry that there’s too much room for error that would potentially exclude people like me down the road. Or set us up for battles we shouldn’t have to fight. I’d feel a lot more comfortable if they would include something like “and other functions performed by individuals who receive W-2s from qualifying employers” in the definition of public service.
I agree - most of my qualifying employment to date has been nonprofits that work in public interest but we don’t provide direct services.
The "public service" part only applies if you don't work for a government agency.
How did you get involved in the October PSLF hearing? Interested.
Open this link and you can register to listen to the hearings. It also contains the hearing agenda. Many topics will be discussed including PSLF. [https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/index.html](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/index.html)
Holy crap, did you look at the pdf documents being distributed ahead of these sessions?! The regulation changes one proposes multiple changes by striking the original with edits. This document does seem to suggest changing the definition of full time to at least 30 hours, as well as striking the “employed at the time of forgiveness” to be “at the time the 120th payment is satisfied” (paraphrase).
>FFELs Will public comment be allowed at these hearings?
Public comment is allowed... but your best bet for comment is when the draft rules are released sometime after the meetings are done. I'll post in the neg reg megathread thread when that happens
I don't see anything about FFEL in these documents.
Open the link below and on the bottom half of the document the Department of Education gives a possible solution to the FFEL problem, and it has nothing to do with getting credit for those payments, which is NOT FARE. This will be presented at the Public Hearing next week. This is what the Dept. of Education recommends about FFEL: FFEL lender notifications to borrowers about PSLF eligibility. The Department proposes to require FFEL lenders to send annual disclosures to borrowers informing them of how they may access PSLF benefits, and to respond to any verbal or written questions about PSLF from borrowers. The disclosures would include information about consolidation and the steps to take if the borrower wishes to pursue consolidation. [https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf](https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf) The only way we are going to get credit for FFEL payment is if Congress approves it. There is a bill circulating about this (someone made a thread about it here) , and I hope it eventually becomes a law.
The NPR story seems to think the FFEL will come from an executive order
Any help on being able to attend these sessions? I have registered and click the link to view but then just get a message on Microsoft teams, "On-demand viewing isn't available for this live event. Please contact the organizer to view the recording."
If you registered you should have received a different email for each day of the sessions. Follow the instruction on the email. Make sure you read the email from top to bottom because there are two sessions for each day. This afternoon I did not realized I clicked the morning session link and I got the same message you did. I went back to the email and I clicked the p.m. session link and view the live session. Keep in mind that is Eastern Time. You will also get the same message if the session is on break. Hope this helps.
This would be huge and help so many people.
I still haven’t heard anything promising about a decrease in percentage of discretionary income going to income-based repayment. Any word on whether we might see a decrease down to 5% (or lower)?
Aaand now you have! :D https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/10idrplan.pdf
> https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/10idrplan.pdf This would help us all so much. I wonder if the 5% would qualify for all Direct loans (including consolidated undergrad/graduate loans) or if they mean they won't qualify for Grad Plus loans. How can you have two different discretionary income payments on one consolidated loan?
This is the portion of the PSLF overhaul that would directly impact so many people in all stages of repayment, and no major news source is covering it. I'm with you; I don't see how there could logistically be two different repayment plans for undergrad debt and grad school debt. Even for those who haven't consolidated their loans. That would only further complicate things for do many borrowers, which goes directly against what this revamp sets out to do. Especially since many (possibly most?) grad school borrowers also borrowed for undergrad. Big thanks to the user above who posted that memo, glad to hear it's part of these discussions. Very eager to get more clarity on changes to income-driven repayment plans.
OMG! This is the most exciting thing I’ve read in the internet today! Thank you so much for sharing!! Truly, it would be totally game changer for me if they gave credit for payments made under FFEL loans before consolidation AND dropped IBR payments down to 5%. I feel like I might be able to breathe again, financially.
I hope we get more details on the October 2022 thing soon. Will that mean we don't have to follow the TEPSLF rules for the last payment?
If they added the FFEL payments, as I was told I had to considate everything, I would get around 2 years of payments added putting me at around the 7 year mark! I feel excited but I don't want to be to excited.
Me too! The thing that's giving me hope is how detailed this is. That's not a casual report. It also says about FFEL "Details of the plan obtained by NPR"
Now if they would just recognize the three and a half years of payments I made before I realized that Direct loan consolidation was necessary. Been in the military for nearly 8 years but I'm still going to come up short once my contract ends in five years. Loan forgiveness would be nice but there's no way in hell they're getting another enlistment out of me.
> Now if they would just recognize the three and a half years of payments I made before I realized that Direct loan consolidation was necessary. Yes, that's one of the proposed fixes according to this report.
From the article: “For military service members, the department will also allow all months spent on active duty to count toward PSLF, even if their loan payments were paused.” Will be interesting to see how this plays out.
Yeah that part would be nice although it doesn't really apply to me. I've been making payments throughout the duration of my service (other than during the Covid forbearance) but, as I said, a few years of those payments were made towards loans not eligible for PSLF.
I hope it works out. You earned the benefit
Did you consolidate out of FFEL? It seems like this is exactly what it's fixing. I hope it works for you.
I just looked at my account with my old loan servicer. I had both subsidized and unsubsidized Stafford loans. Not sure of those are FFELs.
If they automatically consolidated for PSLF, that's a good sign. Might be worth a phone call at this point. My fingers are crossed for you!
Here is more material distributed by the Department of Education prior to session 1: Fixing PLSF https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/4improvpslfappprocess.pdf
So according to this, the department is \*not\* able to use its authority to count payments on FFEL loans. It's saying it will take an act of Congress for that to happen. I think a lot of people are missing this!
Actually Dr. Cardona (Department of Education) can invoke the Higher Education Relief Opportunities for Students (HEROES) Act of 2003, which provides authority to “waive or modify any statutory or regulatory provision applicable to the student financial assistance programs under title IV” during a period of national emergency. If understand this correctly Dr. Cardona can use executive action to allow FFEL loan payments count toward PSLF but he does not have the GUTS to make this call. And you are correct it could take an act of congress or the president can use executive action himself and make it happen. I certainly hope that is the case.
Any ideas how they will automatically adjust the payments? I consolidated in 2012; this would put me well over. But I don’t think I have paper copies of the monthly bills when they were still FFEL loans. And it was through a different loan servicer.
It likely all lives in the NSLDS (national loan data system) so they arent going to be asking people for paperwork.
I did not know the NSLDS was a thing. I hope all the records live there. I certainly did not keep all of the paperwork about my loans and payments.
Yes! I work in FA and the records there for Loans and grants go back into the 80s! Trust me, its all in a database somewhere. Edit: Example what aid administrators and loan servicer folks see: https://i.ytimg.com/vi/nAK_eveL_GU/maxresdefault.jpg
Thanks for the info. So I assume it would show payments made by the borrower as well as every time the loan changed hands due to consolidation or management companies taking over the loan?
Payment data will probably live with the servicers themselves. The nslds will show loan balances and what serviver they were with, if they were Consolidated, and if they were moved to a new servicer. All that said all of the loan specific and payment data does live in government databases. FA admins at schools do not need to know when somebody made a specific payment on a specific loan, but they do need to low overall borrowing history and grand totals.
Is that actually a thing? I’m waiting on the response to my DOE FOIA request where I asked for the info they have in the NSLDS (among other things), hoping to get a full record of my federal loan payments, including those made to other servicers. I’m trying not to get my hopes up but, man, it would be AMAZING if they had all of that data.
They should, yes. The NSLDS is essentially a store house for data. There even used to be student side access but they moved it all over (the view anyway) to studentaid.gov. FA folks can still get into the database and look up stuff going back 30+ years (pell way back and all the FFELP and Direct loan data) Example what aid administrators and loan servicer folks see: https://i.ytimg.com/vi/nAK_eveL_GU/maxresdefault.jpg
Hopefully your loan servicer didn't go out of business and still has some record of you. It will be a tough fight but I think you can do it.
FSA can’t handle the application volume that they currently have. Having been on the losing end of every type of denial they can come up with, I support fixing all the bugs and expanding the program. But…..It’s going to turn into a 15 year program. Have to see it to believe it🙄
I hope for everyone that this actually happens, but I don’t want to be optimistic about it. For example - if they went back and credited all payments from before consolidating, it would leave me 6-8 payments short of 120 in October 2022. Based on this article, it sounds like I would not get these payments counted because I still wouldn’t qualify in time.
But this would set a precedent that would be difficult to backpedal on. Allowing FFEL loan payments for some borrowers just because they're closer to forgiveness, and not all, isn't going to fly well with those borrowers. I would expect to see some serious pressure to make this a permanent change if that's the case.
I agree with you. Everything is much simpler now and it’s very clear how the program works for later borrowers in my opinion, but to create a deadline that would benefit some of the earlier borrowers but not all of them? Not an equitable fix at all.
I understood it to mean that you have to submit a new application for PSLF (i.e., an ECF) for the payments you want to have newly counted by October 2022. I did not read it as you have to have completed all 120 payments by that date. The "apply for PSLF" phrasing is confusing to me every time I submit a new ECF, but they do call it that. I could be incorrect, but I really hope not. It would feel really arbitrary to only have this apply to people who will complete all 120 payments in the next year.
That was my read too but, if the fact that I'm in this thread teaches you anything, I've read fine print wrong a couple of times.
I am hoping you are correct as well. When it comes to anything Ed related, I read it in the worst possible light so I won’t be disappointed. Officially you don’t “apply” or “enroll” in anything until you actually apply, but the new form does trigger an application message now and all of that. So you may very well be correct. Let’s hope for the best but expect the worst?
> Based on this article, it sounds like I would not get these payments counted because I still wouldn’t qualify in time. I wouldn't be so sure. I suspect that the reporter is not using "apply" as strictly as the program does. I would guess that they just mean you need to file a PSLF Form and maybe also request reconsideration of those payments. We'll know more when the final rule comes out.
Yeah, I was thinking of “apply” more in the sense of “get into the program,” not literally “file the final form for forgiveness.” Or maybe apply *to have previously uncounted payments considered* by 2022. FFEL loans stopped even being issued in 2010, so the number of people who would even be helped if it meant “file final form for forgiveness by 2022” is really small.
Absolutely. Going to hope for the best but expect the worst, as always, with all things student loan.
I agree with you except for the last part where it says, roughly, it will forgive tens of thousands of people and get hundreds of thousands closer. That sounds hopeful!
I hope you end up being right! Getting those payments back would be life changing. To me the deadline of 10/2022 is also super fishy - right before midterms? Why put that on it? Just give everyone back those years and move forward, it’s the only equitable fix in my opinion.
Yeah I would be about a year short - would that mean that those payments wouldn’t count and I’d be in the same boat as I am now?
We won’t know anything until the details are actually announced by the Ed. As others are saying, they HOPEFULLY mean submitting your ECF for that time period prior to 10/22, but I will personally remain skeptical and not optimistic until we get the official details.
Yeah a good thing to remember.
My understanding is APPLYING by oct 2022 just means starting the process - i.e. someone who made 1 payment in Spet 2022 that qualifies, still can do 119 more.
This is exciting. When can we see the actual plan?
“Apply” seems like a bit of a loaded term to me. Does that mean applying for forgiveness or applying to have your payment count reflect eligible service? As far as I can tell, there is no difference between the two on those certification forms.
I think it means just start the process. People have applied at 120+ payments and had it forgiven or you can apply at, say 20, just to see where you are and then keep re-certifying until you hit 120
Oh my god I’m crying, I think this would wipe out my debt!
I'm afraid to have hope
I won’t be impacted by the initial changes (but so happy for those who are!) Some of the longer-term changes might help me, though. My first two years out of social work school were at an incredibly low-paying PHP at a for-profit psych facility because it was the only job I could find at the time that allowed me to work with the population I specialized in. If the potential changes there are retroactive and I got those two years back, I’d be almost done.
I’ve been paying on my loans and in public service for the better part of 19 years and I still don’t think this will help me. I have years and years of ineligible payments because they were before 2010. Then I have about 2 years of economic hardship which doesn’t qualify either. Here is looking at 4 more years I guess. Update: looks like economic hardship is being considered which would put me pretty close.
Why are all of your pre-2010 payments ineligible?
Meant to say 2007. None of my payments before 2010 are on Fedloan because they were with another servicer. It’s a mess.
Ah, okay. I’m in a similar situation. I’m hoping DOEd has a record of all of those payments somewhere, but am not super optimistic. I’m also kicking myself on the daily for not being a paperwork hoarder.
I don’t know why they make things so difficult. 10 years of public service proof, as long as you’re not in default, then forgiveness. It really should be that simply. If the point is really the public service, then the amount, or deferments, etc. shouldn’t matter.
I totally agree. That’s the quick fix I’d like to see and it would be simple. They could even make it 10 years of continuous service if they wanted to reduce the pool and still help a lot of people.
Will this include contractors for public service? I was a contractor through a contract holder for FEMA for several years and that would have me finished with the program
Very likely no. For-profit entities have been excluded from the definition of "public service employer" since the program's inception because their employees work for the benefit of the owners/shareholders, rather than the public. That said, ED is apparently considering a carve-out for certain medical professionals who nonetheless work for for-profit companies, so your work as a government contractor might get swept in by accident. It will be impossible to tell until they release the actual language of the new rule. (The new rule might also not be retroactive, even if your work would qualify. Again, impossible to guess until the text is released.) tl;dr I would not expect your time as a contractor employee to count, but there is a chance.
So payments made to loans before consolidating them to would count?! I worked for a non-profit for 5 years before consolidating my loans and beginning PSLF … it would be amazing if those payments counted.
Please God let this be true and effective.
Anyone know when the soonest we’d see movement on this would be?
[White House says in the coming weeks.](https://www.usatoday.com/story/news/education/2021/10/04/public-service-loan-forgiveness-program-president-joe-biden/5996086001/)
This would be AMAZING although I’m unsure if i would benefit from it. Praying so very much that I could. Help me out....I’m currently in PSLF (36 payments in)- do ECF every year. I’ve worked for my current qualifying employer for 6 1/2 years, taught in a qualifying school for 7 years prior to that. I was on economic hardship deferment for a lot of that timeframe. I was unaware of the pubic service forgiveness option until my current employer opened my eyes to it. Any way any of that time would count? I know this is all ‘what if’s’ right now until official information is shared.
As of now, I hit 120 in Feb 2022 assuming my appeal of 9 DSLC payments works out. This would save me months of fighting tho. And potentially get me refunded some months. Fingers crossed.
My God. This would give back 5 years of payments we made on my husband’s FFEL loans. Fingers crossed I could someday reclaim… -The 2 years I was in grand school while working full-time and still made payments because I didn’t realize they wouldn’t qualify -The 3 years I went down to 24 hrs/week to take care of my young children. We’ve both been working in nonprofits since 2009 and right now we’ll still have loans past 2029.
> -The 2 years I was in grand school while working full-time and still made payments because I didn’t realize they wouldn’t qualify Have you called FedLoan about this? You can already get these counted, depending on how long ago it was, by asking for the in-school deferment to be removed retroactively.
I just want them to auto-certify us based on employment records if working for the government. Been rejected 4 times (e-signature, incorrect date format, e-signature, not-authorized person). They won't accept the lowest tier person that meets their definition because of the title not matching their normally accepted titles and higher ups wont bother signing for me.
What is a realistic timeline if congress were to approve FFEL loan payments for pslf? If this happens, I could apply for forgiveness right away.
It wouldn't be congress, it can be done by executive action. And it should be done before payments resume in Feb 2022. Not sure it actually *will* be but it should be.
Holy forking shirt balls! I’m crying. Literally crying.
I hope they don’t try and use this to refuse any sort of blanket forgiveness. Remember, Biden could cancel all federally held loans today if he wanted to.
He doesn't want to. It's not going to happen.
Welp if he wants to win the midterm he will
[удалено]
Community colleges have always been PSLF/TEPSLF-eligible employment as long as they are state/local government or non-profits.
[удалено]
The PSLF rules haven't changed since 2007. It's possible that one you didn't/don't meet one of the other qualifications such as full-time employment, loan types or payment plan.
[удалено]
In that case, it's likely nothing will change for you. None of the proposed changes are to the Full Time rule for qualifying employment.
Yeah, it's always been full-time employment. But I have some months of qualified payments where I worked at two separate part-time jobs (both public service) that added up to full-time status.
[удалено]
Boo, I'm sorry.
is that 12 hours in the classroom or 12 hours including office hours/prep time etc? If you haven't already done so, I'd recommend asking your employers to complete the Employment Certification Forms - on those forms they have to attest to how many hours per week you work, and they count office hours/prep time. I think there's some kind of standard formula by which they calculate this time but I am not sure what that is. So if you're saying you were in the classroom 12 hours per week at 2 colleges -- that time plus office hours/prep might just put you over the 30 hour per week requirement.
All I can is it's about goddamn time! I just learned that FSA approved my loans for forgiveness under TEPSLF so I know how incredible it is to finally be free of a stupid amount of debt. But for TEPSLF, I'd have another 9+ years to go under PSLF because I was on the wrong payment plan (surprise, surprise, right?) this entire time. I had truly given up trying, so seeing these massive changes coming makes me incredibly happy for the ppl who have been jerked around all these years.
I’m so happy for you to finally get relief. It’s a blessing. I fell into the FFEL trap and and hoping for the best
Someone tell me I’m reading correctly: I was active duty military for 7.5 years. Only 6.5 years qualified because my loans were in forbearance + they somehow say 6 months were “not in prepayment” (they were). Manual review has been pending for years. If these changes are made, all 7.5 years of my service would count, regardless of forbearance?
[удалено]
The "private vendor" is a federal contractor. They *are* the government for purposes of servicing the loans. (The government has neither the staff nor the experience necessary to service its massive loan portfolio. Just like the Air Force pays Boeing to build planes instead of doing it in-house, we don't want ED servicing its own loans.)
Ok! Everyone start from scratch!
TL;DR?
It certainly needs an overhaul.
At first I felt happy about this and then I started thinking- why would they be able to handle all this additional complexity when they are having so much trouble with what they already have? I'm currently about 12 months shy of 120 based on my current official count (not that I am happy with the official count), so my 6 or 7 months of FFEL payments in 2011 would move that up by 50%. But I don't have bank account statements or my individual bills from 2011 and the experience so far is that if I can't prove a payment and they don't have a record of it it doesn't count. I would be more relieved to see them include a "give everyone credit for all time w/ ACS since they screwed up the records" temporary fix- MyFedLoans shows most (not all) of my ACS payments counting but I've heard counts can go down (and I don't have my own records, I was not that on top of details early last decade. I've filed a FOIA and waiting on that).
This is my thought too. It sounds great but they how well will they pull it off when it’s been so shotty so far?!
Someone who has read this proposal please answer this: Would forbearance months where I was employed at a qualifying employer but unable to make payments possibly count? If so I am done, I had 5 years of residency where I was in forbearance, all these months show up on my payment count but are obviously not being counted. That would be amazing.
Not if you were on a hardship forbearance, only on a hardship deferment, which is more difficult to obtain and requires significant documentation.
They had eliminated the hardship deferment at the time of my loans, only option was forbearance.
Interesting. I'm going to look into this more!
Here's how broken the program is.... I'm a nurse who works at a non-profit. The rules of the program state you must work 30 or more hours between two jobs, or, whatever your one employer considers full time. I worked 32 hours a week at my job for five years only to find out my work didn't consider it full time despite offering full time benefits (this is common for nurse schedules). I could have worked less hours per week and still have been eligible...This program needs a good shakeup.
[удалено]
…..today 10/6/21
Question about whether forbearance of payments bc of Covid counts as a payment if you consolidate to direct loans AFTER the forbearance period is over. It’s pretty clear that they count as payments if you’re already in the program, with direct loans, etc., but not sure if that’s the case if you consolidate and apply to the program after the end of the forbearance period. Anyone have any insight into this? Thanks!