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Does Deferment or Forbearance Time Count for Student Loan Forgiveness?

Time on a deferment or forbearance usually doesn’t count towards student loan forgiveness, but there is one massive exception to the rule and a couple temporary exceptions.

Written By: Michael P. Lux, Esq.

Last Updated:

Affiliate Disclosure and Integrity Pledge

Federal student loans have excellent perks like Public Service Loan Forgiveness (PSLF) and Income-Driven Repayment (IDR) Forgiveness. Borrowers who work for an eligible employer can have their student debt forgiven after just 10 years. Those who don’t work for a public interest employer have to wait for 20 years for forgiveness. Sadly, deferments and forbearances can complicate the student loan forgiveness clock.

In most cases, a deferment or a forbearance will pause the student loan forgiveness clock. However, there are several notable exceptions to this rule.

A recent reader email shows a classic example of how a break in payments can cause issues chasing student loan forgiveness.

The Reader Email about the Student Loan Forgiveness Clock and Forbearances

Reader Gene writes:

Over the last seven years, I have made about 80 PSLF qualifying payments. During that time, I was on three months of Administrative (processing) Forbearance and three months of Hardship Forbearance.  

Will the months of Administrative Forbearance or Hardship Forbearance count as qualifying payments?

Thank you!

Public Service Loan Forgiveness Basic Requirements

As seen in our detailed breakdown of the Basics and the Fine Print on Public Service Loan Forgiveness, time towards the required ten years, or 120 months, basically has three basic requirements:

  1. Eligible Loans – Not all federal loans are eligible. This includes certain Plus loans as well as FFELP loans. However, some loans can be made eligible through federal direct consolidation.
  2. Eligible Repayment Plan – Only certain repayment plans will count towards PSLF. The income-driven plans such as IBR, PAYE and REPAYE count, but the graduated and extended repayment plans are not eligible.
  3. Eligible Employer – Only employers that fall within the Department of Education’s definition of public service will count. This includes most government agencies and 501(c)(3) non-profits.

Because there is room for confusion within these requirements for PSLF, we suggest sending in an employment certification form every year to your federal servicer. This is the best way to track progress and ensure that you meet all of the necessary requirements.

Is my employer eligible for Public Service Loan Forgiveness? The exact eligibility requirements can be a bit complicated. This article breaks down the criteria for eligibility. Additionally, the Department of Education recently created the PSLF Help Tool to assist with the verification process.

Forbearances and Deferments and Time Towards Student Loan Forgiveness

Unfortunately for Gene, deferments, and forbearances usually do not count towards the required 120 payments for Public Service Loan Forgiveness. Additionally, this time will not be eligible for the 20 or 25-year forgiveness programs under an Income-Driven Repayment Plan.

This is because a forbearance or deferment means that the borrower made no payment under an eligible repayment plan. (Note: $0 payments on an income-driven repayment plan can count.)

This rule can be incredibly frustrating in Gene’s case because he spent three months on an administrative forbearance. Administrative forbearances are usually the result of slow processing or errors on the part of the student loan servicer.  Sadly, there is no mechanism in place to get these months to count towards PSLF.

Good News for Gene: The rules haven’t changed, but a new temporary exception will help Gene and millions of other borrowers.

Scroll down to the temporary exceptions to learn more.

The Massive Exception to the Rule

As part of the Covid-19 economic relief, all federal student loan payments were paused, and interest rates were set to zero.

Fortunately for borrowers, this deferment of payments will count towards Public Service Loan Forgiveness and Income-Driven Loan Forgiveness.

Borrowers don’t need to make extra payments for the time to count towards loan forgiveness.

The Temporary Exceptions

In October 2021, the Department of Education announced rules for temporary expanded Public Service Loan Forgiveness.

Under the expanded rules, active duty military service counts towards PSLF, even if the borrower was on a military deferment.

There is a strong possibility that this exception will become a permanent PSLF rule, but for now, it ends on October 31, 2022. Borrowers who were on a deferment during active duty military service should make sure that their certified payment count is updated to include this time.

In April of 2022, the Department of Education announced an update to the rules for calculating progress towards forgiveness. Previous periods of deferments and forbearances may now count towards forgiveness under this one-time update.

Avoiding PSLF delays due to Forbearances and Deferments

Borrowers working towards PSLF should all be on Income-Driven Repayment (IDR) plans.

One of the key requirements to stay enrolled in the IDR plans is to certify your income yearly. Missing certification deadlines can cause delays in enrollment and force a forbearance or deferment. It can also cause an interest capitalization, which can be expensive.

Bottom Line

Federal student loans can be forgiven after ten years of public service or 20 years worth of IDR payments. Unfortunately, there are other hoops that borrowers have to jump through.

If you are working towards student loan forgiveness but your loans are on a deferment or a forbearance, the clock is likely paused.

About the Author

Student loan expert Michael Lux is a licensed attorney and the founder of The Student Loan Sherpa. He has helped borrowers navigate life with student debt since 2013.

Insight from Michael has been featured in US News & World Report, Forbes, The Wall Street Journal, and numerous other online and print publications.

Michael is available for speaking engagements and to respond to press inquiries.

82 thoughts on “Does Deferment or Forbearance Time Count for Student Loan Forgiveness?”

  1. I have 3 loans (payment counts summarized below), I have to consolidate before the end of the year as none are on income driven repayment plans…trying to figure out consolidation, and also trying to determine which payments will be counted under the IDR adjustment.

    ParentPlus: 50/120 (71 deferment/forbearance not yet counted broken down as follows…1 forbearance, 10 deferments, 7 forbearance all in a row. then 53 deferments in a row)

    DL Subsidized: 98/120 (22 deferment/forbearance not yet counted broken down as follows…7 forbearance, 10 deferments, 7 forbearance all in a row.)

    DL Unsubsidized: 98/120 (22 deferment/forbearance not yet counted broken down as follows…7 forbearance, 10 deferments, 7 forbearance all in a row.)

    The deferment times for the 2 DL’s are not for in-school. they are hardship periods so I am not sure why they are flip flopped back & forth between forbearance & deferment. The Parent Plus deferments are a combination of my son being in school, plus hardships. Of course there is not a 12 month consecutive forbearance period nor is there a 36 month cumulative forbearance period so am I just out of luck on all 3?

    Reply
  2. I have five graduate school loans, each with a different interest rate ranging from about 5.5% to close to 8%. I am enrolled in SAVE and auto-debit. Will auto-debit pay off each loan pro-rata? Is it possible to target the higher interest rate loans for repayment first?

    Reply
  3. Entered active duty military 2010, left in 2021. Direct loans were in deferment from 2010-2014. Payments resumed in 2015 up until Covid-19 forbearance in 2020. Under expanded rules for PSFL in 2022, will years 2010-11-12-13-14 count as qualifying payments. They are currently under review. Current qualifying payments total are 127. Will those early years in deferment count as qualifying payments, and if they do, will my qualifying payments total go from 127 + 48 months to 175?

    Reply
  4. Micheal-
    My basic question is “What type of forbearances are not counted under the temporary waiver”. Here is my situation:
    I have worked and continue to work for a qualified employer since 2009. I put in my PSLF application which was accepted and my account has been transferred to Mohila but I have yet to get an updated count from them. I consolidated my loans in 2013 and as far as I can estimate I’ve made 57 payments with other the other months in forbearance (27 months non-consecutive). I was in repayment status when the Covid payment pause started.
    The 57 payments do not include the covid months which I will estimate to be 39 months assuming the period ends in June of 2023. Based on that I figure 57 + 39 = 96 payments. However, if I were able to count the 27 months in forbearance I would be over the required 120 payment count at about 123. In your opinion, under the temporary rules do you think this loan would be forgiven?

    Reply
    • It definitely sounds possible from the numbers you are describing. My suggestion would be to put together a month-by-month accounting of your status and what you think should count. Then call MOHELA and ask them what their tabulation is. If the numbers don’t match, go through your month-by-month records to figure out any discrepancies. I’d encourage you to do this well before the restart, because once the first bills get mailed out, it will be very hard to get help from your servicer.

      Reply
      • Yes thay are still tabulating so I have to wait for them to notify me. I was trying to take an educated guess. There were also some payments before 2013 but I don’t have data on those

    • Hey Daniel, do you have to have been on forbearance consecutively to qualify? I keep reading something like if you were in forbearance for 12 consecutive months or more. But what if those were not consecutive but like 6 months or 3 months at a time?

      Reply
  5. I was told by Mohela that if deferments wouldn’t count, and could be used against me. My loans are currently with Mohela with a zero balance. But was also told that isn’t correct. I’m confused. Can you provide additional insight on how deferments effect the forgiveness process

    Reply
  6. I want to make sure that the Covid months of forbearance count as $0.00 payments. I meet all three requirements: direct loans, working for government the whole time, in IBR plan. But when I go to payment history on mohela it says “no payments have posted in the last 36 months”. Shouldn’t it have a history of $0.00 for the last 36 months? Are those months not counting? I submitted my Pslf application in October and it’s still processing. I read that Mohela will inform me how many qualifying payments I made once my application is accepted so maybe I have to wait until then for the payment history of 36 $0 payments to show up. Nervously trying to figure this out!

    Reply
  7. So, a person who is in “administrative forbearance” is the SAME as someone in “COVID forbearance” during this special PSLF waiver program?

    They are both treated equally towards the special PSLF waiver program and add to the 120 payment periods? Is this correct and true? Thank you Sir.

    Reply
      • Thank you Sir.

        To clarify, if the person has met all the other requirements for the special waiver PSFL program:

        If a person is in “administrative forbearance,” with Mohela, does that count for PSFL waiver program purposes towards the 120 count for forgiveness? Or does a “COVID forbearance” only count towards the 120 count for student loan debt forgiveness. I assume there are many different styles of “forbearance”. During this very special time, does the “administrative forbearance” count towards the 120 count?

        Thank you Sir.

  8. I think it’s absolutely insane that periods of **mandatory** bankruptcy forbearance do not count, despite whether or not any payments were received. They say that the reason they don’t is ‘you’re not in repayment’ but here are some facts: I filed for Chapter 13 bankruptcy. In my state, the program is 3 years long. Navient/Sallie Mae filed a **claim** to get some of the money. The court gave me a monthly amount that I had to pay for the entire 3 years. Sallie Mae/Navient took that money because they FILED a claim (why would they file a claim if I wasn’t in repayment??). They took that money and it counts for nothing. I was also in a $0 IDR at the time of filing bankruptcy because of my low income. I was also a full-time public servant so despite all of the payments they received because they filed a claim (obviously refuting the claim I wasn’t in repayment), they completely left me stranded and despite being in my 17th year of public service and still have loans from the 90s, they still claim I have 3 years left to qualify for the 10 years (supposedly) PSLF program.

    Reply
    • I was hoping someone would respond to this because it’s nonsensical to me…. You made payments but they don’t count because you’re not in repayment….my head hurts

      Reply
  9. Thank you for simplifying the web of student loan chaos! I began teaching in August 2013 but was under deferment, based on the advice of the loan specialist, until January 2014. Is there any way to make payments now for those months of service so I can achieve loan forgiveness in August 2023, or go back and ask for teacher deferment during that time?
    Thank you!

    Reply
  10. I’m also in the same boat as others in this thread. I have most of my Direct Loan documents from 2009-2010 where I was on forebearance with a reduced payment. So, from what I can tell, forebearance does not always mean ‘no payment’ status; it could mean ‘reduced’ payment status and in that case, if on a reduced payment status, my question is will that month count toward PSLF? I sure hope so. I was just trying to keep from going in default which would have opened the door to more problems and money.

    Reply
    • This is a great question, and I’m not able to offer a definitive answer, but I will share my thoughts and what I’ve learned.

      For starters, the Department of Education has not released any specific guidance on payments made as part of a reduced payment forbearance. Because those loans were not technically in repayment status, my expectation is that those months will not count towards PSLF.

      That said, things are still in flux with the limited waiver. The initial review is still ongoing. This might be an issue where reaching out to your elected officials can make a difference.

      Reply
  11. Hi Michael – If a person’s IBR was surely $0 based on salary and dependents, but the loans were in defferrement because the person was told that their employment would not qualify because they are a paralegal and not an attorney for the government, do you think there would be an exception where the payments would have been zero whether they were in defferrment or not? The person should have been making the payments as they would have been $0.00 under the IBR. But they didn’t. Any advice is helpful.

    Reply
  12. Hello Micheal,
    Thank you for all your hard work, expertise and information. My question is about the 25 year cancelation and when the clock starts to run. I was just on the official government student loan page https://studentaid.gov/manage-loans/repayment/plans/income-driven

    and if I am reading it correctly, a specific passage, which I will insert below appears to say that any deferment, forbearance( which results in a zero dollar payment) or repayment plan counts toward the 25 year cancelation.
    Do you agree with my reading of this paragraph?

    “Under all four plans, any remaining loan balance is forgiven if your federal student loans aren’t fully repaid at the end of the repayment period. For any income-driven repayment plan, periods of economic hardship deferment, periods of repayment under certain other repayment plans, and periods when your required payment is zero will count toward your total repayment period. Whether you will have a balance left to be forgiven at the end of your repayment period depends on a number of factors, such as how quickly your income rises and how large your income is relative to your debt. Because of these factors, you may fully repay your loan before the end of your repayment period. Your loan servicer will track your qualifying monthly payments and years of repayment and will notify you when you are getting close to the point when you would qualify for forgiveness of any remaining loan balance.”

    Thank you in advance for answering this because this is a huge question for me because I have a combination of economic hardship, forbearance, deferment and IBR since 1998.
    Thank you again
    Jim

    Reply
    • Zero dollar payments on IDR plans like IBR all count towards forgiveness. As for forbearances and deferments, they usually don’t count, outside of the exceptions mentioned in this article.

      I’d encourage you to reach out to your servicer for an updated count on where you stand.

      Reply
      • Thank you Michael
        So based on your answer the language I found does not change your opinion as to when forbearance and deferment count. Can you explain your reasoning to me as to why you believe that the language, specifically ” For any income-driven repayment plan, periods of economic hardship deferment, periods of repayment under certain other repayment plans, and periods when your required payment is zero will count toward your total repayment period” does add to the listed exceptions to when deferment and forbearance counts.
        Thank you again

  13. If I graduated in June 2021 and immediately started working in public service and applied for PSLF but did not start making because of the Covid deferment. I still have made now payments because of the current deferement. As long as I begin making payments when the deferement period ends will I receive credit for monthly payments through June 2021 till the deferment period ends?

    Reply
    • That is a really tricky question Tom. If they classify you as being on your six-month grace period, that time may not count. However, once you are officially on the Covid-19 payment pause, that time should count. Based on the info you provided, I’d expect that the latest that you would start getting credit would be six months after school finished.

      Reply
  14. I called and after a lengthy wait, I was finally connected to a representative for the PSLF/TEPSLF program. What I was told was counter to what the limited waiver announcement is saying. When I asked why some of my payments aren’t listed at all, (I’m not seeing any payments made prior to 2017 and I started making payments in 2011), I was told my previous payments did not qualify. This is what the recent PSLF waiver announcement says – ” Past periods of repayment will now count regardless of whether you made a payment, made that payment on time, for the full amount due, on a qualifying repayment plan”. It appears the federal student loan people are still blowing smoke and playing the shell game.

    Reply
  15. By some miracle, back in 2012, I managed to do everything right to go on PSLF—I moved all my loans from Navient, went on IBR, and certified employment every year. In those days, it was impossible to know whether I did the right thing or not because the process was a tangled one, and the right hand didn’t know what the left was doing every time I called. At any rate, I’ve made regular student loan payments in the 20 years I have worked in public service. On Nov. 16, I was forgiven the balance of my loans. A week later, I received 29 credits to my bank account in the amount of the student loan payments that I made over the 10 year mark. I’m not sure where they came up with the 29 but 2007-2017 got me ten years, and they refunded everything from later 2017 to the start of the pandemic in March 2020, when I made my last payment. I have not heard of anyone else getting refunds. Did this really just happen to me.

    Reply
  16. Similar to a previous comment, I received the following email from my loan provider:

    “Based on our estimates and your records, your Direct Consolidation Loan’s payment count for PSLF should go up by at least 12 qualifying payments.

    We based this estimate on your already approved periods of qualifying employment on file.”

    Here’s the thing – I’ve never made any actual payments that weren’t already counted. The most recent 6 months’ of payments aren’t in my payment count yet because I had not yet recertified that “period of qualifying employment.”

    What I DO have are many months (years, actually) of forbearance during which I was working in public service but not making any payments. Since the email gave that estimate based on “already approved qualifying employment on file”…I can’t help but think the administration will just consider all forbearance periods as a ‘newly-qualified payment’ under the temporary waiver…especially since the email indicates “[previously disqualified] payments will count even if you didn’t pay the full amount or on-time.”
    So…how far off do you think I might be? I get it, forbearances aren’t payments but….

    Reply
    • At this point, I think we can only guess. Your theory could be right, but there are many other possible explanations: maybe you were paying $0 per month on an IDR plan instead of on a forbearance, maybe they made an error, maybe you had an FFEL loan that previously didn’t count but now it will… the list goes on.

      Hopefully, when they provide you with an update they will also explain why.

      Reply
  17. Hi,
    I have taught in Title I public schools for 25 years and my loans fell through every crack imaginable during this time for various forms of forgiveness and cancellation, even the 5K teacher cancellation because of my title as elementary teacher/media specialist even though media specialists are teachers and taught daily, craziness! My question however is during the timeframe from 2008 – 2020 I stayed under forbearance because we could not afford the minimum payments for any of the plans we qualified for. We also slipped through the crack on IBR adjustments. The Dept of Ed was glad to continue my forbearance as long as I was making these payments. Anyway for 12 years even though under forbearance I continued to make consistent monthly payments from $175 – 225 per month without ever missing. The verbiage in the new description I am reading says any payment, regardless of if full or late, qualifies. I am terrified I have made 12 years of payments that will go down the drain! Any input or thoughts on this? Also I have submitted my form recently but who should I reach out to so that this topic is covered during refinements to the bill? I’m in Georgia.

    Reply
    • Hi Jan,

      I have a couple of thoughts on your situation. First, I think you might want to double-check your status for the 12 years you said you were in a forbearance. It would be highly unusual for any servicer to grant a forbearance that long, and a forbearance means that you don’t have to make a payment. If you had a monthly bill, you were probably on a repayment plan of some sort. I’d suggest a call to your loan servicer to investigate this issue further.

      If you are worried about future student loan legislation, I’d encourage you to reach out to your elected representatives. An email or a phone call could encourage both of your Senators to refine future bills.

      Reply
  18. Hi Michael. During recent 10/6 Brd of Ed virtual rulemaking meeting, the committee member representing State Attorney General Offices requested that the rulemaking committee include in the regs new PSLF language that considered well-documented and widespread steering by servicers of borrowers into forbearance rather than directing borrowers to financially more appropriate plans ie income based. The speaker for AG’s supported his claim by also listing 7 states where servicers were/are being sued (for $$ lining their pockets) by state regulators on this specific issue. My question…since this bad actor actions are so widespread nationwide and we now have a high authority on the committee ducumenting and officially making this case, do you think this may force the Dept of Ed to ultimately open the door and carte blanche approve all past forbearances just like they recently did for military service members?

    Reply
    • Thats a great question Rich.

      On one hand, I think it is a very real possibility. We have now seen Congress through TEPSLF and the President through the new limited waiver make efforts to help borrowers qualify for PSLF who were given bad information from their loan servicer.

      On the other hand, the limited waiver comes from President’s CARES Act authority, so it might be difficult for the President to unilaterally start counting forbearance time. This issue was known previously, and the administration chose not to help the borrowers with this particular issue.

      However, we are now in the rule-making process for permanent rules and changes to PSLF. Clearly there is still some interest in including people on forbearances. Its possible it will change, but I think its unlikely.

      Reply
  19. I was in a federal chapter 13 bankruptcy repayment plan for five years and made substantial payments on my student loans during that time. I was also placed in administrative forbearance. I am praying that these payment will count towards my public service student loan forgiveness, it would put me way over the required 120 payments. I am waiting to see what the additional rulemaking will take into account. I personally feel that if you make a payment (especially a large payments), even if you are in forbearance or deferment, the payment should count.

    Reply
  20. I was in grad school at least half time for several years during which my loans were automatically placed in deferment. I continued to be employed full-time in a non-military public sector position and I continued to make monthly payments. However, the payments made during this time were deemed ineligible for PSLF because: “You Do Not Have A Bill Due For This Payment Period.” Will those payments be eligible under the new rules announced in October 2021? I didn’t ask for the loans to be placed in deferment.

    Reply
    • Hi Ben,

      I suspect those months of public service work won’t count. As you noted, that deferment is automatic and borrowers have to file a form to end the in-school deferment.

      Additionally, I don’t see it as a new exception under the new October 2021 rules. However, they are still in the rulemaking process for new permanent PSLF rules, and it is possible that future changes might allow that time to count. You might consider reaching out to your elected representative to discuss the issue.

      That all being said, my opinion would be that it is unlikely this time will count towards PSLF

      Reply
      • I could be wrong here, and speaking off the cuff. But payments not made under deferment or forbearance don’t normally count towards PSLF. But the reason they don’t count is because they are not an eligible repayment plan. However, under the new guidelines of the temporarily expanded PSLF, they are now counting payments regardless of the repayment plan.

        I have used forbearances and deferments in the past, and I received an email from the Education Dept. that said my qualifying payment count was going up by “at least 42 payments” which would put me over the 120, and should make me eligible for forgiveness.

        I guess I’m looking for some confirmation, or reasons how/why I’m wrong or misunderstanding.

        Thanks!

      • Hi Kyle,

        Let me start by saying congrats!! It sounds like you are about to get PSLF under the new limited waiver. That must be a huge shock and a relief.

        As for your question, you are right that only certain repayment plans are eligible for PSLF. For example, the IBR plan is eligible, but the graduated repayment plan is not. You are also correct in saying that the recent news means that borrowers who were on the wrong repayment plan may now have those payments count towards PLSF.

        I think where you might be confused is on the deferment or forbearance status. If your loans are deferred, or in a forbearance, you don’t have to make payments. Thus the problem isn’t an ineligible repayment plan. The problem is that you are not making payments.

        Hopefully that all makes sense,

        Michael

      • As I said in my previous response, the email told me my qualifying payments would go up by at least 42 payments. These are the same number of payments that were due while I was in deferment.

        Based on the studentaid.gov website, deferment/forbearance are both viewed as “repayment plans”, but simply the amount due is $0. I think this is the way the Biden administration is trying to help people who have either suffered and had to use voluntary deferment/forbearance, and also casting a wide enough net to account for all of the people put in administrative deferments/forbearances.

        Either way, I submitted a PSLF Employment Certification form, so for now its just a waiting game for them to update my number of qualifying payments.

        Thanks!

        – Kyle

  21. FedLoan took several months to calculate and re-calculate my payment a couple different times a few years ago. They kept coming up with payments that were much higher (about as high as my standard payment, which is >$2000), so of course I didn’t/couldn’t pay these. I had to choose whether to pay that much or go into forbearance. I chose forbearance, and this ended up putting me at least 6 months behind on number of payments counting toward forgiveness since they took their sweet time. Needless to say, I was on the phone with FedLoan MULTIPLE times to try and straighten it out. Finally, I was able to talk to a competent rep, and he told me that I could file to have these months count since it was not my fault that they screwed up the payment calculation and delayed it. Of course, I was unable to write down what he called it at the time, and I cannot for the life of me remember the term he used. When I asked a different rep a couple years later, she said there was no such thing and that these months wouldn’t count. The prior rep had said that they had done it before for cases such as this. Have you heard of this in the past? I need help! Thanks!

    Reply
    • It sounds like you were put on an administrative forbearance. I would be surprised if you were able to get these months to count, but many borrowers have had a similar problem, and counting this time would be the right thing to do.

      Reply
  22. I have been paying student loans since 1996. I was on an Income Based repayment plan the entire time. (I switched to REPAYE in 2015). For much of 1996-2015 I was allowed to make reduced payments. These were lower than the IBR payment should have been, I believe. But I was making payments and my loans were never in default. Do reduced payment forebearances still count towards discharge in 25 years? If so, this should be my year, I think? Twenty-one of those years were in public service, but I retired roughly three months short of having 10 years since the institution of the PSLF program so I am not eligible for that one, I think?

    Reply

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