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:
- 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.
- 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.
- 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.
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?
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.
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?
Hi Carol,
It sounds like you are asking about the one-time IDR count update. This article covers how the time is calculated and the steps required to benefit.