On April 19, 2022, the Department of Education announced a temporary program to update the IDR payment counts for many federal student loan borrowers.
The exact details, explained below, are a bit complicated. As a result, this monumental change might be missed by some borrowers.
What is so significant about the change?
Millions of federal borrowers just got closer to student loan forgiveness. The Department of Education estimates that 40,000 will receive forgiveness.
Updating IDR Payment Counts Fixes a Major Issue
To understand how the changes apply to your student loans, it is helpful to know why the changes were made.
Income-driven repayment plans like IBR, PAYE, and REPAYE help borrowers afford their monthly student loan payments, even if they have a large balance. Crucially, these plans also provide a path to debt freedom. Borrowers on IDR plans can have their debt forgiven after 20 or 25 years, depending on the plan.
The first income-driven repayment option was created in 1994. To this day, the representatives at many student loan call centers don’t fully understand how IDR works and how it can help borrowers. As a result, many borrowers have been given bad advice from their servicer over the past 30 years.
Some borrowers were placed on a deferment or forbearance when an IDR plan would have been a better choice. Others were enrolled in extended or graduated repayment plans instead of an IDR plan. Unfortunate advice like this caused borrowers to delay or completely miss out on student loan forgiveness.
Forbearances, Deferments, Extended, and Graduated Repayment
During this one-time update of borrower IDR count, many previously ineligible repayment plans and payment statuses will now get borrowers closer to the required 20 or 25 years worth of IDR payments.
Deferments — Previous periods of borrower deferments will get credit as IDR repayment time. The one exception is in-school deferments, as outlined below.
Forbearances — If a borrower has 12 consecutive months of forbearance, or a total of 36 months of forbearances, the borrower receives credit for IDR payments during this period.
All Repayment Plans — Borrowers who were “In Repayment” get credit as time towards IDR forgiveness, regardless of the repayment plan they were on.
Activity Before Consolidation — Historically, consolidating your loans meant “restarting the forgiveness clock.” Under the new policy, this time will get added as progress towards IDR forgiveness.
Important Note: The rules for IDR forgiveness have not changed. Instead, borrowers receive a one-time credit for previous periods that were not eligible.
Borrowers still need to enroll in an IDR plan if they want to earn additional progress toward loan forgiveness.
What Doesn’t Count Under the Updated Rules?
Most borrowers are likely to see their tally towards IDR forgiveness jump considerably.
However, a few exceptions will limit the benefit to some borrowers.
In-School Deferments — If you were on an in-school deferment, you will not receive credit for this time. Even if you made payments during school, the time does not count.
Grace Period — All borrowers receive a six-month grace period after finishing school before payments start. This time will not count towards IDR forgiveness.
FFEL Loans — The most significant exception is that borrowers with FFEL loans will not benefit from this program. However, it is possible to work around this issue. (see the next section)
Steps Borrowers Must Take
The good news for borrowers is that these updates happen automatically.
The one exception is commercially-held FFEL loans. If you have an FFEL loan, or a privately held Perkins or HEAL Loan, you should consolidate by December 31, 2023, which is the date the Department of Education expects to start updating the borrower counts.
Many borrowers delayed consolidating for fear of losing progress towards forgiveness. The new policy temporarily allows FFEL borrowers to consolidate without starting from the beginning. Better yet, it’s also a great opportunity for FFEL borrowers who are chasing PSLF.
IDR Count Adjustment Timeline
The Department of Education expects to complete the update of the IDR payment records at some point in 2024 for most borrowers.
However, it is worth noting that this update has already been pushed back multiple times from the originally planned date in January 2023, and it is possible that further delays will happen.
The one exception to this timeline is for borrowers who are nearing the number of payments required for IDR forgiveness. These borrowers should receive their update and details on forgiveness by the spring of 2023 according to the Department of Education. If you think you have already reached the 20 or 25 years necessary to earn IDR forgiveness under these new rules, now is the time to reach out to your servicer.
Timeline Adjustments: The multiple delays on this update are undoubtedly frustrating for borrowers, and this appears to be a lower-priority item from the Department of Education.
If there is good news in this situation, it is that the update may happen after the federal student loan repayment restart. This may increase the number of borrowers who research this issue and benefit from the program.
How to Find Your Payment Status History
Payment histories are notoriously difficult to track down. Loans often move from one servicer to another. Information sometimes gets lost in the transition.
Fortunately, studentaid.gov has records of your payment status history. To find these records:
- Log in to studentaid.gov.
- In the My Aid section of the dashboard, click on View Details.
- Next, scroll down to the loan breakdown at the bottom of the page.
- Click on the View Loans dropdown.
- This will pull up a list of your student loans.
- Select View Loan Details for the loan that you want to review.
- In the top section, there is a link for Loan Status History.
The loan status history should show periods of repayment, deferments, and forbearances.
37 thoughts on “How the Biden Administration is Updating IDR Payment Counts”
Curious your thoughts on this particular frequently asked question on the IDR page. In my situation, I had at undergrad FFEL loans (1999-2003) approx 60k that I have consolidated to direct government loan in order to take advantage of the one time recalculation. I also already have another direct government loan related to my MBA from 2011-2013. Approx 30k
Given this statement from the frequently asked questions, it almost makes me think I need another consolidation to consolidate both of my direct loans together so that my MBA will get potentially credited with more time., but then I’m also extending my undergrad loans from being forgiven at 20 years and making everything 25.
Wonder if there is a general rule about this particular FAQ. Do you offer consultations to look at loan details and offer assistance?
It looks like you intended to link to a specific question on the StudentAid FAQ, but I don’t see a link.
However, based on your question, I suspect I know what you are asking about. In your case, it could make sense to do a secondary consolidation in order to get all of the debt on the same forgiveness timeline.
Unfortunately, I’m not able to offer individual consultations due to limitations in my schedule. I have sent a number of borrowers to the Student Loan Planner, and this is the sort of thing they should be able to walk you through step by step if you are looking for an extra set of eyes.
I currently have 1 FFELP consolidation loan serviced by Nelnet and have been in repayment since 2003. I am on the standard repayment plan now and have been for quite some time, although my repayment status has changed over time. From what I am reading, it seems as though I cannot re-consolidate this loan to a Direct consolidation loan (because I don’t meet the specified criteria) and thus will not qualify for IDR forgiveness, is this true? My servicer has told me different things.
Based on the information you have shared here, it sounds like you could be a good candidate to consolidate under the one-time account adjustment.
What specified criteria is it that you feel you don’t meet?
It’s possible that you haven’t been in payment long enough to have already earned IDR forgiveness. However, consolidation potentially could move you much closer. Perhaps that is the confusion with what your servicer is telling you?
Thanks for the great info. The IDR adjustment is taking place via executive order, correct? I guess I am concerned that with the IDR adjustment taking place “sometime in 2024”, which probably means sometime in 2025, and with a potentially and likely new President being sworn in Jan 20, 2025, isn’t it possible that a new President slams the brakes on the IDR adjustment via another executive order? Thanks!
Great questions, CJ.
I don’t think this particular item is a formal executive order, but it is an action of the Department of Education under the supervision of the President. Notably, it is not happening because of a law passed by Congress and signed by the President.
The IDR adjustment has already been pushed back multiple times, so you are justified in your fear about it moving again. However, I suspect that the previous movement had more to do with the payment pause getting extended. It’s actually better for borrowers if the IDR update happens several months after repayment starts. There is a good chance that the update takes place as planned in early 2024. If nothing else, it will make many voters happy, which is something the President probably wants to do in an election year.
You are also right that student loans have become a political football. However, this isn’t something that a future President is likely to undo. Generally speaking, when the government confers a benfit like this, it is hard to retroactively change it. Additionally, things like the payment pause or $10,000 forgiveness plan are easy to understand and easier to argue. A one-time modification of IDR payment counts is a pretty complicated concept and the type of thing that is unlikely to get changed in the future.
That all said, it certinaly isn’t set in stone. Still, as someone who stands to benefit, I’m cautiously optimistic that it will happen.
Thanks so much for all your great advice. You are a blessing since there is “so much” conflicting info out there! Quick question: do you know if loans dispersed prior to 1994 will be included in the one time IDR loan forgiveness? The info online says that loans prior to that aren’t but it’s not clear as to whether that means dispersed or loans that have gone into repayment. I have loans from 1993 but they didn’t go in to repayment until 1998, so would they count?
I see why that sounds confusing Michelle. The loan from 1993 can still potentially benefit from the adjustment. However, periods of repayment before 1994 will not be included in the adjustment because the IDR program didn’t exist yet.
Is there a refund clause for payments made during this adjustment period? What if you pay off your loan during this timeline?
Borrowers often receive a refund if they receive forgiveness dating back to a specific date. The one exception would be for FFEL borrowers. Extra payments made before consolidation don’t get refunded.
However, if the loan gets paid off in full, you may not get a repayment history review, which would mean no forgiveness and no refund. Fortunately, you can ask for a refund on payments made during the pause.
I am trying to figure out if I should consolidate my remaining FFEL loans. I consolidated the higher interest rate FFEL loans with Mohela before the end of the temporary expanded pslf ended in 2022. I didn’t consolidate them all because I was worried that somehow something would go wrong and they wouldn’t get approved. I did get them forgiven! I have a few loans still with Navient and if I consolidate them with Mohela the interest rate will almost double. With that said, if I consolidate and my prior payments will go towards the pslf then it wouldn’t matter because it would be forgiven. I definitely have the 120 payments and employer approved but I just can’t figure out if I consolidated them if they would still count for the pslf. I have always had the IDR but not sure if I’ve had it for 20 years.
You will definitely want to check out the IDR Count Update that is scheduled to happen at the end of this year. Its got some language that will really help out FFEL borrowers chasing after PSLF.
Thanks from Ann for your reply on the spouse’s signature
I really appreciate it.
I am now preparing my IBR annual recertification request. My spouse and I file taxes as “Married filing separately”. I was surprised to learn that I must now ask my spouse to cosign my IDR request. He does not want to do so, so I have not completed the IDR request. I am not sure that I can say that I could not get access to income information my spouse. (Question 7, Section 4A), however. I also don’t understand why this is being asked of me since the instructions note that he will not be obligated pay my loan by cosigning my IDR application in any case. I would like to understand the point of this change, and so would he, but I have found nothing helpful on StudentAid.gov. Can you help. I would be very grateful.
I’ve got a few thoughts on this one. First, if your spouse refuses to share his income information or sign the form, it would seem to me that you cannot reasonably get access to that information.
Second, spousal income information is sometimes necessary for an IDR calculation. For example, if you enroll in the REPAYE plan, filing separately won’t make a difference. Notice how the IDR request form specifies that the spouse’s income information will only be used for REPAYE enrollment (see questions 19 and 20).
Finally, if you look at the spouse’s signature page, it says the following: “If you are married, your spouse is required to sign this form unless you are separated from your spouse or you’re unable to reasonably access your spouse’s income information.”
Best wishes to you!
Hi thanks for publishing this information -its very confusing. I currently have 2 Direct Consolidation Loans one subsidized and one unsubsidized through Mohela that have been in repayment since October 2002 – on the GRADUATED loan program.
Do I have to switch to a IDR program to qualify for the one-time IDR waiver or will my loans be considered automatically. I cant seem to get a straight answer on this.
That is a great question. If the loans are not FFEL or some other privately held loan, I don’t think you need to. HOWEVER, you should probably get enrolled in an IDR anyway. Your old graduated repayment plan payments will now count, but future graduated loan payments will not count. In other words, if you are pursuing or even considering chasing IDR forgiveness, it makes sense to get started on an IDR plan.
Note: I’m not suggesting that you should opt out of the Covid-19 payment pause. You can submit IDR paperwork today and request that the plan start once the payment pause is over. The entirety of the Covid-19 payment pause will also count towards IDR forgiveness.