Determining how often or when you need to submit PSLF paperwork is tricky.
This is one instance where the minimum requirements under the rules and the best practices are dramatically different.
This article will cover the technical requirements for employment certification and explain why a greater frequency is an excellent idea. I’ll also share a shortcut to simplify the PSLF paperwork.
The Technical Requirement: Only One PSLF Application is Required
Let’s start with the basics. Under the Public Service Loan Forgiveness (PSLF) rules, borrowers don’t need to submit paperwork until their ten years of the program have been completed.
However, waiting until the last second is a terrible idea. In fact, there is a good chance that your application will be denied, and your prior decade of work will not count. This is the sort of mistake that is life-changing. The cost could be well over $100,000, depending on your debt levels, and it could mean retirement is delayed or never happens.
Sherpa Tip: Waiting the full ten years can also mean that you have to work in the PSLF for some extra time. To qualify for PSLF, borrowers must be currently employed by a PSLF employer at the time they submit their application and at the time forgiveness is granted.
Waiting until the last second can delay your retirement or switch to the private sector. Worse yet, a mistake might mean you don’t qualify, even though you have made 120 certified payments.
What Makes the PSLF Documents so Important?
On the surface, the exact timing isn’t a big deal. It is just an employer certifying that their employee is working full-time in a public service position. Waiting a few months or even years to sign this simple form sounds harmless.
In reality, the value of documenting your work comes from the review that it triggers. When a borrower submits their PSLF application, the servicer updates the borrower’s count of certified payments. For a payment to be certified, the borrower needs to be at an eligible employer, but they also need to have eligible student loans and be on a qualified repayment plan. When the paperwork is submitted, the loan servicer performs a comprehensive review of the borrower’s account. If any of these eligibility requirements are not met, the time will not count.
Many borrowers mistakenly think they are on an eligible repayment plan. Some learn the hard way that they should have consolidated their loans first. Others believe they are on a qualifying repayment plan, but they are not. Outside of a limited, temporary fix, there is no way to correct these mistakes after the fact.
A borrower who waits ten years to submit jeopardizes all of that work. I’ve personally heard from many borrowers who had their servicer tell them they were on the right track but learned years later that they were not. Even though the servicer gave terrible advice, these borrowers are stuck starting from scratch on PSLF.
Completing the employer certification form is the best way to verify that you are making progress towards PSLF. Anything less is guessing and hoping.
The Best Practice: Why You Should Send in PSLF Paperwork Yearly
Despite its importance, it is easy to let sending in an employer certification fall through the cracks. Making submission a yearly habit ensures that any PSLF issues are quickly identified.
There are two times when there is a natural reminder to complete your PSLF records.
- Tax Season – Most Americans fill out their tax returns at the same time every year. Student loans are an important consideration at tax time. Completing the PSLF update adds one extra government form that needs to be filled out and filed during your tax prep.
- Income-Certification – The income-driven repayment plans that qualify for PSLF all require yearly income certification. When you certify your income, it makes sense to certify your employer at the same time.
Other Times to Submit a PSLF Application
In addition to the yearly submission of your employment, there are a few circumstances where immediately completing an application is smart.
- Starting a New Job – If you move to a new employer, you want to find out right away if that employer is eligible for PSLF. After a month or two on the job, complete the PSLF form and mail it in. Certifying just two months of work may not be much, but knowing that future months will count is a considerable value.
- Leaving Your Old Job – If you are about to change employers, it is essential to complete PSLF paperwork. The more time that passes, the harder it will be to complete. Getting help from HR is much easier when you work in the same office.
- Getting Married – This is especially important if marriage involves a name change. This is one of those things that shouldn’t make a difference, but because federal servicers are prone to making errors, it is a good idea to make sure that you don’t lose any progress.
- As You Near 120 Payments – Many borrowers don’t realize that 120 certified payments aren’t enough. The borrower must be employed by a PSLF employer at the time they apply for forgiveness and at the time the loans are forgiven. If you time things right, you won’t have to extend your term of employment to accommodate servicer processing times.
How Do I Find the Right Employer Certification Form, and Where Do I Send It?
The latest version of the PSLF Application can be found here.
Once the form is completed, borrowers should mail it to the following address:
U.S. Department of Education
MOHELA
633 Spirit Drive,
Chesterfield, MO 63005-1243
Before mailing in the form, I suggest keeping a copy on file at home. If the form gets lost or destroyed, having a copy is easier than trying to recreate the document from scratch.
Borrowers who already have their loans serviced by FedLoan Servicing can upload the PSLF form directly to MOHELA. Borrowers can also fax a completed form to 866-222-7060.
However, the best way to go through the application process is to use the PSLF Help Tool from the Department of Education. This shortcut will automatically generate the proper form, help borrowers identify eligible employers, and guide borrowers through the submission process.
Great article! I had a follow up question regarding payment counts.
My wife is on an Extended Graduated repayment plan, which we’ve been told does not qualify for PSLF as of 2024, but her payments since 2019 did qualify thanks to the one time payment count adjustment. Although we’ve been told her current payment plan won’t qualify for PSLF, Mohela shows her January payment as “eligible” pending employment verification (similar to her Nov and Dec payments since she last submitted a PSLF form in October).
Does the fact that Mohela shows these last three payments as eligible pending employment certification mean the payments will count toward PSLF? Would you advise submitting a new form ASAP in order to verify the employment and ensure these payments update from “eligible” to “qualifying”?
Similarly, I know the Extended Graduated plan qualifies for TEPSLF, but I’ve been told there’s no guaranty that program will still be around for 6 more years once my wife hits 120 payments. Do you have any insight on this? The one representative I spoke to at studentaid.gov said it’s been around for 5+ years and there’s no sign it will end anytime soon, but we are nervous making years of payments that only qualify for TEPSLF and not PSLF if the program will just go away in a few years and we lose all of that credit.
Thank you very much for your time and advice!
I think there are a couple important points to cover.
First, the Extended Graduated repayment plan will count toward PSLF and IDR forgiveness until the one-time payment account adjustment happens. I suspect you will want to sign up for SAVE as soon as possible.
TEPSLF stans for Temporary Expanded Public Service Loan Forgiveness, and Extended Graduated does count towards it, but it has limited funding, and once that funding runs out, you are out of luck. Because you can’t benefit from TEPSLF until you’ve reached the full 120 payments, betting on it is risky.
Have you estimated monthly SAVE payments? How does the estimated SAVE payment compare to your Extended Graduated Payment?
First off, thank you very much for the quick reply and detailed response!
I guess I was under the impression my wife had already benefited from the one-time account adjustment since Mohela is showing her past 3.5+ years of payments as “qualifying”. If I’m understanding you right, her current payment plan will continue to count until the one-time adjustment is complete for all borrowers? As you mention in your linked article, this timeline seems to keep pushing back as I see now studentaid.gov is saying “summer 2024”, which I did not previously see when I was do my research a few months ago.
I have a similar understanding of the TEPSLF program. It sounds like you agree it’s risky to bank on the program being around 6 years from now. That being said, I had not seen the $283M/$700M you reference in your article, that’s very interesting to read. Also – we did not submit an application prior to the 10/31/22 deadline. However, Mohela is showing the same payment count for PSLF and TEPSLF – maybe that’s incorrect since we didn’t apply in time?
We have looked into the IDR plans and unfortunately even the best one is double what her current Extended Graduated payment is. Our best route if we do have to change payments (which is sounds like you think we will once the one-time adjustment is complete) is the standard 10-year plan since we already have several years of payments complete.
So, if I’m understanding everything right we should continue to stay on our current Extended Graduated plan until at least this summer, maybe longer, if the one-time adjustment is pushed out further. Once that’s complete we will have to switch plans. My question is do we need to get credit for these current payments by verifying my wife’s employment before that adjustment is complete? Is there a downside to submitting a new PSLF form every three months instead of once a year, just to make sure the payment tracker is counting all of our payments?
Thanks again for your help!
Lots to cover here.
I’ll start with the easy one: I don’t see a harm in certifying employment more frequently. I suggest yearly and whenever you change jobs, but I don’t see a reason why you can’t go more frequently.
Given your high IDR payments, have you looked into filing taxes separately?
The deadline you are referencing in that article is for the Limited Waiver. There isn’t a deadline for TEPSLF, it is just a question of whether or not funding will run out before you can benefit.
Finally, as a more general thought, I’d encourage you to not rely too much on the “qualifying counts” on the mohela website. The thing that matters is certified payments and getting to 120. None of that time counts until it has been certified, and given all of the temporary programs and updates happening right now, the mohela estimates could be high or low.
Thank you again for the response, I appreciate your expertise and help talking through our options!
I’ll start with my main question (and concern) – what is the difference between “qualifying” and “certified” for payment counts? I’m a bit worried about your final comment. So far my wife has submitted only one PSLF form, back in Fall 2023, and after receiving a confirmation from Mohela (in Nov) that the form was reviewed her PSLF Payment Tracker on their website shows 47 qualifying payments. The studentaid.gov tracker shows the same thing. All of these payments were made on an Extended Graduated plan. Are you saying these may not actually qualify when her final review is performed after 120 payments are made? I was under the impression that since these were reviewed and deemed qualifying (thanks to the Limited Waiver/one-time payment count adjustment), they are locked in as “certified” for PSLF.
Since submitting the form last Fall, three additional payments were made under the same plan and Mohela is showing those as “eligible”, pending employment certification. That’s where I assumed these payments would continue to count until the Limited Waiver expires, which is estimated this summer. That’s why I was curious if it would be better to submit another application to get these newer payments verified (and locked in) before that expires and my wife’s repayment plan no longer counts towards PSLF (but will still count toward TEPSLF).
I’ve read through your article on filing taxes separately. As you discussed, using our 2022 tax return and filing separately results in the lowest repayment plan, which is SAVE. That plan is still more than the Extended Graduated plan, but not a huge increase. If we were to switch after filing 2023 taxes, even filing separately, the 10 year standard plan actually results in the lowest payment. The next best would be ICR but it’s more than the 10 year. Therefore, if I’m thinking of it correctly it seems we’re best to stay on our current plan as long as it continues to qualify (which I think it does for now?) and then switch to the 10 year plan, which isn’t impact by taxes I don’t believe.
Sorry for yet another long response, this is just such a confusing topic and I haven’t been able to get any help from either Mohela or studentaid.
It looks like Mohela has updated their interface and PSLF tracking since the last time I looked.
I think the best breakdown is available if you click on the show payment summary link. Eligible payments appears to be the total of qualifying/already certified, and the payments that haven’t been certified. In the current interface, qualifying and certified appear to mean the same thing.
I should note that these terms don’t have technical definitions by statute or in the CFR, it is just Mohela’s way of conveying to borrowers their progress. Ultimately, as long as you keep sending in employer certifications and certifying your progress, you should be fine.
To answer your last question, the 10-year plan will qualify for PSLF and if that offers a lower monthly payment than any of the IDR plans, it could be the best option.
Thank you for taking a look at Mohela’s new interface and confirming “qualifying” and “certified” mean the same thing.
I’ve appreciated the back and forth with you, I feel more confident in our plan moving forward than I had in the past, so thank you again for all of your help!
My daughter graduated in Spring 2022. She has been working for a public university since September 2022. She will start her student loan payments this fall. Will she still be able to count the 12 months she has already worked toward PSLF?
Thanks so much
Most of that time should count. The tricky part is that borrowers typically get a 6-month grace period after graduation, and that time does not count toward PSLF. However, once she was on the automatic Covid forbearance, that time will count.
That all said, the best way to verify this information is to have her send in an employment certification. This will give her an exact count and verify that she meets all of the PSLF requirements. I’d highly recommend taking this step as soon as possible.