In article comments and reader emails, many of you have expressed a concern that changing to the new SAVE plan will mean starting over on the path to student loan forgiveness.
The good news is that it won’t.
If you are enrolled in an IDR plan, you can switch to SAVE and resume where you left off.
Concerns about Restarting the Forgiveness Clock by Changing Repayment Plans
Many borrowers have been bitten by following someone else’s guidance only to learn that it was wrong. It happens with friends, and it happens with servicers. The experience is frustrating and a tough pill to swallow.
For some people, the introduction of this article is sufficient. Others will justifiably want more assurance.
I can’t just write a rule into existence. I’m not your attorney, and the things written on this site won’t influence what the Department of Education does when it processes your request for forgiveness.
One extremely polite reader said she appreciated my help but noted that even though she read that she wouldn’t restart progress on this site, she couldn’t find confirmation on studentaid.gov. She wanted something to put her mind at ease.
I try to always link to the appropriate rules and resources, but in this instance, there isn’t an easy way to show my work. Studentaid.gov doesn’t have an explicit statement that changing repayment plans won’t restart IDR forgiveness.
For the borrowers worried that changing repayment plans will restart forgiveness, I’ll show my work. Hopefully, it will provide peace of mind to some of you.
The Code of Federal Regulations on Switching Repayment Plans
Servicers and studentaid.gov don’t get the final says on student loan rules.
When these sources offer conflicting or confusing information, I turn to the Code of Federal Regulations for clarity.
Given that the CFR is a legal document, the language often seems convoluted or confusing. The rule on switching repayment plans is no different.
However, if you wish to venture into that area, check out Code of Federal Regulations § 685.209(c)(5)(v).
It specifies that the starting point for the 20 or 25 years required for forgiveness goes back to the earliest starting point on the IBR, ICR, or PAYE plans.
Eagle-eyed readers may note that the regulation discusses REPAYE and not SAVE. However, SAVE won’t be fully implemented until July 1, 2024. Until then, the official rules will list the technical name of the plan, which is still REPAYE.
IDR Forgiveness vs. Specific Plan Forgiveness
A less technical way of looking at this question is also available.
If we look at various policies on studentaid.gov, they usually discuss IDR forgiveness generally. For example, in early 2024, the Department of Education will update IDR payment counts.
In other words, the IDR count is the number that matters.
PAYE, IBR, and REPAYE/SAVE may have different rules regarding IDR counts required before forgiveness, but they still operate from the same IDR count rules.
If you had separate PAYE counts and IBR counts, changing plans might risk wasting that progress. However, the Department of Education uses IDR counts to track this progress.
Restarting Payment Counts When Switching Doesn’t Make Sense
Sometimes, when trying to make sense of one rule, it helps to look at another rule.
One of the new rules on SAVE is that borrowers cannot sign up for IBR after they have been on SAVE for 60 months or more, starting July 1, 2024.
Why have this rule?
The Department of Education’s commentary on the new rules for REPAYE/SAVE noted that such a limitation was necessary to prevent borrowers from signing up for lower payments on REPAYE/SAVE and then getting forgiveness immediately by switching back to IBR.
If switching repayment plans restarted progress toward forgiveness, this rule wouldn’t be necessary.
Final Thought: Continue to Seek Verification
I know many of you have struggled to track down answers to your student loan questions. Sometimes two different people from the same servicer will give two different answers. It’s frustrating.
If you see something on this site that you don’t understand or can’t verify on your own, feel free to ask.
It helps me make the site a better resource, and hopefully, I can share some information that gives you some peace of mind.
I have seen a few sources that have indicated that switching to the SAVE plan (from the IBR, in my case) *will* result in forgiveness progress being reset, if the switch is made prior to 7/1/24, but as near as I can tell, these sources keep referring to “consolidating” into a SAVE plan, rather than “switching” to a SAVE plan. Is this is meaningful distinction? My student loan balance is about 20 times what I make per year, which means that I make less per year than the *interest* on my student loan. As such, forgiveness is the only path I have to getting out from under it. I am at about 12 out of 25 years toward forgiveness, and I’m terrified of losing that progress.
On a side note, it would be nice to see an article about why these are the only loans you can’t dissolve through bankruptcy. Con men and charlatans can do outright malicious things and get off scot-free by declaring bankruptcy, but so many of us are stuck under crippling debt for life because we made the naive mistake of listening to everyone tell us that higher education was the path to financial well-being in our teens and early 20s.
Sources:
https://www.investopedia.com/new-repayment-plans-could-be-saving-grace-for-stretched-student-loan-borrowers-7974644#citation-3
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/idrfactsheetfinal.pdf
The switching to SAVE and consolidating into a SAVE plan is a very meaningful difference.
This article talks about switching from an IDR plan like IBR to the SAVE plan. In most cases, consolidation is not a required step.
However, some loans are not eligible for the SAVE plan, such as FFEL loans. These loans can get consolidated into a federal direct loan, which is eligible for the SAVE plan. If you are in this category, you will definitely want to consolidate before the 12/31/23 deadline. This article explains the timeline and what happens to payment counts when you consolidate into a new loan.
My loans are all entirely federal direct loans, and according to my servicer (Mohela) they are all eligible for the SAVE plan already.
So, if I understand correctly, no consolidation is necessary for switching from IBR to SAVE, which in turn means that I could switch at any point in time (prior to or after 12/31/23 would make no difference), and no progress would be lost on forgiveness.
Unfortunately because I have an older IBR, all of the interest currently accrued will apparently be capitalized, but then further interest would not accumulate as long as I’m making the minimum monthly payments. (I was actually originally told by Mohela that it would *not* capitalize if switching from IBR to SAVE, but many people have reported on various forums and Reddit threads that theirs did when they made the switch.)
Your understanding of the situation appears to be correct. Switching from IBR to SAVE only requires consoldiation for certain loan types, such as FFEL.
The interest will also be capitalized when you switch. That is required by statute.
I am on the standard graduated repayment plan right now. Do I have to switch to a different plan to have my years of payment counted toward the 20-25 years forgiveness? If I do will my years of payment start over or will it still count towards that? I have been paying for them since 2009.
Great questions here.
There are a couple of things I’d like to put on your radar. First, at some point next year, they will be updating IDR payment counts. For you, it means your years on the graduated repayment plan will count toward the 20-25 years for forgiveness.
However, to finish the remaining 20-25 years, you will need to sign up for an IDR plan, like SAVE. The good news is that switching to SAVE will not restart your progress.
Thank you for all your help and clarity. My loan has been sold to so many different lenders, that I have been having a hard time following them to confirm they are properly keeping track of my counts. I am currently on the IDR plan. I graduated (undergrad) in 2009 and have kept up on making sure I am current. Currently my loan is with Mohela and I cannot get anyone one the line. Is there somewhere I can look to see where they have my count so I can make sure it’s being tracked properly?
There really isn’t a good place for the count. Right now the best you can do is to pull your records from studentaid.gov. You won’t see payment amounts, but you will see periods of repayment, forbearances, etc.
Then you can compare those records to the IDR Count Update rules to see where you stand. Once the IDR count update is complete, which should happen in early 2024, I suspect they will make an updated count much easier to find.
Thank you so much for this information.
I spent some time on the studentgov site (prior to seeing your reply) and they had my forgiveness eligibility date as 2038, which makes no sense as I started paying my loans back in 2010. (I have never defaulted on payment.) Which is why I was asking about the count tracker. I will check out the information you shared above. Thank you.
One more question, please: Is the SAVE plan also considered an IDR? I graduated in 2009 as an undergrad and have been on the IDR since 2010. What I still owe (esp compared to what I borrowed) is a ridiculously large number—upwards of $70k. (I make less than that a year.) I am crossing my fingers and chasing forgiveness at this point. I switched over to the SAVE plan but I am very nervous that it is going to mess with my 20 year forgiveness count down. I’ve read your blogs of the comparisons between IDR AND SAVE, but they seem to always refer to graduate loans or new borrowers. Given what i’ve shared with you, is the SAVE plan safe for me?
The SAVE plan is absolutely an IDR plan. It was designed to pretty much replace the other IDR plans. For the vast majority of borrowers it is the best IDR option. Given that you only have undergraduate loans, it is almost certianly the best IDR option available.
Wonderful. Thank you so much for your time and insight. This website has been a HUGE help during this process.
Thanks for this article Michael! I’m currently on PAYE with graduate student loans. This plan has a 20 year forgiveness date. Would switching to the new SAVE plan add 5 years to the forgiveness date? I’ve been paying for 8 years FWIW. I can’t find anything related to that.
Your timing on this question couldn’t be better Matt. I’ve just written an article covering the SAVE vs PAYE question for borrowers with graduate debt.
Thank you for this article. I have been making student loan payments for about 14 years now through Income Based Repayment. My balance is supposed to be forgiven after 25 years of payments I believe. I found a few of the statements in the article a little confusing but it sounds as though it’s fairly safe to assume that if I switch from IBR to the SAVE plan, that my 14 years of repayment won’t reset to zero. Is this correct? I tried reaching out to Nelnet with this question through a message on their website a few weeks back and have not heard back.
I think your understanding of the article is correct.
However, I have to be very careful about making promises to individual borrowers about their debt. I don’t have your file, and I can’t pull your records. Your servicer can. I try to lay out all of the facts available so that you can have productive conversations with your loan servicer.
In this article you mention the 20 yr vs 25 yr rule, which I have seen a lot of conflicting and misleading information about when it comes to IDR forgiveness. Can you clarify what the actual rules are? For instance, I’ve been consolidated and in repayment for 21 years total. I graduated (undergrad) in May 2002 and began repayment 6 months later, but I was never informed about IDR plans at that time. I’m one of the 800k people who was recently notified that due to the one-time adjustment, I qualified for forgiveness. Is that actually possible if most of my time in repayment was on the standard graduated repayment plan and/or in forbearance?
The 20 vs 25-year rule comes down to a couple of issues. On some repayment plans, such as PAYE, all borrowers get IDR forgiveness after 20 years. On others, such as ICR, all borrowers get IDR forgiveness after 25 years. On other plans, such as REPAYE/SAVE, borrowers who have graduate student loans get IDR forgiveness after 25 years, and it gets lowered to 20 years for borrowers with just undergraduate debt.
I suspect that the recent notice you received is related to the one-time IDR count adjustment. Previous time on the graduated repayment plan and/or in forbearance can count toward the 20 years needed for IDR forgiveness.
My grandkids all applied when first published the possibility. Do these applications ever expire and need to file again?
There is a long list of forgiveness programs, so it is difficult to say without knowing more detail about what they applied for.
That said, applications sometimes can take several months to review because the servicers can be really slow. If your grandkids haven’t heard anything for months, it is probably a good idea for them to call an ask about the status of the application.
What is the simple answer. Will debt ever be forgiven in your opinion?
I don’t know if we will see forgiveness for all, like the plan that was recently shut down by the Supreme Court.
However, many borrowers have already qualified for forgiveness on programs like PSLF and IDR forgiveness. Additionally, many of the confusing rules that caused borrowers to miss out have been changed to make things more clear and easier.
Pursuing loan forgiveness is definitely a reasonable debt-elimination strategy.