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.