Navigating Public Service
Loan Forgiveness

PSLF is codified in statute (20 U.S.C. § 455(m)), so it cannot be eliminated through executive action or rulemaking alone — it would require an act of Congress. That said, the program's requirements (qualifying employer definitions, payment plan eligibility, processing timelines) are all set by regulation, which means the rules around PSLF can shift significantly even while the program itself remains law.

On February 27, a federal judge in Missouri dismissed the primary lawsuit that had been blocking the SAVE plan since mid-2024. Both the Trump Administration and the plaintiff states wanted the court to formally kill SAVE through a consent judgment. Judge Ross refused — because both sides wanted the same outcome, there was no live dispute for a court to decide. He dismissed the case as moot.

That dismissal lifted the injunction that had blocked SAVE for more than a year and a half. But within days, the plaintiff states filed a motion asking the judge to stay the dismissal and reinstate the injunction while they appeal. The Education Department took no position on that motion. Judge Ross denied the stay on March 4, and the states immediately appealed to the Eighth Circuit — the same court that originally expanded the injunction to block all of SAVE in the first place.

As of today, the case is pending at the Eighth Circuit. No court order currently blocks SAVE, but no one is administering it either. The Department of Education has said only that it is "evaluating" the decision. Servicers have received no new guidance. Borrowers remain in forbearance.

The practical bottom line for PSLF borrowers: nothing has changed on the ground yet. You are still in forbearance, that time still does not count toward your 120 payments, and interest is still accruing. If you are waiting on the SAVE situation to resolve before making a move, understand that the Eighth Circuit could reinstate the injunction, or the Department could act on its own to end SAVE through rulemaking — or do nothing and let the One Big Beautiful Bill Act phase it out by July 2028.

I wrote a detailed breakdown of this situation for borrowers — read it for the full context.

Yes — months spent in forbearance after SAVE was enjoined do not count toward PSLF's 120 qualifying payments. Interest continued accruing during that period as well. If you haven't already, you should switch to an active IDR plan (IBR or PAYE) so that future payments count. Each month you remain in forbearance is a month lost.

1. Log in to StudentAid.gov and use the PSLF Help Tool
2. Generate a pre-filled ECF with your employer information
3. Have your employer's authorized official sign it
4. Submit it to MOHELA (your PSLF servicer)

Filing before July 1, 2026 locks in your current employer's eligibility under the existing rule. Don't wait — processing times at MOHELA are running several months behind.

The final rule evaluates eligibility at the employer level, not the division or program level. However, the rule's language around "primary purpose" is ambiguous enough that large organizations with diverse missions could face scrutiny. This specific issue is being challenged in the pending lawsuits. File your ECF now to lock in eligibility under the current framework.

1. Go to StudentAid.gov and submit an IDR application
2. Select IBR as your plan
3. Provide income documentation (AGI from most recent tax return)
4. Your servicer will process the switch — expect 30–60 days

While the application is processing, make sure you're not sitting in forbearance. Ask your servicer to place you on IBR immediately with an estimated payment if possible.

Parent PLUS loans are only eligible for PSLF if consolidated into a Direct Consolidation Loan and placed on ICR. After July 1, 2026, new consolidation borrowers will lose access to ICR (the only IDR plan available to Parent PLUS). If you hold Parent PLUS loans and haven't consolidated yet, do it before that date or you may permanently lose your path to PSLF.

You can — payments on the 10-year Standard Plan count toward PSLF. But if you're on Standard and reach 120 payments, you'll have already paid off the loan. IDR plans result in lower monthly payments, which means you actually benefit from forgiveness. Standard only makes strategic sense if your IDR payment would be higher than the Standard amount.

We don't know yet. RAP's final regulations haven't been published, so the income calculation methodology — including whether it uses individual or household income for married borrowers — is still pending. This FAQ will be updated once the final rule is available. In the meantime, run the numbers under both MFJ and MFS to understand your range of outcomes.

Your qualifying payment count doesn't reset. If you return to an eligible employer later, your count picks up where it left off. You don't need 120 consecutive payments — they just need to total 120 qualifying payments made while working for an eligible employer. Payments made while working in the private sector won't count, but they won't erase prior progress either.

Under the PSLF Buyback program, consolidation does not reset your payment count for bought-back periods — that's the whole point. However, if you consolidate outside the Buyback context, your count does restart to zero. This is a critical distinction: Buyback preserves prior credit, but standard consolidation wipes it. Make sure you understand which process you're entering before you submit paperwork.