What counts as qualifying public service employment?

Full-time, paid work for government employers, 501(c)3 organizations, and a few additional non-profit organizations.  For-profit employers do not qualify under existing rules or the Limited Waiver.

Which months count towards PSLF under the Limited Waiver?

During the Limited Waiver period, any months since October 1, 2007, during which a borrower worked full-time for a qualifying public service employer, AND during which the borrower was in a “repayment status,” on any federal student loan they took out for their own education.

Are Parent PLUS loans eligible for the Limited Waiver?

No.  Parent PLUS loans are excluded from the relaxed rules of the Limited Waiver; however, if a borrower has a mix of Parent PLUS Loans and loans they received as a student, the period the borrower was in repayment on the loans they received as a student will be considered as months of qualifying payments on the Direct Consolidation Loan.

Are Spousal FFEL Consolidation Loans eligible for the Limited Waiver?

No.  Spousal FFEL Consolidation Loans are excluded from the relaxed rules of the Limited Waiver.

Do you have to be currently employed or working full-time to receive loan forgiveness?

Not during the Limited Waiver period.  If you have accrued 120 months of public service employment while your loans were in repayment since October 1, 2007, you can qualify, regardless of what repayment plan you were in, and regardless of whether you actually made a payment for a given month, as long as your loan was not in a deferment, forbearance, or default.

What is the PSLF Limited Waiver?

On Oct. 6, 2021, the Department of Education announced a waiver of certain PSLF requirements, which will be available to borrowers until October 31, 2022.  The waiver is authorized by the HEROES Act in 20 U.S.C. §1098bb to benefit public service workers who have been affected by the COVID-19 pandemic.

How do I apply for the Limited Waiver?

If a borrower has or receives a Direct Consolidation Loan and has or does submit a PSLF Certification and Application Form that is approved, the Department of Education will treat as a qualifying payment any period of repayment from October 2007 until the date of consolidation that corresponds to the period of qualifying employment.

Which loans are eligible under the Limited Waiver?

Loans made under the FFEL Program, the William D. Ford Federal Direct Loan (Direct Loan) Program, and/or the Federal Perkins Loan Program that the borrower consolidated into a Federal Direct Consolidation Loan before October 31, 2022.

What period of public service employment counts towards PSLF and the Limited Waiver?

Any period of repayment from October 2007 through October 2021 that corresponds with a period of qualifying employment approved by the Department of Education upon submission of the PSLF Form.

Will all the months until October 31, 2022 be counted under the relaxed Limited Waiver rules?

No. For existing Direct Loan borrowers to continue getting credit for PSLF after loans resume repayment after May 1, 2022, they must make payments on their loans under the regular PSLF rules.

Which criteria are waived under the PSLF Limited Waiver?

The PSLF program provides forgiveness after making 120 qualifying payments.  The waiver provides credit to borrowers toward the 120 qualifying payment requirement for periods of time in which their loans are reported as being in a “repayment status” to the National Student Loan Data System (NSLDS), without regard to whether a payment was actually made, when it was made, or what repayment plan the borrower was in at the time.

What does it mean to be in a “repayment status”?

Being in “repayment status” means not in default, deferment, or forbearance status; however, some active-duty military borrowers may qualify for credit toward PSLF during specific periods of deferment or forbearance.

What if I have FFEL or Perkins loans?

Typically, FFEL and Perkins loans do not qualify for PSLF or TEPSLF, but under the PSLF Limited Waiver, prior periods of repayment may qualify for credit toward PSLF or TEPSLF if the borrower receives or applies for a Direct Consolidation Loan on or before October 31, 2022.  For current FFEL and Perkins Loan borrowers to take advantage of the opportunity provided by this waiver, they must apply for a Direct Consolidation Loan that repays the FFEL and or Perkins Loans on or before October 31, 2022. A borrower who submits a Direct Consolidation Loan application by October 31, 2022, is still eligible so long as the application results in a Direct Consolidation Loan being made even if it is made after October 31, 2022.

Additionally, borrowers must have submitted a PSLF Certification and Application Form to the PSLF Servicer or have used the PSLF Help Tool on StudentAid.gov to generate such a form or request that the Department determine whether the borrower’s employer is qualifying before October 31, 2022.

I have some loans that were in a repayment status when other loans were not. What happens then?

For borrowers who consolidate their loans or submit a consolidation loan application by October 31, 2022, the Department of Education will provide credit toward PSLF for any month the borrower was in qualifying employment and was in repayment on the loans they consolidated, even if not all their loans were in repayment during a given month. For example, if a borrower was in repayment on a FFEL Subsidized Stafford Loan from January 2013 through December 2021 but was in repayment on a Federal Perkins Loan from February 2012 through December 2013, the borrower would receive credit on the Direct Consolidation Loan for the entire period of February 2012 through December 2021. As usual, for a payment to fully qualify for PSLF, an approved employment certification must be on file for each month under consideration.

How do I know if I already have qualifying payments for PSLF or if I will have under the Limited Waiver?

Register for an FSA ID if you don’t already have one, and log in to the PSLF Help Tool at studentaid.gov to check if your employer qualifies (you will need your employer’s Federal Employer Identification Number from your IRS Form W-2).

What will consolidation do to my interest rate?

The consolidation of loans required to take advantage of the limited PSLF waiver may have implications for the interest rate and “borrower benefits” for some borrowers.  Consolidation loans have interest rates of the weighted average of the underlying loans rounded up to the nearest 1/8 of 1 percent.  Borrowers who have earned “borrower benefit” interest rate reductions from FFEL lenders will lose those reductions upon consolidation. For example, if the FFEL lender has provided the borrower with a 1 percentage point reduction in the interest rate after the borrower made 2 years of on-time payments, the reduced interest rate that was applied to the borrower’s account is the interest rate that must be certified by the lender when the borrower consolidates, not the maximum statutory rate that a lender could have charged under the Act but for the interest rate or other reductions.

I’m a borrower in the PSLF Program, is there any action I need to take regarding the Limited Waiver announcement?

To be “in the PSLF Program” means that you have Direct Loans and qualifying employment for PSLF. If that is the case, you are already opted into the waiver and there is no action that you need to take currently. Federal Student Aid (FSA) will work with the current PSLF servicer, FedLoan Servicing, to review your account, update any payment counts, correct any errors, and consider/reconsider any forgiveness that may result. If any additional information is required, you will be contacted either by FSA or FedLoan Servicing.

I’m a borrower who would benefit from these temporary changes and need to consolidate my FFEL or Perkins loans. What steps do I need to take?

Verify your loan types with Aid Summary

  • You can see what loans you have by logging in to your account on StudentAid.gov, going to the My Aid page, and scrolling down to the Loan Breakdown section.
  • There, you’ll see a list of each loan you have borrowed, even if you have paid the loan off or consolidated it into a new loan. Direct Loans begin with  the word “Direct” Federal Family Education Loan Program loans start with “FFEL,” and Perkins Loans include the word “Perkins” in the name.
  • Now that you know what type of loans you have, read on to  see what actions you may need to  take to receive additional qualifying payments.

Verify eligible employment with the PSLF Help Tool Step 1, Employment History

  • Log into the PSLF Help Tool with your FSA ID
  • In the Employment History Section, you can check your employer’s eligibility by searching for your employer by Federal Employer Identification Number (only enter the number that appears on your IRS Form W-2). If your employer is eligible, request a Loan Consolidation by  Oct. 31, 2022
  • Borrowers who need to consolidate their loans to receive these benefits should check out the consolidation page on StudentAid.gov to understand the process for loan consolidation. Borrowers who want to consolidate should fill out and apply via this link. Submit a PSLF Form with the PSLF Help Tool by Oct. 31, 2022
  • Log in to the PSLF Help Tool with your FSA ID
How soon can I expect to start seeing the benefits of the Limited Waiver on my account?

It may take several months to complete processing for these changes and for account updates to reflect an increased number of PSLF payment counts.

I understand that FedLoan Servicing will soon no longer be the PSLF servicer. Will this transition have any impact on these benefits?

FSA will be working side by side with FedLoan Servicing as borrowers participating in the PSLF Program are transferred to a new servicer and these benefits will apply whether your loans are with FedLoan Servicing or the new PSLF servicer.

I have already received forgiveness under PSLF or TEPSLF. Does this waiver apply to me? Will I receive a refund?

Borrowers who have already received forgiveness or who paid off their loans will not be reconsidered under the waiver. They will also not receive a refund.

If the number of qualifying payments on my account are updated using the waiver and it is determined that I have exceeded the 120 payments needed for forgiveness, will I receive a refund?

Some borrowers who are determined to have made payments in excess of 120 on a Direct Loan or a Direct Consolidation Loan will receive refunds.

Which period of time is under consideration for the limited PSLF waiver?

You can only receive credit for periods of time after Oct. 1, 2007, since that is when the PSLF program began. For Direct Loans, periods of repayment prior to Oct. 1, 2021, will be reviewed. For Direct Consolidation Loans, periods of repayment on the loans that you consolidated will be considered if the borrower submits a consolidation application by Oct. 31. 2022.

Do I need to do anything right now?

If you have not certified employment for all of your qualifying repayment periods, you should do so now. If you have FFEL or Perkins loans and you have qualifying employment, you must submit a consolidation application by Oct. 31, 2022.

How do I figure out if my past or current employer qualifies for PSLF?

You can use the PSLF Help Tool to access the employer database, which provides information on which employers meet PSLF program requirements. Remember, as of right now, borrowers who do not have any Direct Loans cannot complete a form using the PSLF Help Tool and it has not been updated to reflect the waiver or the COVID-19 forbearance, but they can still search the employer database.

How can I figure out which payments now qualify for PSLF under this Limited Waiver?

If you have previously filed a PSLF form, you will be able to see which of your previous periods of repayment are eligible under this limited PSLF waiver by logging into your account with FedLoan Servicing in the coming months. The implementation of the waiver will take several months so you may not see an update for some time.

If you have never filed a PSLF form, you need to do so by Oct. 31, 2022, to see what payments qualify under this limited-time opportunity.

How can I tell if I have already submitted an Employer Certification form (ECF) or PSLF form?

If you are assigned to FedLoan Servicing, you can log in to your account to see your progress toward PSLF so far. In most cases, if you have a loan servicer other than FedLoan Servicing, you have not had an ECF or PSLF form approved.

I think there is a mistake with my payment count. Who should I contact?

Implementation of the waiver will take several months so you may not see an update with your payment counts for some time. After your payment counts are updated, if you still think there is a   mistake, you should contact FedLoan Servicing about discrepancies you may see in your payment counts.

I’m seeing information that still says that consolidation will cause me to start over again for PSLF, but you’re saying the waiver means that’s not the case. How do I know what to believe?

The waiver is real.  Right now, and through Oct. 31, 2022, consolidating your loans will not cause you to lose credit for PSLF and may allow you to gain credit towards PSLF.

Where can I go for more information?

StudentAid.gov/PSLFwaiver – information page on the limited PSLF waiver

StudentAid.gov/pslf – landing page for the PSLF help tool, where borrowers can find out if the Department has previously determined that their employer qualifies for PSLF or not

StudentAid.gov/publicservice – information page about PSLF

StudentAid.gov/fsa-id/create-account – where borrowers can go to get an FSA ID, which will enable them to receive direct communications from the Department as well as use the PSLF Help Tool and consolidate their loans

StudentAid.gov/consolidation – the landing page for the consolidation application