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The Limited PSLF Waiver for FFEL Program Loans

On Oct. 6, 2021, the U.S. Department of Education (ED) announced a set of changes to the Public Service Loan Forgiveness (PSLF) Program which will be implemented in phases over the next year. These changes to the program are intended to help PSLF reach a broader audience of qualified borrowers. Some changes are time-limited and will require you to act soon.

The opportunity to use this limited PSLF waiver exists from October 6, 2021, through October 31, 2022. More information and updates can be found at StudentAid.gov/pslfwaiver.

You should also know:

  • Your Federal Family Education Loan (FFEL) Program loans do not currently qualify for PSLF or Temporary Expanded Public Service Loan Forgiveness (TEPSLF). However, your prior periods of repayment on FFEL Program loans may qualify for credit toward PSLF or TEPSLF if you receive or apply for a Direct Consolidation Loan. If you received Teacher Loan Forgiveness, the period of service that led to your eligibility will count toward PSLF (if you certify employment for PSLF for that period). The deadline to apply is on or before October 31, 2022.
  • Regardless of the limited PSLF waiver, you must consolidate your loans into the Direct Consolidation Loan program in order to qualify for PSLF or TEPSLF. Normally, prior periods of repayment would not qualify for credit toward PSLF or TEPSLF. However, the limited PSLF waiver allows for a waiver of certain program requirements. For any non-Direct Loan to be forgiven under the limited PSLF waiver, it must be consolidated into a Direct Loan. The deadline to apply for this consolidation is October 31, 2022. You cannot receive credit for payments made under the limited PSLF waiver if you apply to consolidate after this date.
  • To understand whether you may already have qualifying payments for PSLF or TEPSLF under the limited PSLF waiver, you should follow our step-by-step instructions to see if your employer qualifies.
  • You should apply for a Direct Consolidation Loan on or before October 31, 2022, if: Your employer is a qualifying public service employer OR you are uncertain about your employer, but want your loans to qualify for PSLF, TEPSLF, and the limited PSLF waiver.
  • NOTE: If you are uncertain about your employer eligibility, you should review your account and carefully consider the pros and cons of loan consolidation based on your loans and circumstances. For more information, please refer to AES - Federal Loan Consolidation.

How Does it Work?

Under this limited PSLF waiver, periods of repayment on FFEL Program loans, Perkins Loans, and Direct Loans made to student borrowers will count toward PSLF forgiveness.

The limited PSLF waiver does not make any changes to the public service employment requirements or what counts as qualifying employment. To opt into the limited PSLF waiver, you must do two things:

  • Have or get Direct Loans by consolidating loans made under other loan programs into a Direct Consolidation Loan. The deadline to apply for this consolidation is October 31, 2022.
  • Submit a PSLF form to FedLoan Servicing by October 31, 2022. That form must be approved by FedLoan Servicing; that means you may miss your opportunity for the limited PSLF waiver if your form is denied after the deadline. The best way to avoid this is to consolidate and apply early, so that you have time to make corrections to your PSLF form if needed.

Qualifying Payment Credits

The limited PSLF waiver does not count payments made on loans. Instead, it counts periods of time when you were in an “In Repayment” status (obligated to make a payment). It does not count periods of time when you were in default, deferment, or forbearance. The limited PSLF waiver will still count you as “In Repayment” even if your payments were not made:

  • For the full amount due
  • On a qualifying repayment plan
  • On-time

Repayment Histories

Your repayment history is maintained in FSA data systems. You will not need to provide any repayment histories or request histories from your servicers prior to consolidating.

Parent PLUS Loans

Parent PLUS Loans will not be directly evaluated for credit under the limited PSLF waiver, regardless of whether the loan was made under the Direct Loan or FFEL Program. However, if you had a mix of Parent PLUS Loans and FFELP loans that you received as a student, ED will consider the period of time when you were “In Repayment” on the loans you received as a student as months of qualifying payments on the Direct Consolidation Loan.

EXAMPLE:

You were in repayment on a FFEL Parent PLUS Loan from January 2012 through December 2015 and on a FFEL Subsidized Stafford Loan from January 2010 through December 2015. You consolidated both loans in December 2015.

While the repayment status history on the FFEL Parent PLUS Loan will not be considered, the repayment status on the FFEL Subsidized Stafford Loan will be considered. The entire Direct Consolidation Loan made in December 2015 would receive credit under the limited PSLF waiver for the period of January 2010 through December 2015.

However, if you only had the FFEL Parent PLUS Loan and consolidated it, you would not receive credit under the limited PSLF waiver.

Check Your Employer for PSLF Eligibility

We have step-by-step instructions for you to check the eligibility of your current and past employers for PSLF.

  1. Create an FSA ID or use your existing FSA ID to log in to the StudentAid.gov website.
  2. Enter the PSLF Help Tool and proceed to Step 1.
  3. Enter your Federal Employer Identification Number (EIN) to look up your employer. You can find this number on your IRS W-2 form.
  4. The PSLF Help Tool will confirm or deny your employer’s eligibility for PSLF, TEPSLF, and the limited PSLF waiver.

Frequently Asked Questions

  • How soon can I benefit from the limited PSLF waiver?

    The Department is working with the PSLF Servicer to review and update borrower accounts. It may take several months to complete processing for these changes and for account updates to reflect increased number of PSLF payment counts. If you apply for a Direct Consolidation loan, we will work hard to make sure it is processed expediently. If you are going to consolidate for the limited PSLF waiver, it is best to start now.

  • How do I consolidate my loan?

    You can access the Direct Consolidation Loan Application at StudentAid.gov. That page also has information about who can consolidate and what to expect when you consolidate.

  • Which non-Direct Loans can I Consolidate for credit under the limited PSLF waiver?

    You can only receive credit under the limited PSLF waiver for non-Direct loans if you include them in a Direct Consolidation Loan first. The deadline to apply for consolidation is October 31, 2022. This would include both FFEL Program and Federal Perkins loans.
    Visit StudentAid.gov/aid-summary to find out what types of loans you have.