Dept of Education Announces New PSLF Improvements

On October 25, 2022, the Department of Education announced one-time and permanent improvements to PSLF. The permanent improvements will be reflected in the updated PSLF regulations, set to be published fully on November 1, 2022. For now, we have the press release and fact sheet for details.

New Improvements

One More Chance

Because the one-time account adjustment will not be fully implemented until July 2023, a borrower who misses the Limited PSLF Waiver deadline of October 31, 2022, will have one more chance to have their payment count corrected.

Here is how the Limited PSLF Waiver and the one-time account adjustment will work together for
borrowers who work in public service:

• A borrower who submits a PSLF form by October 31, 2022, will have their time in repayment
credited under the Limited PSLF Waiver. They will also have time in deferment and forbearance
as described above credited to them for both IDR and PSLF under the one-time account
adjustment in July 2023. As the Department continues to process PSLF forms, borrowers may
see their payment counts adjust after October 31, 2022.

• A borrower who has never applied for PSLF and submits a PSLF form after October 31, 2022, will
have their PSLF form assessed under normal PSLF rules. However, they may receive additional
credit toward PSLF for any periods of certified employment when the one-time account
adjustment occurs in July. At that point, borrowers who reach 120 qualifying payments, may
need to provide additional certification that they remain employed by a qualifying employer.

Limited Waiver vs One-Time Adjustment

Like the Limited PSLF Waiver, any changes made to your account based on the one-time adjustment will be permanent and will count toward your IDR or PSLF forgiveness at any time in the future. While the one-time account adjustment is largely similar to the Limited PSLF Waiver, there are some key differences in both benefits and process.

First, the one-time account adjustment provides credit for periods that were not added under the PSLF waiver. It credits certain periods in deferment and forbearance towards IDR and PSLF for months beyond those provided by the Limited PSLF Waiver.

Finally, borrowers with Direct Loans do not have to apply for PSLF by July 1, 2023. The credit awarded as part of the one-time account adjustment can be later counted toward PSLF if the borrower certifies employment. While the one-time account adjustment provides some benefits for borrowers that go beyond the Limited PSLF Waiver, there are several PSLF requirements that will no longer be waived after October 31.

First, borrowers will no longer be allowed to count the same period of service toward both Teacher Loan Forgiveness (TLF) and PSLF. Second, a borrower will have to be employed by a qualifying employer when they apply for and receive PSLF forgiveness. Borrowers can indicate they are still employed on the PSLF form by checking the ‘Still Employed’ box on line 6.

IDR 20 or 25 Year Forgiveness

The Department will begin forgiving loans for borrowers that have reached the required monthly
payments to receive forgiveness under IDR – 20 years (240 months) or 25 years (300 months) – in
November 2022. Borrowers who reach 120 payments for PSLF due to the inclusion of periods in
deferment or forbearance will also receive forgiveness if the 120th month occurred before November 2022. Borrowers who receive additional credit for IDR or PSLF through the one-time account adjustment but who do not reach the required monthly payments under the programs will have their accounts adjusted in July 2023.

Permanent PSLF Regulation Changes: Broadening Qualifying Payments

• Allow borrowers to receive credit toward PSLF on payments that are made late, in installments,
or in a lump sum. Prior rules only counted a payment as eligible if it was made in full within 15
days of its due date.

• Count certain periods in deferment or forbearance toward PSLF to avoid instances where a
borrower may have faced confusing choices about pausing payments or getting credit toward
PSLF. These periods include:

o Cancer treatment deferment
o Military service deferment
o Post-active-duty student deferment
o Economic hardship deferment, which includes service in the Peace Corps
o AmeriCorps and National Guard service forbearances
o U.S. Department of Defense Student Loan Repayment Program forbearance
o Administrative or mandatory administrative forbearances

• Borrowers will receive a weighted average of existing qualifying payments toward PSLF when
they consolidate their Direct Loans. Under current rules, borrowers lose all progress toward
forgiveness when they consolidate. Under the new regulations, for example, a borrower with 60
qualifying payments on Direct Loan with a balance of $30,000 who consolidates their loan with
another Direct Loan with a balance of $30,000 with 0 qualifying payments will have a new
payment count of 30 payments.

Permanent PSLF Regulation Changes: Employment Certification

• Adopt a single standard of full-time employment at 30 hours a week. Prior rules required
borrowers to either work 30 hours per week at multiple jobs or whatever their employer
defined as full-time. This created confusing and varying standards. A single 30-hour-a-week requirement will make it easier for borrowers and employers to establish what it means to be

• Require employers, for purposes of PSLF, to give adjunct and contingent faculty credit of at least
3.35 hours of work for every credit hour taught. Historically, employers have struggled to
determine the work hours of adjunct instructors. This minimum conversion factor will help
employers figure out the number of hours to certify.

• Allow a qualifying employer to certify employment for a contractor if that individual is providing
services that by State law cannot be filled or provided by an employee of that organization. The
Department is aware of specific circumstances where existing state laws generally prevent
doctors at nonprofit hospitals in California and Texas from working for the hospital directly. This
change would cover those individuals as well as any other contractor whose employment is
similarly barred by state law.

Permanent PSLF Regulation Changes: Error Corrections

• Borrowers will be able to access a hold harmless option to have other periods of deferment and
forbearance potentially counted toward PSLF if they make payments equivalent to what they
would have owed at the time. This includes getting credit for periods during which the borrower
would have had a $0 payment.

• We formalized the reconsideration process for borrowers to have their applications reviewed
again if there are errors made in review.

Upcoming Changes: Early Childhood Education Providers

In the Notice of Proposed Rulemaking, the Department asked questions about the possibility of allowing early childhood education providers who operate as private for-profit businesses to be considered an eligible employer for the purposes of PSLF. In response, the Department received many detailed comments about early childhood education as well as a range of other for-profit employers. To ensure those comments receive necessary attention, the Department will publish a separate final rule addressing comments related to the definition of an eligible employer and its applicability to for-profit employers.

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