February brought the first official sessions of the negotiated rulemaking process that the DOE previewed a month earlier. Held on February 10 and 22, 2025, these sessions focused heavily on proposed employer eligibility standards for PSLF, directly tied to directives from the March 2025 executive order already being drafted by administration officials.
Meeting notes published on ed.gov/rulemaking detailed debates around what counts as a “substantial illegal purpose.” Representatives from universities, state agencies, and large nonprofits argued forcefully for safe-harbor provisions to protect employees who had no knowledge of or control over organizational missteps.
Financial planners began urging borrowers to gather annual tax filings, recent pay stubs, and updated ECFs. This built a strong archive in case final rules—expected for comment drafts by June—introduced new burdens of proof around employment.
Meanwhile, the Department confirmed that until at least July 1, 2026, PSLF would continue operating under existing guidelines. Payments made now under approved employment and IDR plans like SAVE remained fully on track toward forgiveness.
February closed with cautious optimism. While employer scrutiny might increase, borrowers who stayed diligent with annual certifications and comprehensive recordkeeping positioned themselves well for any new compliance demands that could come in 2026.