Public Service Loan Forgiveness (PSLF)

Are you considering a career in public service and want to utilize Public Service Loan Forgiveness (PSLF)? On this page, we offer some helpful tips and best practices compiled from the Department of Education, loan servicers, advocacy groups, and some of our very own LRAP participants. These tips are for informational purposes only. Please always defer to the Department of Education’s guidelines and regulations.

Please see our PSLF Best Practices one-page sheet for a shorter and easier-to-read version of this information. Our latest LRAP Presentation (updated in October 2021) may also provide more context about PSLF and how it works with income-driven repayment and LRAP. If you’d prefer to follow along with guided audio, please click here.

On October 6, 2021, the Department of Education announced new improvements to the Public Service Loan Forgiveness program to restore the promise of PSLF.

The Dep’t of Ed is calling the new improvement a “Limited Waiver Opportunity.” Made under the Department’s executive authority during an emergency, the waiver will be in place until October 31, 2022. The waiver will allow borrowers to receive PSLF credit for all payments made while working full-time for a PSLF-qualifying employer, regardless of federal loan type or payment plan. This includes loan types and repayment plans that were previously not eligible for PSLF, and payments that were late or not made in the full amount due.

The waiver alone will benefit over 550,000 borrowers. As of November 23, already 30,000 borrowers have received PSLF under the new waiver. Around 60% of borrowers who submit PSLF Forms have ineligible FFEL loans–this waiver will help those borrowers become eligible.

For a summary of the changes, check out this handy Consumer Protection Guide by the Berkeley Center for Consumer Law and Economic Justice. And if you prefer learning via video, you can watch this PSLF Town Hall held by Student Debt Crisis Center on October 14. AccessLex is also hosting live webinars about the waiver from November – February.

 

Timing:

  • The waiver runs through October 31, 2022. Payments must have been made after October 1, 2007. Some previously-non-qualifying payments will count until October 31, 2022, and others had to have been made before September 30, 2021 to qualify for the waiver. When in doubt, complete all required actions to comply with the waiver ASAP.

 

Who the waiver helps:

  • Those who have ineligible loan types, like FFEL or Perkins loans.
  • Those who previously had ineligible loan types, but consolidated them into a Direct consolidation loan.
  • Those who consolidated their loans into a Direct consolidation loan and then lost qualifying PSLF payments on their prior loans.
  • Those who made payments under an ineligible repayment plan, such as a graduated or extended plan or the standard plan for consolidation loans.
  • Those who made payments that were late or not in the full amount due.

 

How to tell if you’re eligible:

  • Check your loan types and repayment plans:
    • Visit Federal Student Aid, log in, click “My Aid” under your name in the top right corner, and view your loan breakdown. This will tell you what types of loans you have and what repayment plan you’re in.
    • If you currently have FFEL or Perkins loans, or your loans are not in an income-driven or standard repayment plan, you may be eligible. If you have a consolidation loan, you may also be eligible.
  • Review your loan account and past PSLF Forms (formerly called Employment Certification Forms):
    • Have you ever had your payments not count toward PSLF because you had the wrong loan type, were in the wrong repayment plan, made a little or incomplete payment, or previously consolidated your loans? You may be eligible for the waiver. Check the PSLF payment tracker on the FedLoan Servicing website to see if you have ineligible payments and review the reason for ineligibility.
  • Are you or have you been in PSLF-qualifying employment, but you’ve never submitted a PSLF Form?
    • Now is the time to submit PSLF Form(s) to ensure that if you qualify for the waiver, you can get the benefits before October 31, 2022.
  • Are you missing documentation for certain periods of employment?
    • Now is the time to submit PSLF Form(s) to ensure that if you qualify for the waiver, you can get the benefits before October 31, 2022.
  • Have you applied for PSLF before, but were denied?
    • If you think the waiver will mean that you’re now eligible for PSLF, you may need to take some corrective actions described above and then re-apply for PSLF. Sit tight for more direction from the Department of Education.

 

Which PSLF requirements are waived:

See https://studentaid.gov/announcements-events/pslf-limited-waiver 

 

How to utilize the waiver:

  • Make sure your contact information is up-to-date on both studentaid.gov and your loan servicer’s website. If the Department of Education is going to reach out about your eligibility for the waiver, they need to be able to contact you.
  • If you’ve not yet submitted a PSLF Form, or have not yet certified some periods of qualifying employment, you need to submit PSLF Form(s) to document your employment and payments before October 31, 2022. Make sure you’ve submitted at least 1 form for all qualifying employers you’ve worked for.
  • If you have Perkins or FFEL loans, you must submit a consolidation loan application by October 31, 2022. You do not need to take this step if the only federal loans you have are Direct loans (e.g. Direct subsidized and unsubsidized loans, Direct Stafford loans, Direct Grad PLUS loans, and Direct consolidation loans).
    • Make sure to download and save your payment history documentation from your Perkins and/or FFEL loans before they are consolidated for your PSLF records.
    • Make sure to enroll your new consolidation loan in a qualifying income-driven repayment plan.
  • If you’re in the wrong repayment plan, switch to an income-driven repayment plan now.
  • All other borrowers will automatically receive credit for months of qualifying payments for any months in which they were employed full-time by a PSLF-qualifying employer and have already certified their employment, but didn’t receive credit toward PSLF because of ineligible loans, repayment plans, or payments.
  • The Dep’t of Ed recommends borrowers take all action through the online PSLF Help Tool.

 

When you’ll see the benefits:

  • The Department of Ed will automatically adjust PSLF payment counts for borrowers who have already consolidated FFEL and/or Perkins loans into Direct consolidation loans and/or have already certified all periods of qualifying employment. Changes may take several months. You may receive an email letting you know how many qualifying payments you’re eligible to gain through the waiver.
  • Borrowers with existing FFEL and Perkins loans must consolidate their loans by October 31, 2022 to benefit from the waiver. If you have not yet submitted a PSLF Form for employment periods covering prior payments made on Perkins and/or FFEL loans, make sure to submit new forms by October 31, 2022, too.
  • Borrowers who have not yet submitted a PSLF Form or haven’t certified certain periods of employment should submit PSLF Form(s) before October 31, 2022 to benefit from any potential adjustments.
  • You may receive an email from the Department of Education letting you know what actions to take to benefit from the waiver.

 

More than 120 payments? Expect a refund.

  • If, because of the waiver provisions, you have made over 120 PSLF-waiver-qualifying payments, you should be able to receive a refund for any extra payments made. Stay tuned for more information about the mechanics of the refund process.

 

The future of PSLF:

The waiver will be paired with additional long-term improvements to PSLF. The Dep’t of Ed has these goals in mind with their planned improvements:

  • Simplify qualifying payment rules.
  • Reduce barriers to PSLF for military service members. Months spent on active duty will count toward PSLF, even if loans were in forbearance.
  • Automatically give service members and federal employees credit for PSLF by matching Dep’t of Ed data with federal employee databases.
  • Review denied PSLF applications and correct errors in PSLF processing. This comes as part of a settlement between the Massachusetts Attorney General and FedLoan Servicing, and will also take place as part of an internal review by the Dep’t of Ed.
  • Improve outreach and communications with borrowers potentially eligible for PSLF.
  • Simplify the PSLF application process, including improving the qualifying employer database and allowing e-signatures on applications.

Other long-term improvements to PSLF are coming! Negotiated rulemaking hearings on PSLF and IDR have just ended, with proposed new IDR and PSLF regulations coming soon.

The main program requirements are:

1) Make 120 qualifying payments, that are:

  • Due (you must have a payment due to make a qualifying payment. You cannot make a qualifying payment during a grace period, forbearance, deferment, or default)
  • On-time (made not sooner than 15 days before your due date and not later than 15 days after your due date)
  • Previously, payments had to be made in full each month. Now, you can make multiple smaller payments so long as they 1) add to up your full amount due and 2) are made within 15 days of your due date.
  • Previously, you had to make a payment each month. Now, lump sum payments can count through the end of your IDR plan.

2) On Federal Direct loans

  • Only federal Direct loans are eligible for PSLF (E.g., subsidized and unsubsidized Stafford, Plus, and Consolidation loans)
  • Perkins and FFEL loans are not eligible
  • Private loans are not eligible

3) In a qualifying payment plan, including:

  • Income-Driven Repayment plans (IBR, PAYE, REPAYE, or ICR)
  • Standard 10-year repayment plan (qualifies for PSLF for all loans except Direct Consolidation loans)

4) While in qualifying employment

  • Full-time (according to employer’s definition of full-time or at least 30 hours a week, whichever is greater)
  • At a 501(c)(3) tax-exempt nonprofit or governmental organization
  • Payments must be made while employed to count for PSLF–if you’re between jobs and make a payment, that won’t count.
  • If you want to know if your employer qualifies for PSLF, use the PSLF Help Tool. The tool contains and employer database searchable by Federal Employer Identification Number (EIN), which you can find on your W2. After you enter an EIN, you’ll see that your employer is eligible, likely ineligible, or ineligible. The tool isn’t perfect, but it can be useful.
  • You must document your employment by submitting a PSLF Form. It’s recommended that you submit a new form annually and each time you leave a job.

Some tips that will make applying for and obtaining loan forgiveness under PSLF easier include:

  • Enroll in autopay so you never miss a payment or make a late payment. And consider keeping a separate bank account for your loan payments to make it easier to track your payments, LRAP funds, and out-of-pocket contributions all in one place.
  • Recertify your income-driven repayment plan every 12 months, on time. If you don’t recertify on time, your loan servicer will kick you out of IDR, potentially interfering with your ability to make a qualifying payment and prolonging your PSLF timeline.
  • Submit the PSLF Form to certify your employment and payments annually, every time you leave a job, and more frequently the closer you get to 10 years.
    • You can use the PSLF Help Tool to partially complete the form electronically and search for your employer in the PSLF database.
    • Make sure to correctly and accurately fill out every piece of required information on the form, or it will get rejected.
    • Only certain signature types are accepted.
    • If you submit multiple forms for the same job, make sure the employer information and start date is consistent on each form, or they may be rejected.
    • Make sure to submit a new, final form that includes an end date whenever you leave a job.
    • Make a copy of each form you submit for your own records, and save all communications you get back from FedLoan Servicing about your forms (i.e. form acceptance, form approval, updates to qualifying payment counts, etc.).
    • As you approach your final year of repayment, submit a new PSLF form every 3 months to continually get updates about how close you are to applying for PSLF and ensure your PSLF application can be processed quickly.
  • Download and save your loan payment history every 6-12 months. Payment history data older than 12 months is often removed from your loan servicer’s website, so make sure you download this information at least once a year. And if you transfer loan servicers, make sure to download all the payment history data from the old servicer before you lose access to their website.
  • Regularly track how many months of qualifying payments you’ve made. If you notice discrepancies between what you believe and what your loan servicer says, contact them ASAP. Here is a template tracking spreadsheet you can download.
  • Watch your loan balance to ensure your loan servicer hasn’t made any errors.
  • Avoid paid ahead status. You can now “prepay” for up to 12 months, or the time your IDR plan is due for recertification, whichever comes first. But if you made extra payments prior to August 2020, contact your loan servicer to make sure you’re not in paid ahead status. If you are in a paid ahead status, your payments will often not count as qualifying payments for PSLF.
  • If your loans are going to be transferred to a new servicer, prepare to update your loan records. Download and save everything you can from your loan servicer’s website–payment histories, billing statements, income-driven repayment plan documents, PSLF Form acceptances and approvals, notifications, and more. Once your loan are transferred to a new servicer, you may not be able to log into your old servicer’s website!
  • After you switch loan servicers, confirm your total loan balance and number of qualifying payments is correct. You may need to submit a new PSLF Form to be certain. 
  • Document everything and be diligent. Keep a history of communications with your loan servicer, employment records, IDR plan letters and payment schedules, PSLF Forms and approval letters, and payment histories. Each time you call your loan servicer, document the date, employee ID number, what you spoke about, and any timelines for action. You want to build a case for why you deserve to be approved for PSLF, and be able to counter any disagreements from your loan servicer or the Department of Education.
  • Use your legal skills to read and understand all of the PSLF requirements and to advocate for yourself.
  • About 18 months before you plan to apply for PSLF, request an audit of all of your payments. This will ensure your qualifying payments are counted up correctly, allow you to catch any errors before submitting your PSLF application, and make sure your payment tally is up-to-date and the records are fresh before you apply.

Before applying to have your loans forgiven using PSLF, make sure to:

  • Submit a new PSLF Form for every qualifying job you’ve had and any periods for which you have not already submitted a form. Use the PSLF Help Tool to do so.
  • Don’t quit your job! Continue working in qualifying employment when you submit your application and up until you are approved, as this is required to obtain forgiveness.
  • At this point, the PSLF application process takes approximately 60 days. During the wait, you have the option of continuing to make payments or putting your loans into forbearance making no payments.

You may have heard about the Temporary Expanded PSLF (”TEPSLF”). This is a program for those who applied for PSLF but were denied because they were in the wrong payment plan, namely, the extended repayment plan. You can determine if this temporary expansion applies to you and see how to apply on the TEPSLF website. TEPSLF has limited funding.

If you have issues with your loan servicer, you can:

  • Contact Berkeley Law’s Financial Aid Office
    • We can help answer common questions or help you find loan records.
  • Contact your loan servicer
    • You can contact your loan servicer via their online portal or their customer service phone number.
      • Document your conversation and ask for the employee’s ID number. Don’t be afraid to ask for a manager or hang up and try again if the staff member you’re talking with isn’t knowledgeable.
    • FedLoan Servicing has a PSLF-specific website and phone number (1-855-265-4038).
    • Many loan servicers also have their own ombudsperson’s office to deal with escalated issues. Consider contacting the ombudsperson if dealing with a long-lasting issue.
      • FedLoan Servicing also has an ombudsperson / escalated phone number you can call for faster response times and faster resolution to any issues you may have (717-720-7605).
    • PHEAA (FedLoans’ owner) also has an Office of Consumer Advocacy you can contact.
  • File a complaint with the Federal Student Aid Ombudsperson.
    • This should be your last resort if dealing with a dispute with your loan servicer regarding your loans.
  • File a complaint with the Consumer Financial Protection Bureau.
  • File a complaint with the California Attorney General’s Office or your state’s AG. You can also reach out to your state’s consumer protection or financial services agency (e.g. California’s Department of Financial Protection & Innovation or New York’s Department of Financial Services), or one of your Congressional representatives.

Some common issues we see people run into, and how to fix them:

  • Problem: Fedloans tells you you have 24 qualifying payments, but you know you’ve made 36.
    • Solution: Request an audit or “payment-by-payment detail of [your servicer’s] evaluation of qualifying status for PSLF.” You might try requesting this via written request, or even certified mail with return receipt requested. And, if you have your own documentation of your payments, provide that your servicer. If your servicer continues to disagree with you, contact the Federal Student Aid Ombudsperson, who should have detailed records.
    • To preemptively prevent running into a problem like this, make sure you keep detailed documentation of your loan payments and your repayment plan. Download your payment history at least every 12 months–before your servicer removes it from their website. And make sure that your payments are dueon time, in the correct amount, and that your loans are not in paid ahead status.
  • Problem: Your new loan servicer isn’t counting the qualifying payments you made before your loans were transferred to them.
    • Solution: Your new servicer should have all the billing information from your account, even before your loans were transferred to them. They should be able to provide a detailed breakdown, showing how much was due each month and how much you paid. You should request a “payment-by-payment detail of [your servicer’s] evaluation of qualifying status for PSLF” to obtain this information. You might try requesting this via written request, or even certified mail with return receipt requested. And, if you have your own documentation of your payments, provide that to your servicer. If they continue to disagree with you, contact the Federal Student Aid Ombudsperson, who should have detailed records.
  • Problem: Your servicer rejects your PSLF Form.
    • Solution: make sure your employer qualifies for PSLF. The easiest way to qualify is if your employer is a 501(c)(3) nonprofit or a government entity. If your employer qualifies but your form still got rejected, make sure all the information is correct. Pay close attention to the EIN–is it the correct number and correct amount of digits? You must also make sure the person that signed your form is considered an authorized official. Finally, make sure the information is consistent from when you last submitted a PSLF Form. For instance, did you accidentally change the start date for a job for which you’ve already submitted a form? The information must be the same form to form.

Have further questions? Additional PSLF information can be found here:

Last updated December 15, 2021