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. For distilled information about the changes, check out this handy Consumer Protection Guide by the Berkeley Center for Consumer Law and Economic Justice for FAQs on this topic, or our Google Doc.

 

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. An estimated 22,000 borrowers will be eligible to have their loans immediately discharged through PSLF, and another 27,000 borrowers could potentially be immediately eligible for PSLF if they certify additional periods of employment. Around 60% of borrowers who submit PSLF Forms have ineligible FFEL loans–this waiver will help those borrowers become eligible.

 

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 lost qualifying PSLF payments on their prior loans.
  • Those who made payments under an ineligible repayment plan, such as a graduated or extended plan.
  • Those who made payments that were late or not in the full amount due.

 

How to tell if you’re eligible:

  • Check your loans 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 not had your payments counted because you had the wrong loan type, were in the wrong repayment plan, or previously consolidated your loans? You may be eligible for the waiver. Check your FedLoan Servicing account to see if you have ineligible payments.
  • Are you or have you been in PSLF-qualifying employment, but you’ve never submitted a PSLF Form?
    • Now is the time to submit a PSLF Form 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 a PSLF Form to ensure that if you qualify for the waiver, you can get the benefits before October 31, 2022.

 

Timing:

  • The waiver runs through October 31, 2022.

 

How to utilize the waiver:

  • 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).
  • 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 or repayment plans.
  • 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 their employment. Changes may take several months.
  • Borrowers with existing FFEL and Perkins loans must consolidate their loans first and submit a new PSLF Form to see their payment count adjusted.
  • 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.

 

The waiver will be paired with additional long-term improvements to PSLF. The Dep’t of Ed has these goals 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 application 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 is happening now (October, November, and December meetings).

As a reminder, the main program requirements are:

 

1): Making 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, or deferment.)
  • On-time (made not sooner than 15 days before your due date and not later than 15 days after your due date)
  • At minimum, in the amount due and as required by any applicable income-driven repayment plans you’re enrolled in (even a penny short will not count)
  • Made each month–but lump sum payments can now 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 and Plus loans)
  • Perkins and FFEL loans are not eligible (unless consolidated, but we do not recommend consolidating with your Direct loans if you have already made qualifying payments. This action will create a new loan and restart the clock back to 0 months out of the 120 needed for forgiveness)
  • Private loans are not eligible

 

3): In a qualifying payment plan, including

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

 

4): While in qualifying employment

  • Full-time (according to employer’s definition of full-time and at least 30 hours a week)
  • 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.

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 and every time you leave a job.
    • 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.
    • 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 typically 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. If your loan servicer is FedLoan Servicing, this practice was changed in August 2020 (you can now “prepay” for up to 12 months, or the time your IDR plan is due for recertification, whichever comes first). If your loan servicer is not FedLoan Servicing or you made extra payments before August 2020, make sure you’re not in paid ahead status. To do so, you must either manually select that you do not want an overpayment to put you into a paid ahead status, or contact your loan servicer to permanently remove paid ahead status (see FedLoans’ recommendation). If you are in a paid ahead status, your payments will often not count as qualifying payments for PSLF. Read Federal Student Aid’s information about paid ahead status here

 

  • 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/Employer Verification 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. 

 

  • Generally, document everything and be diligent. Keep a history of communications with your loan servicer, employment records, IDR plan approval 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.

Temporary Expanded PSLF: 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.

 

  • 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 ombudsman’s office to deal with escalated issues. Consider contacting the ombudsman if dealing with a long-lasting issue.
      • FedLoan Servicing also has an ombudsman/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 Ombudsman.
    • This should be your last resort if dealing with a dispute with your loan servicer regarding your loans.

 

 

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 FedLoan Servicing’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 to FedLoans. If FedLoans continues to disagree with you, contact the Federal Student Aid Ombudsman, 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 FedLoans 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: FedLoans isn’t counting the qualifying payments you made before your loans were transferred to them.
    • Solution: FedLoans 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 FedLoan Servicing’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 FedLoans. If FedLoans continues to disagree with you, contact the Federal Student Aid Ombudsman, who should have detailed records.

 

  • Problem: FedLoans 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? Some PSLF information can be found here:

 

 

  • Use the PSLF Help Tool to determine what remaining steps you need to take to obtain PSLF.

 

  • Explore the PSLF FAQs for specific information on qualifying employment, eligible loans, the PSLF application process, and more.

Last updated October 13, 2021