Borrowers who have Parent PLUS Loans deal with somewhat of a different beast than when a student borrows federal student loans. Parent PLUS Loans stay in the name of the parent who pulled them out if kept in the federal system. They generally have much higher interest rates than Direct Loans and don’t offer student loan forgiveness opportunities.
Parent PLUS Loans also have far fewer repayment options available (e.g., amortized standard fixed and graduated repayment plans). But there’s a loophole you probably haven’t heard about before: the Parent PLUS double consolidation.
The Parent PLUS double consolidation loophole is a game changer. This strategy could drop your payment from 20% to 10% of your income.
Refinancing Parent PLUS Loans to private student loans
A few options we’ve written about in the past have included private refinancing and consolidation. With Parent PLUS Loan refinancing, you take federal loans out of the federal system and get a new loan with a private lender like Laurel Road. The goal is to get a lower interest rate and snag more favorable terms.
Student loan refinancing works great for folks in a couple of different situations, assuming their credit is in a good place, such as:
- When the student loan debt balance is lower than their annual income, and they feel confident in committing to that payment and term.
- When there’s a need or desire to transfer ownership of the loan to the student/child, and their credit and financial situation allow them to commit to that payment and term.
If refinancing doesn’t seem to be the right fit — because of poor credit or the loan balance is much higher than income, making the repayment terms difficult to commit to — consolidating within the federal system is a way to open the door to one income-driven repayment plan (IDR): Income-Contingent Repayment (ICR).
Parent PLUS double consolidation loophole
Parent PLUS loan borrowers can consolidate into a Direct Consolidation Loan even without another loan and have access to Income-Contingent Repayment (ICR). This plan is based on 20% of discretionary income and has a maximum student loan repayment period of 25 years. If your employment meets eligibility requirements, it also qualifies for loan forgiveness programs, like the Public Service Loan Forgiveness program (PSLF).
If refinancing isn’t a viable option and consolidation does not bring relief with the 20% calculation, you can entertain a process called Parent PLUS double consolidation.
How Parent PLUS double consolidation works
Double consolidation is not something your servicer will offer as a strategy for repayment. The federal Direct Consolidation Loan application and process is also very tedious and time-consuming. However, it CAN open the door for access to Revised Pay As You Earn (REPAYE), Pay As You Earn (PAYE), and Income-Based Repayment (IBR). In the future, it might also give you access to a more generous new REPAYE plan that President Biden’s Department of Education is proposing in 2023. However, this plan hasn’t been finalized as of yet.
These lower IDR repayment options were not initially available to Parent PLUS Loans or consolidated Parent PLUS Loans. Let’s get technical:
- A consolidation loan that includes a consolidation that paid off a Parent PLUS Loan is NOT the same as a consolidation loan that paid off a Parent PLUS Loan.
You essentially wipe out the Parent PLUS Loan code by consolidating twice.
This technicality is critical because of the way student loans are administered and how the laws were written to identify what repayment options are available for a loan code. This legal “loophole” allows the double-consolidation process to open the door for accessing REPAYE, PAYE (if you hadn’t borrowed prior to October 1, 2007) and IBR.
Could the double consolidation loophole work for you?
First and foremost, let’s review some terminology and how consolidations work:
- Parent PLUS Loans can consolidate themselves into a Direct Consolidation Loan. This means the double-consolidation process could be successful with as little as two Parent PLUS Loans consolidating individually in the first round.
- Unlike Parent PLUS Loans, Direct Consolidation Loans need one other loan to consolidate with.
- Parent PLUS Loans can consolidate with non-Parent PLUS Loans. But it might be best to keep them separate if possible.
- If you only have one Parent PLUS Loan (and no other federal loans), your only opportunity is to consolidate that one loan into one Direct Consolidation Loan and have access to ICR or private student loan refinance.
Will double consolidation be unnecessary with Biden Parent PLUS Reform?
If President Obama could have included Parent PLUS loans in the REPAYE and PAYE plans directly, he likely would have done so. Hence, we do not think the double consolidation process is going away anytime soon, unfortunately.
Parent PLUS double consolidation steps
If it sounds like this double consolidation loophole would work for you, here are some next steps and notes:
1. Fill out paper consolidation applications
You will want to submit paper applications for the first round of consolidations. This includes one application for consolidating one or more loans and the second application for consolidating the other loan(s) left out from the first application.
You will mail to two different servicers to avoid having them added into the same consolidation (which defeats this process’s purpose). Loan servicers and contact information can be found on the Federal Student Aid website.
2. Include an IDR application for ICR
In the application mailer, include an IDR application electing the ICR plan. If you don’t, the consolidation will be denied for no repayment plan elected.
3. Mail your consolidation paperwork
Use certified mail to ensure delivery to the servicers.
If you’re going for PSLF, don’t send an application to MOHELA first. Consolidations take 30 to 90 days to complete, in which your loans will be put into forbearance or deferment while the process is underway.
You can find your corresponding loan codes and account numbers by logging into studentaid.gov. Once you’re logged in, click on the “consolidate my loans” section. You should see a long list of your loans.
View the titles of each individual loan by hovering over the question mark box with your mouse, and the name should pop up.
Reminder: DON’T submit your application online this way — the first round should be via paper application.
Final steps
Wait for your confirmation that the different servicers processed both consolidations and you have payment schedules. Once that is confirmed, you can proceed to the last steps:
4. Do the online consolidation application for the final consolidation
After you have confirmation that both consolidations were processed and you have payment schedules, do the online consolidation application.
5. Choose your final servicer
You’ll select this from the drop-down menu in the online application. If going for PSLF, choose MOHELA. If not, choose a servicer that you haven’t sent a consolidation application to yet.
6. Complete the online IDR application
When completing the online IDR application, elect REPAYE, PAYE or IBR repayment plans.
7. Make your monthly payments and recertify annually
To maintain eligibility for income-driven repayment plans, it’s crucial to make your monthly payments on time and recertify your income and family size annually.
Case study #1: Parent PLUS double consolidation with PSLF
Sara is a single mom and borrowed loans to send her two sons to college. She works full-time for a 501(c)(3) nonprofit and is interested in pursuing PSLF.
Here’s Sarah’s loan list:
Loan | Balance | Servicer |
Direct PLUS Parent | $43,000 (Son #1) | Aidvantage |
Direct PLUS Parent | $35,000 (Son #2) | Aidvantage |
Her current payment on the Standard Extended Fixed Plan is $575 per month for 300 months (25 years). She knows there is efficiency to be achieved with PSLF, so she needs to have the right type of loans (Direct) and be on an IDR plan to qualify.
Consolidation process #1
Sara consolidates each Direct PLUS Parent loan individually.
- She mails in a paper consolidation application to Nelnet, consolidating one Direct PLUS Parent Loan. Additionally, she includes an IDR application for ICR in the mailing packet.
- Sara mails a second paper consolidation application to Great Lakes, consolidating the other Direct PLUS Parent Loan she didn’t include on the first application. She also includes an IDR application for ICR in the mailing packet.
- She waits. Her Direct PLUS Parent loans are successfully consolidated into a Direct Consolidation Loan at both Nelnet and Great Lakes.
Consolidation process #2
Sara then completes the online consolidation application.
- She now consolidates BOTH loans by logging into studentaid.gov and including them in her online application.
- Sara sends them to MOHELA since she’s going for PSLF.
- She completes an online IDR application for REPAYE. This plan is based on 10% of discretionary income and household size. She also submits her Employer Certification Form (ECF) for PSLF.
Sara’s adjusted gross income (AGI) is $80,000, so her new payment under REPAYE is $511 per month. This payment is slightly lower than the 25-year plan she was on and now she will achieve PSLF forgiveness after 120 qualifying payments (10 years). Her estimated forgiven balance will be $65,000!
Case study #2: Consolidating Parent PLUS Loans and Direct Loans
A second case study is for Sam, who has Direct PLUS Parent loans and his own federal loans. Sam borrowed it for his daughter’s education. He also has loans from his own education funding.
Here is Sam’s loan list:
Loan | Balance | Servicer |
Direct Consolidated Unsubsidized | $35,000 (Sam's) | MOHELA |
FFEL Consolidated | $35,000 (Sam's) | Aidvantage |
Direct PLUS Parent | $44,000 (Daughter's) | MOHELA |
Direct PLUS Parent | $37,000 (Daughter's) | MOHELA |
Direct PLUS Parent | $36,000 (Daughter's) | MOHELA |
Sam’s current monthly payment on the Extended Graduated Plan is $1200. He is entering retirement, and this will severely impact his cash flow. So, he begins the double-consolidation process.
Consolidation process #1
Since Sam has his own loans, we want to leave those out of this consolidation for now.
- Sam puts his Direct consolidated unsubsidized and FFEL consolidated loans in forbearance for six months. This pauses his payments while he completes the consolidation for the Parent PLUS Loans.
- He mails in a paper consolidation application to Nelnet, consolidating one Direct PLUS Parent loan. Sam includes an IDR application for ICR in the mailing packet.
- Then, he mails in the second paper Consolidation application to Great Lakes, consolidating the other two Direct PLUS Parent Loans he did not include on the first application. Sam includes an IDR application for ICR in the mailing packet.
- He waits. His Direct PLUS Parent loans are successfully consolidated into a Direct Consolidation Loan at both Nelnet and Great Lakes.
Consolidation Process #2
Sam then completes the online consolidation application.
- He now consolidates just the consolidated loans at Nelnet and Great lakes together by logging into studentaid.gov, and still leaving his own loans out.
- Sam sends them all to the servicer, Nelnet.
- He completes an online IDR application for REPAYE, which is based on 10% of discretionary income and household size.
Sam’s joint AGI for him and his wife is $60,000. So, his new payment under REPAYE is slightly higher than $288 per month.
*Since Sam has one FFEL loan that’s not eligible for REPAYE, this loan’s payment is specifically based on 15% of discretionary income instead of 10%, slightly increasing his payment. Sam could complete another consolidation in the future, consolidating his two education loans together, but that application would likely need to be done via paper and sent to MOHELA.
This lower payment will help him manage retirement better, giving him about $900 per month back in his cash flow. This is a big difference compared to his original payment of $1200 per month (which would increase every two years on the graduated repayment plan).
I mistakenly consolidated two of my daughters plus loans into my direct loans from nursing school (second career). Do I have any options available to pull the plus loans back out? I cannot qualify for the IDR plan to get into the PSLF plan due to the payment being $700 a month. I’m currently on an income contingent plan that has my payments at $350/month.
Nelnet offers me no options except paying the 700 to qualify.
What do you think?
Thanks
This stinks to tell you but unfortunately no it can’t be pulled out once it’s already been included.
Do you have any guidance as to what servicer to file the final consolidation under? Would the original servicer be more likely to recognize the loophole I’m trying to work through and deny me?
Thanks!
We tend to suggest Great Lakes as the ideal servicer to end up with if you’re not pursuing PSLF, and we suggest FedLoan for people pursuing PSLF. The reason you need to use different servicers is that any loans not included with a consolidation get automatically included with a 180 day lookback if you use the same servicer. So you just have to follow the instructions exactly and then it likely works out according to the rules.
Okay gatcha. My initial services was Great Lakes, and I split the first round of the consolidations between Great Lakes and Nelnet. I am pursuing PSLF, so if I do the final consolidation through FedLoan, is the 180 day look-back not applicable? Or should I leave a 180 day window before the final consolidation?
Thanks so much for your quick response.
We suggest using someone besides your current servicer for the 2 consolidations that are used. It might work out ok but I would’ve suggested you use navient and nelnet then do the final consolidation immediately after getting confirmation that both went through and send that internet consolidation of the 2 consolidation loans to fedloan for PSLF.
I was wondering, I have 7 Parent plus loans and no other federal loans. Am I able to take advantage of this strategy? If I consolidate 3 of these loans at one servicer, and 4 at another, and then at a third servicer once those have been confirmed consolidated, submit those two consolidated loans to this third servicer to be consolidated the second time and I am able to apply for REPAYE on this final consolidated loan?
Thanks!
It’s definitely a lengthy process. If you want help walking through it, you can book a consult. All of the student loan planners have experience with it, but Meagan has the most if you want to schedule with her. https://www.studentloanplanner.com/book
I had completed the paperwork and was ready to send everything in to initiate the process of consolidating the 2 sets of loans but then was furloughed at the end of March due to COVID-19. They’re still paying my insurance, though of course my income has been drastically diminished without a paycheck since March. Would it make sense to leave my employer listed, still provide my 2019 tax return, as well as my unemployment application to verify the date of furlough?
Sure you just want to get the loans consolidated then reconsolidated dont worry about the payment you can change that later w updated documentation
Great article but it seems that the outcome of Case Study #2 is a little inflated unless I missed something. Wasn’t the new payment of $288 only for the Parent Plus loans that Sam consolidated? If so, what is the remaining payment for Sam’s Direct loans that were placed into forbearance while he dealt with the Parent Plus loans? If I’m correct, the stated $900 per month cash flow increase will be lower once the remaining loans are accounted for. Thanks for confirming if I missed something or not. Again, great article!
Eventually once you get everything added to the Direct Consolidation loan the payment is then much lower.
I will have 2 Parent Plus Loans. The first has deferred payments until my daughter graduates in 2021. I am deciding whether we should make immediate payments on the second loan, which will be for my son starting college this Fall. Can these consolidation strategies work if we do NOT defer payments on the 2nd loan or must we defer that as well?
It’ll still work, you just might end up paying a little more over the long run.
I have two children. If I have a Parent Plus loan for one child who will graduate in 2023. Can I consolidate that into a Direct Consolidation loan once she graduates with ICR payment? Then, when the second child graduates in 2025, can I consolidate the Parent Plus loan I took for her into a Direct Consolidation loan with ICR, and then immediately consolidate both Direct Consolidation loans into a final consolidation loan with FedLoan as the servicer if I’m going for PSLF? Will this loophole work if I consolidate the first child’s loan two years before the second child’s loan is consolidated? Hope this makes sense. Great article!
It depends. It could work. Although if you consolidate the Parent Plus loans for your child who graduates in 2023 again in 2025, you lose 2 years of potentially qualifying payments toward PSLF because your payment count starts over when you consolidate. When you first child graduates in 2023, I’d suggest booking a consult to walk through your best strategy options.
I have three Parent Plus Loans and I’d like to take the Double Parent Plus Consolidation approah. How can I do this with three Parent Plus Loans?
I suggest you reach out to a consultant to discuss your options and to get a custom repayment plan for your situation.
Is it possible to use this consolidation plan on my own or do I need to pay someone to help me with this? I have Parent Plus loans that I would like to move to PAYEE program by doing the double consolidation.
You shouldn’t ever have to pay someone to use a consolidation plan. It’s possible to do it on your own. Our consult service analyzes your loans and situation to pick the best repayment option but you’re paying for our financial expertise which can streamline your repayment strategy.
I have gone through the first round of consolidation with my parent plus loans. I have received confirmations that both have been approved, but because of the covid cares acts, payments do not start till February, so I have not received a payment schedule yet on both. Would you suggest waiting for the payment schedules before going through the second round of consolidation on Federal Aid’s website? Or would it be ok for me to move forward without the payments schedules?
I appreciate the article!
As long as you have 2 direct consolidation loans showing up on the online consolidation app, you could complete the 2nd round.
If I already have a consolidation loan with Fed Loan that includes a FFEL (my) loan and parent plus, can I consolidate again with my daughters parent plus loans. So basically combining the 3 consolidation loans together with Fedloan to be eligible for the loophole, or will Fedloan know and just combine them all together with them and I would just remain on ICR?
Hi Bobbi – I ran this one by one of our consultants and if they are all 3 separate consolidation loans, you could combine them all and open access to REPAYE/PAYE/IBR. Just make sure to use a different servicer altogether. If you leave the consolidation loan with FedLoan out (with an FFEL loan and a Parent Plus loan) and only consolidated the 2 Parent Plus consolidated loans, that FedLoan consolidation loan would stay only eligible for ICR, while the other 2 would consolidate and have access to PAYE/REPAYE/IBR. If the Parent Plus loans are still in their original form, those need to be consolidated FIRST, then you could consolidate that one with your existing consolidation loan at FedLoan. Hopefully that makes sense – it’s quite a process, as you can see. If that seems confusing, book a consult and one of our consultants can walk you through it.
Thank you Amy, it is not confusing at all. I forgot to mention I am a teacher so that is why I am using Fedloan for PSLF. I listen to the Student Loan Planner podcasts which give great advice as well.
I have told other teachers about your service and info on the web, most of them think they are getting forgiveness but they are not with Fedloan. They do have to be with Fedloan for PSLF, correct?
Thanks Again,
Bobbi
Thank you for the great article!
Do you know whether the same method works if we reconsolidate a single commercially-owned *FFEL* consolidation loan–that repaid Parent PLUS loans–to a Direct Consolidation Loan? The current loan shows up as type J, “Unsubsidized FFEL consolidation loans,” on the Direct Consolidation Loan Application.
By the way, I thought readers might be interested to know the 2017 PROSPER Act (currently dead to my knowledge) had an explicit provision to close this loophole: “A current law loophole allows parent loan borrowers to enter IBR if such borrowers consolidate a consolidation loan. We eliminate this ‘double consolidation’ loophole for all loans.”
If you have not taken a new loan out in the last 180 days (6 months) can you do the process electronically. When talking to the loan servicers, they say that to just pick the loans you want to consolidate when you fill out the online application.
You can, but because you need to send the paperwork to 2 different loan servicers to make the double consolidation loophole work, doing it online isn’t recommended.