So You’ve Applied for the PSLF Waiver – Here’s What Comes Next

The Limited PSLF Waiver — a temporary initiative that expands relief under the Public Service Loan Forgiveness (PSLF) program — has now ended. 

Under the waiver, past repayment periods on any federal student loan repayment plan and any federal student loan (except Parent PLUS loans) can be counted as “qualifying payments” towards PSLF, along with certain periods of deferment and forbearance. Many borrowers will advance their progress toward student loan forgiveness as a result of the waiver. And those who reach or surpass the 120 total qualifying payments required for loan forgiveness will see their balances discharged. 

The Limited PSLF Waiver officially ended on October 31, 2022. But the road ahead may be a bit rocky for hundreds of thousands of borrowers who have already applied for relief. Implementation of the waiver benefits can take a while, and the process may need some clarification. 

Here's what to expect.  

Borrowers who have not yet submitted PSLF employment certifications

To get PSLF credit under the Limited PSLF Waiver, borrowers would have needed to submit PSLF Employment Certification forms (if they had not already done so). This is the only way the Education Department and its contracted PSLF servicer, MOHELA, can count a borrower's qualifying payments. 

Borrowers who have not yet submitted a PSLF Employment Certification form can still do so to receive the benefits of the waiver. If you used the online PSLF Help Tool by October 31, 2022, to generate a PSLF form that is subsequently signed and approved, you could still get the benefits of the waiver, even if it gets submitted after the deadline. And a manually-generated PSLF Employment Certification form can also get the waiver benefits if it was signed by October 31, even if it is submitted to MOHELA after that date.

Borrowers who already have a MOHELA account can upload their PSLF forms online. Other borrowers can send the completed forms to MOHELA by mail or fax:

Mail to:

U.S. Department of Education, MOHELA
633 Spirit Drive
Chesterfield, MO 63005-1243.

Fax to:

866-222-7060

Borrowers who consolidated Direct Loans may see their PSLF count drop temporarily

Borrowers with FFELP loans needed to consolidate those loans via the federal Direct consolidation loan program to qualify for loan forgiveness under the Limited PSLF Waiver.

Related: FFELP Loan Forgiveness Options (Including New 2023 IDR Waiver Benefits)

Borrowers with existing Direct loans could have also benefited from the waiver by consolidating. Previously, consolidating would reset a borrower’s PSLF payment count to zero. But under the Limited PSLF Waiver, consolidating loans with different PSLF payment counts would result in the new Direct consolidation loan being credited with the maximum number of qualifying PSLF payments based on the individual loans being consolidated. 

But Direct loan borrowers who have recently consolidated may be in for a surprise when they find out that their PSLF payment count resets to zero. This is normal and temporary, says the Education Department. 

“If you recently consolidated your loans, your count of eligible and qualifying payments may temporarily reset to zero, but it will be further adjusted as we continue to process updates to your account under the limited PSLF waiver,” says the Education Department in published guidance. “You will receive credit on your consolidation loan for time in repayment from your existing loans. This differs from the prior approach under the normal PSLF rules, where consolidating your Direct Loans in PSLF would have reset your payment count to zero.”

It may take time for PSLF payment counts to update to reflect the waiver benefits 

Borrowers wait as PSLF applications are backlogged

The Education Department and MOHELA are dealing with a surge of PSLF applications, and they are backlogged. Officials advise borrowers that the initial review may take 90 days or more. The Department is prioritizing borrowers close to the 120-payment mark, meaning that other borrowers may have to wait even longer.

In addition, it’s important to note that most borrowers will receive an initial PSLF payment count from MOHELA that undercounts qualifying PSLF payments. This is because MOHELA may initially apply the “original” PSLF rules when evaluating a borrower’s qualifying payments. The Education Department is then supposed to conduct a further review and instruct MOHELA to adjust borrowers' PSLF counts in accordance with the waiver. This may take additional weeks or months on top of the initial 90-day review. 

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Forbearances may take longer to be counted towards PSLF

It may take even longer for the Education Department and MOHELA to credit borrowers with qualifying forbearance periods toward PSLF.

Under the waiver, extended forbearances (defined as 12 consecutive months of forbearance or longer, or 36 cumulative months of forbearance or more) can count towards PSLF as long as the borrower was in qualifying employment at the time. But the Education Department is only starting to count these forbearance periods towards PSLF.

“In fall 2022, [we] will begin making account adjustments to include these [forbearance] periods,” says the Education Department in published guidance. Since officials are just getting started, it may not be until the winter or later that many borrowers begin seeing these periods credited towards PSLF. 

IDR Account Adjustment provides a second chance for PSLF borrowers

For borrowers who may have missed the boat on the October 31, 2022, deadline, a related initiative by the Biden administration called the IDR Account Adjustment might provide a second chance for PSLF borrowers to get retroactive credit under many of the same criteria as the PSLF waiver.

“[U]pdated payment counts credited toward IDR forgiveness [under the IDR Account Adjustment] also count toward PSLF for any months in which a borrower has certified qualifying employment,” says an Education Department fact sheet. Borrowers can learn more about the IDR Account Adjustment at StudentAid.gov. 

Borrowers can submit PSLF reconsideration request or appeal

After the Education Department and MOHELA have completed their PSLF adjustments, borrowers who believe that they have been improperly denied relief, or that not all payments have been properly counted as qualifying, can appeal through a new PSLF Reconsideration process. But the Education Department encourages borrowers to wait until the PSLF and IDR adjustments have been fully implemented before submitting a request for reconsideration. 

“Be aware that borrower accounts are still being updated with payment count changes related to the limited PSLF waiver, which ended on Oct. 31, 2022,” says a message on the PSLF reconsideration website.

“In addition, if you recently consolidated, you may not see any PSLF qualifying payments on your account yet. We anticipate a lot of overlap for those benefiting from both the limited PSLF waiver and the income-driven repayment (IDR) account adjustment, and those who might want to submit a reconsideration request. Therefore, we recommend that you wait until the limited PSLF waiver period ends, and we announce that the IDR account adjustments have been made to borrower accounts before you submit a reconsideration request so that our evaluation of your request will be based on the newest information.”

The IDR account adjustments are not expected to be implemented until July 2023.