Comments on: How Often Should I Certify My Public Service Employment? https://studentloansherpa.com/often-should-submit-ecf/ Expert Guidance From Personal Experience Thu, 08 Feb 2024 13:38:07 +0000 hourly 1 https://wordpress.org/?v=6.7.1 By: Jordan https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13404 Thu, 08 Feb 2024 13:38:07 +0000 https://studentloansherpa.com/?p=10847#comment-13404 In reply to Michael P. Lux, Esq..

Thank you for taking a look at Mohela’s new interface and confirming “qualifying” and “certified” mean the same thing.

I’ve appreciated the back and forth with you, I feel more confident in our plan moving forward than I had in the past, so thank you again for all of your help!

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By: Michael P. Lux, Esq. https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13399 Tue, 06 Feb 2024 18:30:15 +0000 https://studentloansherpa.com/?p=10847#comment-13399 In reply to Jordan.

It looks like Mohela has updated their interface and PSLF tracking since the last time I looked.

I think the best breakdown is available if you click on the show payment summary link. Eligible payments appears to be the total of qualifying/already certified, and the payments that haven’t been certified. In the current interface, qualifying and certified appear to mean the same thing.

I should note that these terms don’t have technical definitions by statute or in the CFR, it is just Mohela’s way of conveying to borrowers their progress. Ultimately, as long as you keep sending in employer certifications and certifying your progress, you should be fine.

To answer your last question, the 10-year plan will qualify for PSLF and if that offers a lower monthly payment than any of the IDR plans, it could be the best option.

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By: Jordan https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13398 Tue, 06 Feb 2024 15:34:11 +0000 https://studentloansherpa.com/?p=10847#comment-13398 In reply to Michael P. Lux, Esq..

Thank you again for the response, I appreciate your expertise and help talking through our options!

I’ll start with my main question (and concern) – what is the difference between “qualifying” and “certified” for payment counts? I’m a bit worried about your final comment. So far my wife has submitted only one PSLF form, back in Fall 2023, and after receiving a confirmation from Mohela (in Nov) that the form was reviewed her PSLF Payment Tracker on their website shows 47 qualifying payments. The studentaid.gov tracker shows the same thing. All of these payments were made on an Extended Graduated plan. Are you saying these may not actually qualify when her final review is performed after 120 payments are made? I was under the impression that since these were reviewed and deemed qualifying (thanks to the Limited Waiver/one-time payment count adjustment), they are locked in as “certified” for PSLF.

Since submitting the form last Fall, three additional payments were made under the same plan and Mohela is showing those as “eligible”, pending employment certification. That’s where I assumed these payments would continue to count until the Limited Waiver expires, which is estimated this summer. That’s why I was curious if it would be better to submit another application to get these newer payments verified (and locked in) before that expires and my wife’s repayment plan no longer counts towards PSLF (but will still count toward TEPSLF).

I’ve read through your article on filing taxes separately. As you discussed, using our 2022 tax return and filing separately results in the lowest repayment plan, which is SAVE. That plan is still more than the Extended Graduated plan, but not a huge increase. If we were to switch after filing 2023 taxes, even filing separately, the 10 year standard plan actually results in the lowest payment. The next best would be ICR but it’s more than the 10 year. Therefore, if I’m thinking of it correctly it seems we’re best to stay on our current plan as long as it continues to qualify (which I think it does for now?) and then switch to the 10 year plan, which isn’t impact by taxes I don’t believe.

Sorry for yet another long response, this is just such a confusing topic and I haven’t been able to get any help from either Mohela or studentaid.

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By: Michael P. Lux, Esq. https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13394 Mon, 05 Feb 2024 20:08:46 +0000 https://studentloansherpa.com/?p=10847#comment-13394 In reply to Jordan.

Lots to cover here.

I’ll start with the easy one: I don’t see a harm in certifying employment more frequently. I suggest yearly and whenever you change jobs, but I don’t see a reason why you can’t go more frequently.

Given your high IDR payments, have you looked into filing taxes separately?

The deadline you are referencing in that article is for the Limited Waiver. There isn’t a deadline for TEPSLF, it is just a question of whether or not funding will run out before you can benefit.

Finally, as a more general thought, I’d encourage you to not rely too much on the “qualifying counts” on the mohela website. The thing that matters is certified payments and getting to 120. None of that time counts until it has been certified, and given all of the temporary programs and updates happening right now, the mohela estimates could be high or low.

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By: Jordan https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13373 Wed, 31 Jan 2024 22:33:27 +0000 https://studentloansherpa.com/?p=10847#comment-13373 In reply to Michael P. Lux, Esq..

First off, thank you very much for the quick reply and detailed response!

I guess I was under the impression my wife had already benefited from the one-time account adjustment since Mohela is showing her past 3.5+ years of payments as “qualifying”. If I’m understanding you right, her current payment plan will continue to count until the one-time adjustment is complete for all borrowers? As you mention in your linked article, this timeline seems to keep pushing back as I see now studentaid.gov is saying “summer 2024”, which I did not previously see when I was do my research a few months ago.

I have a similar understanding of the TEPSLF program. It sounds like you agree it’s risky to bank on the program being around 6 years from now. That being said, I had not seen the $283M/$700M you reference in your article, that’s very interesting to read. Also – we did not submit an application prior to the 10/31/22 deadline. However, Mohela is showing the same payment count for PSLF and TEPSLF – maybe that’s incorrect since we didn’t apply in time?

We have looked into the IDR plans and unfortunately even the best one is double what her current Extended Graduated payment is. Our best route if we do have to change payments (which is sounds like you think we will once the one-time adjustment is complete) is the standard 10-year plan since we already have several years of payments complete.

So, if I’m understanding everything right we should continue to stay on our current Extended Graduated plan until at least this summer, maybe longer, if the one-time adjustment is pushed out further. Once that’s complete we will have to switch plans. My question is do we need to get credit for these current payments by verifying my wife’s employment before that adjustment is complete? Is there a downside to submitting a new PSLF form every three months instead of once a year, just to make sure the payment tracker is counting all of our payments?

Thanks again for your help!

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By: Michael P. Lux, Esq. https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13372 Wed, 31 Jan 2024 21:10:39 +0000 https://studentloansherpa.com/?p=10847#comment-13372 In reply to Jordan.

I think there are a couple important points to cover.

First, the Extended Graduated repayment plan will count toward PSLF and IDR forgiveness until the one-time payment account adjustment happens. I suspect you will want to sign up for SAVE as soon as possible.

TEPSLF stans for Temporary Expanded Public Service Loan Forgiveness, and Extended Graduated does count towards it, but it has limited funding, and once that funding runs out, you are out of luck. Because you can’t benefit from TEPSLF until you’ve reached the full 120 payments, betting on it is risky.

Have you estimated monthly SAVE payments? How does the estimated SAVE payment compare to your Extended Graduated Payment?

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By: Jordan https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-13368 Wed, 31 Jan 2024 19:47:17 +0000 https://studentloansherpa.com/?p=10847#comment-13368 Great article! I had a follow up question regarding payment counts.

My wife is on an Extended Graduated repayment plan, which we’ve been told does not qualify for PSLF as of 2024, but her payments since 2019 did qualify thanks to the one time payment count adjustment. Although we’ve been told her current payment plan won’t qualify for PSLF, Mohela shows her January payment as “eligible” pending employment verification (similar to her Nov and Dec payments since she last submitted a PSLF form in October).

Does the fact that Mohela shows these last three payments as eligible pending employment certification mean the payments will count toward PSLF? Would you advise submitting a new form ASAP in order to verify the employment and ensure these payments update from “eligible” to “qualifying”?

Similarly, I know the Extended Graduated plan qualifies for TEPSLF, but I’ve been told there’s no guaranty that program will still be around for 6 more years once my wife hits 120 payments. Do you have any insight on this? The one representative I spoke to at studentaid.gov said it’s been around for 5+ years and there’s no sign it will end anytime soon, but we are nervous making years of payments that only qualify for TEPSLF and not PSLF if the program will just go away in a few years and we lose all of that credit.

Thank you very much for your time and advice!

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By: Michael P. Lux, Esq. https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-11151 Tue, 15 Aug 2023 14:12:17 +0000 https://studentloansherpa.com/?p=10847#comment-11151 In reply to Amanda.

Most of that time should count. The tricky part is that borrowers typically get a 6-month grace period after graduation, and that time does not count toward PSLF. However, once she was on the automatic Covid forbearance, that time will count.

That all said, the best way to verify this information is to have her send in an employment certification. This will give her an exact count and verify that she meets all of the PSLF requirements. I’d highly recommend taking this step as soon as possible.

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By: Amanda https://studentloansherpa.com/often-should-submit-ecf/comment-page-1/#comment-11147 Tue, 15 Aug 2023 02:35:10 +0000 https://studentloansherpa.com/?p=10847#comment-11147 My daughter graduated in Spring 2022. She has been working for a public university since September 2022. She will start her student loan payments this fall. Will she still be able to count the 12 months she has already worked toward PSLF?
Thanks so much

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