Comments on: The Limited Waiver On PSLF Expired, But FFEL Borrowers Can Still Benefit

By: Michael P. Lux, Esq.

Michael P. Lux, Esq. — Mon, 23 Oct 2023 13:04:48 +0000

In reply to Mike. There is a ton going on here, so I really can't say anything for certain without looking at your account myself. A data entry error is definitely a possibility with all the consolidations on her account. The one insight I would add is that the one-time IDR account adjustment has not happened yet. Some of the borrowers who have enough payments with the adjustment had their IDR counts updated right away, but the rest of us will have to wait until 2024 when they make the adjustment for everyone else. In other words, your wife's qualifying payment months may jump when the adjustment happens for her.

By: Mike

Mike — Sun, 22 Oct 2023 05:15:13 +0000

Hi Michael –

My wife took out a number of Parent PLUS loans, including one in August 2018 and one in September 2018. Those loans were consolidated in November 2018. That consolidated loan was later consolidated with a February loan (which itself was a consolidated loan). The final double-consolidated loan was disbursed in April 2019.

MOHELA lists the August and September loans as having entered repayment those months; but the first qualifying payments (via a special waiver) for the double-consolidation loan after the August loan isn’t until November. Would the current account adjustment period allow for the months of August, September, and October to be treated as “qualifying payment months”?

But wait – there’s more! For some reason, MOHELA is also listing __February to May of 2018__ as qualifying (via the special waiver) – even though that time period predates any of the loans that ended up being part of the double consolidation. (My wife took out some other Parent PLUS loans earlier that year and in prior years, but those were not part of the 2018-19 academic year double consolidation. What’s your best guess? Data entry errors? (I did find several incorrect dates – off by several years – in some of MOHELA’s records (inherited from FedLoan).)

Any insight or suggestions would be welcome. Thanks.

By: Michael P. Lux, Esq.

Michael P. Lux, Esq. — Mon, 14 Aug 2023 13:16:57 +0000

In reply to Beth. Glad to hear it!

By: Beth

Beth — Sat, 12 Aug 2023 21:10:58 +0000

In reply to Michael P. Lux, Esq..

Dear Michael,

Thank you so much for your thorough response!

I really appreciate your guidance and help with carrying some of the weight on this mountainous journey. : )

That was exactly the information I was missing.

By: Michael P. Lux, Esq.

Michael P. Lux, Esq. — Tue, 08 Aug 2023 19:59:33 +0000

In reply to Beth. This is a tricky one, and I want to make sure I understand your questions correctly. The way I understand it, you have 7 years of qualifying employment. If this has already been certified, that means you need three more years (or, more specifically, 36 payments). The three years as a medical resident for a for-profit hospital likely do not count as a for-profit hospital wouldn't be a PSLF-eligible employer. (that said, it doesn't hurt to try to get it to qualify... the worst they can say is no.) The IDR adjustment will help with many aspects of qualifying for PSLF, but the one thing it can't fix is employer eligibility. If you are not working or not working in a public service job, that time won't count toward PSLF.

By: Beth

Beth — Tue, 08 Aug 2023 19:51:52 +0000

Hi Michael, On behalf of all of us confused PSLF borrowers, thank you so much for shedding some light on the topic of PSLF forgiveness and the one-time IDR account adjustment. After finally speaking with a trained employee at Mohela, I got the confirmation that most PSLF borrowers who have reached forgiveness thanks to the IDR account adjustment should by now (August 2023) have already been contacted about the discharge of their student loans. However, what was less clear was how the number of qualifying payments are counted, particularly for PSLF in conjunction with the one-time IDR account adjustment. I have acquired 7 years of PSLF qualifying payments working for a nonprofit hospital and prior to this, I have also accumulate 3 years of IDR-qualifying forbearance working as a medical resident in a for-profit hospital. Can both periods be added together to obtain the 10-year PSLF forgiveness? In other words, under the special IDR waiver, can IDR-qualifying months be added to PSLF-qualifying months to reach the 120 months required for PSLF forgiveness, even if the IDR period was not acquired through a PSLF employer? Or, is a consolidation of all my direct loans necessary to benefit from the IDR waiver?