
Renee is a school counselor in Ohio who makes $65,000 a year. In July 2024 she had 102 qualifying payments toward Public Service Loan Forgiveness, which put her about a year and a half from having the rest of her $58,000 balance wiped out. Then the courts froze the SAVE plan, her loans went into forbearance, and her PSLF counter stopped moving. She kept showing up to work every day for two more years. None of those months counted. (Renee is a hypothetical, but her situation is common.)
If you're pursuing PSLF and you were on SAVE, you're probably in some version of her spot right now. Servicers started mailing 90-day notices on July 1, 2026, and for most of the roughly 7 million borrowers still in SAVE forbearance, that window closes in September or October, according to The College Investor. If yours hasn't closed yet, it's close. What you do before it closes decides whether your count starts moving again or stays stuck.
Why PSLF borrowers have more at stake than everyone else
For most people leaving SAVE, the question is which plan gives them the lowest bill. For PSLF borrowers, there's a second question that matters more: does the plan count?
PSLF forgives whatever federal Direct Loan balance you have left after 120 qualifying monthly payments made while working full time for a government agency or a 501(c)(3) nonprofit. It's also one of the few forgiveness programs that stays tax-free in 2026, even though regular income-driven forgiveness became taxable again this year. And it's paying out. Federal Student Aid data compiled by Student Loan Planner shows $87.6 billion forgiven for 1,183,600 borrowers through September 2025, an average of $74,100 each. Another 2,583,200 borrowers with $228.1 billion in loans had certified qualifying employment and were still on the way.
So the prize is big. The risk is that a missed letter drops you into a plan that doesn't count.
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The default plan is the trap
If you don't pick a plan within 90 days of your notice, your servicer moves you into the Standard plan or the new Tiered Standard plan, depending on your loans. Tiered Standard doesn't count for PSLF at all. The old 10-year Standard plan technically counts, but it's built to pay your loan off in 120 months, so by the time you'd qualify there's nothing left to forgive.
For PSLF, the plans you can pick from stack up like this:
| Plan | Counts for PSLF? | What to know |
|---|---|---|
| Repayment Assistance Plan (RAP) | Yes | New July 1, 2026. Payment is based on your income and dependents, and it's the only income-based plan for loans taken out after July 1, 2026. |
| Income-Based Repayment (IBR) | Yes | Stays open long term. It can beat RAP on monthly cost for some higher earners. |
| PAYE and ICR | Yes, for now | Expected to close to new enrollment around July 1, 2027, and phase out by 2028. |
| Tiered Standard | No | Fixed terms of 10 to 25 years based on balance. A common default landing spot. |
| 10-year Standard | Counts, but | You'd pay the loan off in full by month 120, so you'd get nothing forgiven. |
My take: if you're four or five years into PSLF, RAP or IBR are the safe picks, because both will still exist when you cross the finish line. PAYE can work as a short stopover (The College Investor points out it avoids some interest capitalization if you plan to move to RAP later), but you'll have to move again before 2028, and every forced move is another chance for paperwork to go sideways.
Don't wait for the letter, either. A notice being mailed doesn't mean it reached you. If your servicer has an old address or email, your 90 days can run out before you know they started.
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Those forbearance months: what buyback costs now
Back to Renee. Her SAVE forbearance months don't count toward PSLF, and plenty of borrowers are learning that the hard way when they log in and see a counter that hasn't budged since 2024.
The fix is PSLF Buyback. Once you have 120 months of certified, qualifying employment, you can pay for the months you spent in certain forbearances or deferments while working for a qualifying employer, as long as buying them back gets you to 120. You pay roughly what your income-driven payment would have been for those months.
Two things changed in 2026 that make this harder.
First, it got pricier for SAVE borrowers. On March 31, 2026, the Education Department said it would stop using SAVE's formula to price bought-back months. Forbes reported it under the headline "Student Loan Forgiveness Just Got Much More Expensive For 88,000 Borrowers." If you were on SAVE, the department now looks to the income-driven plan you were on before SAVE.
I ran a rough version for Renee, using the 2025 federal poverty guideline of $15,650 for a single person and assuming her buyback gets priced on the newer version of IBR. Under SAVE's undergraduate formula (5% of income above 225% of the poverty line), her payment would have been about $124 a month. Under new IBR (10% of income above 150% of the poverty line), it's about $346. She needs 18 months bought back:
- Priced the old way: about $2,234
- Priced under IBR: about $6,229
That's a real jump. It's also small next to a balance in the $50,000 range that disappears once she hits 120. Your number will depend on your actual income and which plan you were on before SAVE, so treat hers as a ballpark.
Second, it's slow. As of April 30, 2026, about 88,000 buyback requests were pending, though the department estimated 18,000 to 19,000 were duplicates. April was the first month the department decided more requests (about 6,870) than it received (about 4,790). Since then it has stopped publishing buyback data, though Forbes reported in August that borrowers say approvals are coming through.
So should you buy back months?
If you've already hit 120 months of qualifying employment, I'd file the request now. Asking doesn't commit you to paying anything. When the department makes you an offer, you get a set window to accept and pay it.
In the meantime, keep making payments on RAP or IBR. Each qualifying payment shrinks the number of months you'd need to buy. If your regular payments get you to 120 before the offer shows up, you can skip it.
If you haven't hit 120 months of employment yet, buyback isn't available to you. Your job is to get onto a qualifying plan quickly so the count starts again.
The employer rule that didn't happen (yet)
You may have heard that your employer could lose PSLF eligibility. In October 2025, the Education Department finalized a rule that would let it disqualify employers it found had a "substantial illegal purpose," with examples like aiding violations of federal immigration law. It was set to take effect July 1, 2026.
It never did. On June 30, 2026, federal courts in Massachusetts and Washington, D.C. vacated the rule in two separate cases. The D.C. court found the Secretary had exceeded her authority under the Higher Education Act, which covers full-time work at any 501(c)(3). The Massachusetts ruling by Judge Myong J. Joun also found the rule arbitrary and capricious and a First Amendment violation.
The government appealed in late August, according to NASFAA, sending one case to the First Circuit and the other to the D.C. Circuit. The vacatur stays in place while those appeals run, so the old employer rules apply today.
This isn't something to panic over, but it's a good reason to certify your employment now. Every month already on your record with an approved employer is a month that's harder to argue about later.
Paperwork that keeps your count clean
Most PSLF horror stories come down to records. A few habits fix that.
Certify your employment at least once a year and any time you change jobs. Use the PSLF Help Tool on StudentAid.gov, which checks your employer and routes the form for your HR office to sign electronically. After it's processed, open your PSLF tracker and confirm the months you expect are there.
Screenshot your tracker after each update and save it somewhere outside the servicer's website. If a count ever drops, you'll want proof of what it said before.
Watch for this year's gaps. If your count jumped back to life in the fall but skipped a month during the switch, raise it with your servicer in writing now instead of discovering it at month 119.
And make every payment in full and on time, especially on RAP. RAP's interest subsidy only applies when you make the full scheduled payment each month, according to The College Investor's breakdown of the plan.
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Bottom Line
PSLF still works, and it's still tax-free. The danger this fall is a quiet one: a missed notice, a default plan that doesn't count, or a forbearance stretch you never fixed. Here's what to do this week:
- Log in to StudentAid.gov and your servicer's site. Update your mailing address, email, and phone, then check what repayment plan you're in today. If it says SAVE or forbearance, you're on the clock.
- Pick RAP or IBR before your 90 days end. Run both through the Loan Simulator on StudentAid.gov with your latest tax return, and choose the cheaper one. Don't let your servicer pick for you.
- Certify your employment through the PSLF Help Tool. Then screenshot your updated count.
- If you have 120 months of qualifying employment, request buyback now. It's free to ask. Keep paying while you wait, and decide on the offer when it arrives.
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