The Limited PSLF Waiver Ended — Here's How it Worked

The Limited PSLF Waiver ended on October 31, 2022. While it ran, it gave people who worked in public service anytime after Oct. 1, 2007 retroactive credit toward Public Service Loan Forgiveness for payments made under any repayment plan, on any federal loan, whether or not those payments were on time or for the full amount due.

Nothing about the waiver can be applied for today. But the problem it was built to solve — payment counts that came up short because of the wrong loan type, the wrong plan, or years parked in forbearance — has not gone away, and there are still ways to address it.

Related: Does Forbearance Count Toward PSLF?

The PSLF Waiver was a temporary rule change that retroactively credited borrowers for past payments that didn’t qualify under the standard Public Service Loan Forgiveness requirements. It targeted public service workers, and it answered PSLF approval rates that had sat below 2%.

The waiver let borrowers get PSLF credit for payments that ordinarily wouldn’t have counted, including:

• Payments made toward Federal Family Education Loans and Perkins Loans.

• Loan payments made under non-qualifying repayment plans.

• Late payments.

• Past payments for less than the full amount.

Military service members got a specific benefit: all months spent on active duty counted toward PSLF, even if the loans were in deferment or forbearance and not being repaid. Educators could also count time toward both Teacher Loan Forgiveness and PSLF.

The waiver period ended on Oct. 31, 2022. To qualify, a borrower had to have started the consolidation process and applied for the waiver by that date.

Time spent in an in-school deferment did not count toward the waiver. Time spent in certain military-related deferments, economic hardship deferments, and any deferment before 2013 other than in-school deferment did count.

Related: Are Teachers Public Service Workers?

The waiver rebuilt payment counts. A borrower told they had 14 qualifying payments after a decade of public service could come out the other side with a count in the triple digits, because months discarded for technical reasons were added back.

That mattered most for two groups. Borrowers with FFEL or Perkins loans had been shut out of PSLF entirely, because those loan types earned no credit no matter how long someone worked in public service. And borrowers who had spent years on plans that weren’t income-driven had been making real payments the whole time that simply weren’t the qualifying kind.

The waiver didn’t forgive anyone who hadn’t already done the work. It counted work that had already been done.

No. Private student loans never qualified, and neither did federal loans refinanced with a private lender. Federal loans made through the FFEL Program and held by a commercial lender were eligible, but only if they were consolidated into a Direct Loan before Nov. 1, 2022.

Related: Can Private Student Loans Be Forgiven?

The PSLF Waiver started on Oct. 6, 2021, when the U.S. Department of Education announced it would temporarily waive certain eligibility requirements. The waiver ended a little over a year later, on Oct. 31, 2022.

While it was open, the waiver reached nearly all federal student loan borrowers who had worked full-time for the government or a nonprofit anytime after Oct. 1, 2007. Public servants who had borrowed parent loans for their children were the main exception — Parent PLUS Loans weren’t eligible.

A borrower didn’t need to have worked in public service for that entire stretch. Someone who changed employers or left for the private sector still qualified, and received credit for the payments made while working in qualifying employment.

Borrowers who were eligible for the PSLF Waiver:

• Full-time government and nonprofit employees.

• Retired public service workers.

• Borrowers who no longer worked in a public service job, including those who left during the pandemic.

• Borrowers with joint spousal consolidation loans made through the Direct Loan Program. Joint spousal consolidations made under the FFEL Program couldn’t be consolidated into a Direct Loan and were shut out — the law letting those borrowers separate their loans didn’t pass until after the waiver window closed.

Borrowers who were not eligible:

• Parents who borrowed PLUS Loans for their child’s education, including consolidation loans that paid off Parent PLUS Loans.

• Public servants who only had private student loans.

• Borrowers who stopped working in public service before Oct. 1, 2007.

• Volunteers at government and nonprofit organizations.

• Borrowers who worked for a private company that provided services to the government or a nonprofit.

• Teachers and employees at a for-profit charter school or university.

• Borrowers who had only worked in the private sector.

Related: What Happened to TEPSLF

Before the deadline, a borrower applied by submitting a PSLF Form on StudentAid.gov and then faxing the signed employer’s certification to MOHELA, or uploading it through the MOHELA website if MOHELA was already their servicer.

Borrowers with FFEL or Perkins Loans also had to submit a consolidation application before the same Oct. 31 cutoff.

Borrowers with Parent PLUS Loans were locked out of the waiver unless they had other federal student loan debt borrowed for their own education. To qualify, they would have needed to combine the parent loans with their own. A Direct Consolidation Loan formed that way could still be forgiven once it reached 120 qualifying payments, even though some of the underlying loans were Parent PLUS Loans.

Parent PLUS rules have changed substantially since then.

Learn More: Parent PLUS Loan Forgiveness

The Education Department’s early estimates ran from roughly three to four months. Applications far outran them, many arriving in the final days before the deadline, and processing slowed. Long waits were common through 2023.

That backlog has long since cleared. Waiver applications are no longer pending, and there is no waiver status left to check.

No. The Education Department never released a separate form or application for the waiver. Borrowers applied using the existing PSLF Form on StudentAid.gov through the PSLF Help Tool, or by downloading the Employment Certification Form.

Refunds for extra PSLF payments on Direct Loans were meant to be issued without a request — any payment beyond the 120 PSLF requires was returned to the borrower, though in practice many people had to follow up with their servicer.

Refunds weren’t available for excess payments made on FFEL Loans before consolidating, or for borrowers whose loans had already been forgiven or paid off.

Overpayment refunds still work this way today for borrowers who pass 120 qualifying payments.

Related: How Does a PSLF Overpayment Refund Work?

The waiver delivered billions of dollars in relief, but for many more borrowers it updated payment counts without producing immediate forgiveness.

Those borrowers kept working in public service and kept making payments toward the 120-payment threshold.

Separately from the waiver, the Education Department issued new PSLF regulations in late 2022 that broadened the kinds of payments that qualify. Those rules took effect July 1, 2023. Under them, borrowers can receive credit toward PSLF for partial, late, and lump-sum payments. Adjunct and contingent faculty get credit for at least 3.35 hours of work for every credit or contact hour taught. The department also set full-time employment at 30 hours per week.

Unlike the waiver, these were permanent rule changes rather than a temporary window. The PSLF regulations were rewritten again effective July 1, 2026, but these three provisions carried through and still govern PSLF today.

Related: PSLF Weighted Average Consolidation Rules

The waiver is closed and the one-time IDR account adjustment that followed it is closed too — its consolidation deadline was June 30, 2024, and the department finished applying it. Neither can be requested now.

What remains is more durable than either.

PSLF credit is still retroactive. There is no deadline to submit a PSLF form. Qualifying employment going back to Oct. 1, 2007 can be certified at any time, and a month counts if you were working full-time for a qualifying employer at any point during it. Periods that were rejected years ago can be resubmitted and reviewed under today’s standards.

Start by certifying everything. A short payment count is usually caused by uncertified employment rather than anything exotic. Filing a PSLF form for every period you haven’t certified yet is the step that resolves the most counts, and it costs nothing.

Then, if you already have 120 months of employment, look at buyback. Buyback closes a payment gap, not an employment gap — it’s only open to borrowers whose account already shows 120 months of approved qualifying employment but fewer than 120 qualifying payments. If that’s you, months spent in deferment or forbearance that overlapped with that employment can be converted into qualifying payments by paying what you would have owed on an income-driven plan. If your income during those months would have produced a $0 payment, the buyback costs nothing. It also doesn’t require you to still be working for a qualifying employer. You can estimate what those months would cost with our PSLF buyback calculator.

If your certified employment is still short of 120 months, buyback isn’t available yet — continuing to work and certify is what moves you toward it.

Some months can’t be recovered any way. Time in school, in a grace period, in default, in bankruptcy, or in disability monitoring falls outside both the old waiver and current buyback.

Related: PSLF Buyback Program | Can PSLF Be Retroactive?