Will My SAVE Months Still Count Toward Forgiveness?

No, your SAVE administrative forbearance months do not count toward Public Service Loan Forgiveness (PSLF) or income-driven repayment (IDR) forgiveness — but if you worked in qualifying public service, PSLF Buyback can recover them. Months you paid on SAVE before forbearance began still count, and the SAVE plan was vacated on March 10, 2026, so you must switch to IBR or another available plan to earn forgiveness credit again.

Two kinds of SAVE time get opposite treatment: payments you made count toward forgiveness; administrative forbearance does not.

Payments you actually made under SAVE. From summer 2023 through about July 2024, you made monthly payments under SAVE’s formula. Those were qualifying IDR payments. Despite the March 10, 2026 vacatur, the Department of Education has not revoked prior qualifying payments, and the IBR-to-RAP transition rules confirm that qualifying payment history carries over when you switch plans. If you paid on SAVE and worked in qualifying employment, those months count toward PSLF. If you’re not pursuing PSLF, those months count toward IDR forgiveness on whichever plan you switch to.

Time in SAVE administrative forbearance. In July 2024, after the Eighth Circuit’s preliminary injunction blocked SAVE, the Department placed you in administrative forbearance because servicers couldn’t bill you. No payments were due, and no interest accrued. But administrative forbearance does not count toward forgiveness. Those are the “lost months” most borrowers are asking about.

PSLF requires 120 qualifying monthly payments and IDR forgiveness requires 240 or 300 — but only payments made in qualifying repayment status count, and forbearance is not qualifying status.

PSLF requires 120 qualifying monthly payments on a Direct Loan, while working full-time for a qualifying public-service employer, and on a qualifying repayment plan (any IDR plan or the 10-year Standard plan). Forbearance — including SAVE administrative forbearance — and most types of deferment do not count as “payments.”

IDR forgiveness requires 240 or 300 qualifying months (20 or 25 years, depending on plan and loan vintage) under IBR, PAYE, ICR, or — historically — SAVE. Forbearance time doesn’t qualify.

If you’re pursuing PSLF, the PSLF Buyback program is the only way to convert SAVE forbearance months into qualifying payments. It’s codified at 34 C.F.R. § 685.219(g)(6) and has been operational since 2023.

You must already have 120 months of qualifying employment, and the buyback must complete your 120 payments. Buyback is not a “bank for later” tool. If you have 60 qualifying payments and 24 months of SAVE forbearance, you cannot use buyback to add 24 to your count — the eligibility window opens only when buyback would complete forgiveness.

Loan and status eligibility. Buyback covers months on Direct Loans with a positive balance when you were working full-time for a qualifying PSLF employer and the loan was in deferment or forbearance. Months in default, in-school status, grace period, bankruptcy monitoring, or total and permanent disability monitoring cannot be bought back. FFEL, Perkins, and non-federal loans are not eligible. Buyback adds payment credit, not employment credit — you can’t buy back months you weren’t working.

The post–July 1, 2024 formula rule hits SAVE forbearance directly. Per studentaid.gov, if the buyback period starts or ends on or after July 1, 2024, the amount cannot be based on the SAVE formula. Almost all SAVE administrative forbearance falls in this window, so FSA will recalculate your payment under IBR, PAYE, or ICR — typically higher than SAVE’s 5%/10% formula would have produced.

The $0 path is still available. Under 34 C.F.R. § 685.219(g)(6)(ii), if your income during the forbearance would have produced a $0 payment on an IDR plan, you owe nothing to buy back those months. This is regulatory, not just FSA guidance — it applies regardless of which IDR formula FSA uses.

Documentation. Because SAVE forbearance has lasted 12 months or longer for most borrowers, FSA requires tax returns and a signed family-size statement for each calendar year covered, plus your usual PSLF employment certification. Submit the buyback request through the PSLF reconsideration form at studentaid.gov.

Related: PSLF Buyback Option: How It Works | PSLF Buyback Timeline: How Long Does It Take

If you’re not pursuing PSLF, there’s no buyback program for SAVE administrative forbearance. The buyback regulation at § 685.219(g)(6) is part of the PSLF rule and doesn’t apply to IDR forgiveness.

That leaves three possibilities, and only one produces credit:

• The 2024 IDR Account Adjustment is closed for SAVE forbearance. It swept past forbearance and deferment time into IDR counts, but concluded January 16, 2025 without retroactively crediting SAVE administrative forbearance.

• Two regulatory provisions could theoretically credit SAVE forbearance toward IDR — but neither is operational. § 685.209(k)(4)(iv) survives the SAVE vacatur and on its face covers post–July 2024 administrative forbearances under § 685.205(b)(8) or (9). § 685.209(k)(6) provides a separate “additional payment” pathway for forbearances not listed in (k)(4)(iv). The department has not implemented either for SAVE administrative forbearance, and both depend on the unresolved question of whether litigation-driven SAVE forbearance is the listed type.

• Switching to IBR (or another available IDR plan) starts earning credit again. The forbearance months stay missing on your count, but every month after the switch is a qualifying month. If you’re years away from forgiveness, this matters more than the lost forbearance time.

For IDR-only borrowers, every additional month in SAVE administrative forbearance is non-qualifying time on the 20- or 25-year clock with no operational recovery program to fix it.

Related: Should You Switch IDR Plans in 2026? What to Know About SAVE, PAYE, IBR, and ICR

SAVE is gone — the rule was vacated on March 10, 2026 — so you need to switch to IBR or wait for RAP (launching July 1, 2026) to keep earning forgiveness credit. The Eighth Circuit reversed an earlier dismissal of Missouri v. Trump and directed entry of final judgment. On March 27, 2026, the Department of Education issued transition guidance to all 7.5 million borrowers enrolled in SAVE.

The transition timeline. Servicer notices begin July 1, 2026, with a 90-day window to choose a new plan. If you don’t choose a plan within the window, you’ll be auto-enrolled in the Standard Repayment Plan or the Tiered Standard Plan. You don’t have to wait for your servicer to contact you — you can switch plans now.

Your options going forward.

• Switch to IBR now if you want IDR forgiveness credit to keep accruing. Contact your servicer and request the plan change. Your qualifying payment history from SAVE carries over.

• Wait for RAP if your forgiveness timeline is long and your balance is climbing. RAP launches July 1, 2026 and includes an interest waiver and monthly principal credit, but extends the forgiveness clock by five years.

• File a PSLF Buyback request once you reach 120 months of qualifying employment. See above for eligibility rules.

For most SAVE borrowers, the practical sequence is: switch to IBR now to preserve forward credit, then file a buyback request when it would close out your PSLF count.

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