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New PSLF Waiver Questions Answered

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FAQs PLUS a scandal expose!

New PSLF Waiver Questions Answered (Audio Version)

I’ve been hearing lots of questions about the PSLF, and I’d like to answer the most frequently asked ones here.

If you have a question that isn’t answered here, you can send it directly to me using the form at the bottom of this page.

In case you missed it, here are the links to the PSLF Waiver Explained 4-Part Series:

Part 1: What’s the PSLF?

Part 2: What are the new changes to PSLF?

Part 3: How do these changes affect me?

Part 4: The easiest way to sign up for the PSLF waiver

Here’s the how-to video:

Ok, let’s get to your questions!

What does it mean when it says Qualified Employer is waived?

All loan payments, in order to be counted towards PSLF, had to have been made while at a qualifying employer. This is still true under the waiver.

What’s waived are these 2 requirements:

  1. You could only apply for PSLF while employed at a QE.
  2. In order to receive final loan forgiveness, you had to be currently employed with a QE.

Essentially, this means that it doesn’t matter who you currently work for, or if you work at all, as long as your past payments were made while you worked at a QE, they’re eligible under the waiver.

If you’ve made some payments, but not all 120 payments, you can consolidate your loans into a Direct Consolidation loan whether you’re employed or not, for example, if you’re between jobs.  But going forward, in order to count towards PSLF, all payments must be made while you work for a QE.

Wait, why didn’t I sign up for the PSLF when I was a resident?

If you’re wondering why you didn’t sign up for this back in the day, well, if you borrowed before 2009-10, it’s because your loans weren’t eligible.  The only loans eligible for PSLF are Direct Loans.  (That’s why you have to consolidate your current loans into a Direct Consolidated loan.)  Direct Loans didn’t exist before 2009, so if you borrowed before then, your loans were not eligible for PSLF.  

Loans before 2009 are called FFELP (Family Federal Education Loan Program). There’s also the Perkins Loan program.

If I already consolidated my loans, but they’re still federal loans, (I didn’t consolidate with a private lender) can I consolidate them again into a Direct Consolidated loan?


I consolidated my federal loans after graduation, and they are still federal loans (I didn’t consolidate them into private loans) but I noticed they weren’t eligible for the Covid-19 relief, when payments were suspended.  Why?

Yes, the loans are still federal loans, but they are FFELP loans.  FFELP loans don’t qualify for the Covid-19 relief because they are not owned directly by the government.

WTF does this mean? Allow me a brief history lesson…and an expose of what I consider to be a true scandal:

Prior to 2010, loans would be issued by private institutions, and these loans were backed by the federal government but not owned by the government. This set up is why student loans & college tuition got so cray cray out of hand.  

Due to the Higher Education Act of 1965, private lenders could now lend federally backed student loans— so if the borrower defaulted, the government would reimburse the lender, essentially removing the risk from the private lenders, thus creating a lucrative situation for the lenders.

So what did the lenders do?  They said, “Hey!  Universities! You can charge more! Because students can borrow more (from us)!”  So the lenders and the universities worked in tandem—raising tuition and the number of student loans. Tuition rose way faster than inflation, which is why baby boomers could afford to put themselves through college and you have to take out a mortgage-worth of loans.

There are two expose books & an article in the Wall St Journal about it. Oh, also my fantabulous IG Reels commentary.

Dr. Wagner posing a question, with index finger poised on chin, and one eyebrow raised.

What are FFELP—Federal Family Education Loan Program loans?

These include Stafford, Grad PLUS, Parent PLUS and FFELP consolidation loans.  FFELP was introduced as part of the Higher Education Act of 1965, which made student loans suddenly super available to everyone, and allowed private lenders to lend federal loans. This created a lucrative opportunity for private lenders, who encouraged universities to raise tuition which could now be paid by all of this easily accessible loan money. This situation is why loans & tuition got so cray cray out of hand—  And why tuition rose so damn fast (blazing past inflation).  So your FFELP loans are technically not owned by the government, just backed by the government, which is why they weren’t eligible for suspension of loan payments during the covid times, even though they are federal loans.  Direct loans are called Direct because they are lent Directly by the federal government.

Don’t let the creativity of these names blow your mind.


Don’t get confused by the TEPSLF.  TEPSLF is “Temporary Expanded Public Service Loan Forgiveness”. This was a plan introduced by Congress in 2018 that allows borrowers who already made 120 loan payments but were on the wrong repayment plan (ie: not an IDR) to retrospectively apply for loan forgiveness. TEPSLF has all the other strict requirements of PSLF.

Is there any rush to applying for this before the 10/31/22 deadline?

If your loans are already Direct and you’re on an IDR, then no.

If you’re not on an IDR, then only the payments before October 2021 will be eligible for the PSLF waiver.  All payments after October 2021 must be IDR in order to be eligible for the PSLF waiver.  And all payments going forward, after you sign up for the PSLF waiver must be made on an IDR plan in order to count.

For all official info on the PSLF Waiver, use this webpage: https://studentaid.gov/announcements-events/pslf-limited-waiver

Confusing webpages on studentaid.gov (don’t use these):

This page explains TEPSLF.  That’s not what we’re applying for.  You want the PSLF Limited Waiver.


This next link is the regular PSLF application.  For the PSLF waiver, the government prefers that you use the PSLF help tool.  (Even though it’s the same form.)


Do I have to give the PSLF Application (with Employer Certification) to all my employers?

Yes— each qualified employer that you’ve had while making payments must confirm your employment dates for the government.

What are the IDRs?

IDR stands for Income Driven Repayment plan.  There are 4 of them, and they are:

REPAYE, PAYE, ICR and IBR.  These are the only four acceptable repayment plans under the new PSLF waiver.  

Technically, the original PSLF also accepted the 10-year Standard Repayment Plan (SRP), which is just the amount of money you owe divided by 120.  

From what I’ve read, my understanding is that the 10-year SRP does not count for the PSLF waiver, and *definitely* not the 30-year SRP, which is what you’ll see if you consolidate your loans to a Direct Consolidation loan.  So don’t pick that.

Ironically, IDRs were created to make loan repayment feasible, by making them income based.  But you may find, like I did, that switching from your current repayment plan to an IDR actually increases your monthly payment!

Helpful Summary Table: PSLF vs TEPSLF vs PSLF Waiver

Date IntroducedOctober 1, 20072018 Consolidated Appropriations ActOctober 6, 2021
Expiration Daten/a“This opportunity is temporary, has limited funding, and must be provided on a first come, first served basis. Once all of the funds are used, the TEPSLF opportunity will end.”October 31, 2022
What it doesForgives remaining student loan debt after 120 payments, for Direct loans on an IDR plan.   (Prospective)
Forgives Direct loans after 120 past payments on a non-IDR plan (Graduated, Graduated Extended) (Retrospective)Forgives remaining student loan debt after 120 payments, applies to past payments, includes FFELP, and any repayment plan. Refunds Direct loan payments over 120 payments. (Retrospective)
Who’s it forYou enrolled in PSLF at the start of loan repayment and are working towards 120 payments. You already made 120 payments, but they were made with a graduated repayment plan, instead of the IDR plans.  You met all the other PSLF criteria.You never enrolled in PSLF, but have been making loan payments on any repayment plan, on federal loans that previously didn’t qualify for PSLF.
Repayment Plan
(Income Driven Repayment=IDR)
Must be:
Allows past payments under “Graduated Repayment” plans to qualifyAny repayment plan for past payments.  
IDR plans for future payments.
Eligible loansFederal Direct LoansFederal Direct LoansFederal Direct Loans & FFELP, Perkins can now qualify when consolidated to Direct Consolidated Loan
Payments had to beOn time Full amount
On time Full amount All 120 payments completed (applies to past payments only)Late-ok Any amount ok Any repayment plan ok Past payments while not enrolled in PSLF ok
Payments must be made while working at a qualified employerYESYESYES
Can enroll in PSLF while not employed or not employed at QENONOYES
Can receive final forgiveness while not employed or employed at QENONOYES
How to applyComplete a PSLF Application at start of repayment.Complete a PSLF & TEPSLF Certification & Application (PSLF Form) after 120 payments made (irrelevant now that there’s the waiver)If your loans are direct loans, complete a PSLF Application 
If your loans are FFELP or Perkins, consolidate your loans into a Direct Consolidation loan and complete a PSLF Application
Summary Table: PSLF vs TEPSLF vs PSLF Waiver moneymedschool.com

Official Department of Education PSLF Waiver press release.

What are your questions? Send them to me in the form below, and I’ll answer them. (I’ll answer you personally if you include your email. Email address will not be added to my list, and it will remain private.)

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