- No enrollment in SAVE
- No opportunity to request enrollment in the plan with the lowest monthly payment
- No new enrollments in PAYE (ok for those already enrolled)
- No new enrollments in ICR except parent plus (those already enrolled can stay enrolled)
So as expected, IBR was Congressionally passed back in 2009 and will continue. We expect that IBR applications will re-start processing shortly. If you have received a large bill to restart payments now, you might want to consider getting an IBR application in or apply for forbearance if available to avoid negative credit reporting and the other effects of a default. Talk with us if you would like more information on options to reduce an IBR payment, how IBR works including the forgiveness aspect, or another program such as a TPD discharge or bankruptcy discharge.
FSA also updated the IDR Court Actions page which has detailed guidance on recertifications. https://studentaid.gov/announcements-events/idr-court-actions.
You may note that this announcement page by FSA states that as of March 26, 2025, the online application is once again available for eligible borrowers to apply for IBR, PAYE or ICR. However, we believe that access to PAYE and ICR is only available for people were were previously enrolled. An exception exists for those with Parent Plus loans as Congress has provided that a consolidation of a Parent Plus loan at any time will then permit someone to enroll in ICR.
The jury is still out on those with previous double consolidations. The Rule allows someone with a Parent Plus loan to bypass ICR and apply for a more lenient payment plan by doing a double consolidation by July 2025. We don’t believe someone will be able to do this going forward as there is likely no time to complete a double consolidation and the servicers do not appear to be processing those. We hope that the 2023 Rule by ED will allow those who have already completed a double consolidation to enroll in IBR (not SAVE as it is still subject to an injunction and not expected to survive).
