Income Driven Plan Details

• IBR (Income Based Repayment)
• New IBR
• ICR (Income Contingent Repayment)
• PAYE (Pay As You Earn)
• REPAYE (Revised Pay As You Earn)

Which ones you are eligible for depends on what kind of federal student loans you have, your income, and when you got your loans.  You can try to see what your payments will be using our calculator:  https://studentloanplans.app or the Dept. of Education website: https://studentaid.gov/loan-simulator/, or you can ask your servicer.

There are two primary federal loan programs.  Federal Family Education Loans (FFEL) and Direct Loans (DL).  FFEL loans are not eligible for the majority of these IDR plans but can be made eligible by consolidating them into the DL program.  In most cases, consolidation will reset any forgiveness counts you may have already accrued so research this carefully before taking any action.  Perkins loans can also be consolidated into the DL program to access these plans.  No other loans, including private or state loans, can ever be made eligible for IDR plans.

If your income is high compared to your loan balance, the non-income related repayment plans such as the extended, graduated and standard consolidation plans might be a better fit for your situation.  The calculators linked above will also give you the estimated payment amounts on these plans.  Remember, the name of the game is paying the least amount over time and depending on your balance and income, that may mean paying your loans as aggressively as possible rather that pursuing loan forgiveness under these income driven plans.

Old IBR – FFEL borrowers regardless of when they got the loans and Direct Loan borrowers who are not new borrowers on/after July 1, 2014. If your loan was disbursed prior to July 1, 2014, you are not a new borrower on/after July 1, 2014. Borrower must also have a partial financial hardship (see below for information on partial financial hardships). You can find your loan disbursement date on www.studentaid.gov, the Department of Education website or on your loan servicers website. If you have outstanding federal student loans, you can create an account to get your loan information.

New IBR – Direct Loan borrowers who are new borrowers on/after July 1, 2014. Borrower must also have a partial financial hardship. You are a new borrower on/after July 1, 2014, if all of your loans were disbursed on or after July 1, 2014. Consolidating loans made prior to July 1, 2014 does not make you a new borrower.

ICR – Direct Loan borrowers regardless of when loan was received. If you have FFEL loans, you must consolidate into a Direct Consolidation loan to be eligible for this plan. This is no partial financial hardship requirement. This is the only IDR plan available to Parent Plus borrowers and they must transfer their Parent PLUS loans (whether they are Direct or FFEL) into a Direct Consolidation Loan to be eligible.

PAYE – Direct Loan Borrowers who were new borrowers on/after October 1, 2007 and received a Direct Loan disbursement on/after Oct. 1, 2011. FFEL borrowers who were new borrowers on/after October 1, 2007, may qualify by consolidating their FFEL loans into a Direct Consolidation Loan. Borrowers must also have a partial financial hardship.

REPAYE – Direct Loan Borrowers regardless of when they got the loans. No partial financial hardship requirement. Caution: If you are married, please see the section below on Effect of Marriage on IDR Plans.

Plans that require a partial financial hardship: IBR (old and new versions) and PAYE plans.

A partial financial hardship is when your IDR payment amount is less than what you would have paid under a ten-year standard repayment plan.

A partial financial hardship is determined as follows:

1. Use the link below to find the poverty level for your family size based on the state where you live. Multiply that amount by 1.5 (150% of the poverty level). Your family size includes both spouses and dependents. The poverty level is the same for the lower 48 states. Alaska and Hawaii have different levels. https://aspe.hhs.gov/prior-hhs-poverty-guidelines-and-federal-register-references

Subtract the 150% of the poverty level amount from the Adjusted Gross Income you reported on your most recent federal tax return. This is your “discretionary income.” Multiply your discretionary income by 10% (.10) for New IBR and the PAYE plans. For the Old IBR plan, multiply your discretionary income by 15% (.15). This is the total amount you will pay on your loan over a year. Divide that amount by 12 for your monthly payment amount.

2. If the IDR payment amount is less than what your payment would be under the 10-year standard plan, then you have a partial financial hardship.

When you are on an IDR plan that requires a partial financial hardship (PFH) and your income increases enough that you no longer have a PFH, you can remain on the plan, however, your payments will be adjusted to repay the balance you owed when you started on the plan within 10 years. If that payment is too high check to see whether there is another payment plan not based on income that can give you lower payments. If you’ve never consolidated your loans, you might have a lower payment by consolidating and going on the standard plan for consolidation loans that has terms up to 30 years depending on the loan balance. The standard plan doesn’t offer any forgiveness.

Plans that don’t require a Partial Financial Hardship: ICR and REPAYE
For the ICR plan payments are the lesser of 20% of Discretionary Income or the payment amount you would have under the 12-year standard payment multiplied by an Income Percentage Factor. Your discretionary income is the amount by which the Adjusted Gross Income (AGI) on your federal tax return exceeds 100% of the applicable poverty Guideline. Your discretionary income is multiplied by .20 which gives you the total you would pay in payments over a year. Divide by 12 to get the amount of your monthly payment. The Income Percentage Factor is an amount published annually by the U.S. Dept of Education that is used to calculate your IDR payment. It’s based on your annual income.  https://www.federalregister.gov/documents/2021/04/14/2021-07605/annual-updates-to-the-income-contingent-repayment-icr-plan-formula-for-2021-william-d-ford-federal

For the REPAYE plan, discretionary income is the amount by which the AGI on your federal tax return exceeds 150% of the Poverty Guideline. Your discretionary income is then multiplied by .10 which gives you the total you would pay in payments over a year. Divide by 12 for your monthly payment amount

If your income has decreased since you did your last tax return, you can do the calculation based on your current income. The servicer will ask for proof of your current income.

With IDR plans, if you are married and file federal taxes jointly, both spouses’ incomes (and federal student loans) are used to determine whether you have a partial financial hardship. If you file federal taxes separately, only the borrower’s income is used, but there is one exception.  With the REPAYE plan, it doesn’t matter whether you file taxes jointly or separately, both spouses’ incomes will be used to calculate payments.

There is an interest rate subsidy for some IDR plans if negative amortization occurs (this happens when the payment amount doesn’t cover all the interest due). Payments are always applied to interest before being applied to principal.

For the Old IBR, New IBR, and PAYE payment plans there is an interest subsidy for subsidized loans for the first 3 years on the plan of 100% of the difference between the monthly payment and the monthly accruing interest. There is no interest subsidy for unsubsidized loans.  Paying more than what your monthly payment is will not negatively affect your interest subsidy eligibility.

The REPAYE has the most generous interest subsidy. For REPAYE, subsidized loans have a subsidy of 100% of the difference between the monthly payment and the monthly accruing interest for the first 3 years on the plan and 50% thereafter. For unsubsidized loans, there is a subsidy of 50% of the difference between the monthly payment and monthly accruing interest.

Periods where your loan was under an economic hardship deferment (not a forbearance) will count against the three year interest subsidy on all of the IDR plans.  You do not get a new three year period of subsidy by switching plans.

For IBR and ICR it takes 300 qualifying payments (at least 25 years), for New IBR and PAYE it takes 240 qualifying payments (at least 20 years). For REPAYE it takes 240 qualifying payments (at least 20 years) for undergrad loans and 300 qualifying payments ( at least 25 years) if you have any loans for graduate school.

A qualifying payment is a payment in the full amount due within 15 days of the payment due date.

We advise borrowers to look at what they would pay over time and choose an affordable payment plan that will result in paying the lowest total amount over time. We have a calculator on our website that can help https://studentloanplans.app. You can ask your servicer for help or if you have Direct Loans only you can use the Student Aid website: Dept. of Ed calculator: https://studentaid.gov/loan-simulator/

All IDR plans require borrowers to certify their incomes and family size each year. Your servicer will contact you each year when it is time for you to certify your income and family size and ask for documentation of both.

If your income decreases during the year or your family size increases, you can ask for a payment recalculation to be done at that time based on your lower current income or increased family size.  If your income increases during the year, it’s not necessary to notify your servicer.

If you fail to re-certify your income and family size and are on the IBR, New IBR, or PAYE plan, you can remain on the plan, but your payment amount will be adjusted to repay the balance you owed when you went on the IDR plan based on a 10-year term. If you were on the REPAYE plan, you will be removed from the plan and your payments will be based on the balance at that time, amortized over the reminder of the 20- or 25-year forgiveness period or the next 10 years, whichever is less and there will be no forgiveness. For the ICR plan, you will be removed from the plan and your payments will be recalculated to pay off the balance in 10 years from the time you

If you want to return to making payments under an IDR plan after failing to recertify, you can reapply for an IDR plan and provide information on your income. For REPAYE plans, however, the process is a bit more involved as the Department of Education explains in its Q&As on Income Driven Repayment Plans.

You can return to the REPAYE Plan only if you provide your servicer with documentation of your income for the period when you were not on the REPAYE Plan. Depending on how long it has been since you left or were removed from REPAYE, this could be the same income documentation (such as your most recent tax return) that you would normally submit to enter REPAYE, or it could be income documentation from prior years.

Your servicer will then calculate what your monthly payment amount would have been under the REPAYE Plan during that period and will compare this amount to your monthly payment amount under the alternative repayment plan (or any other plan) over the same period.

If the amount you would have been required to pay under the REPAYE Plan is more than what your monthly payment amount was under the alternative plan or another plan during this period, your new REPAYE Plan payment amount will be increased. The amount of the increase will be equal to the difference between what you were required to pay during the period when you were not on the REPAYE Plan, and the amount you would have been required to pay if you had remained on the REPAYE Plan, divided by the number of months remaining in your 20- or 25-year repayment period.

If you are on the IBR, or New IBR plan, and no longer have a partial financial hardship, fail to re-certify your income by the deadline, or choose to leave the IDR plan, the unpaid interest will be added to your principal balance. This is called capitalization.

If you are on the ICR plan, unpaid interest in connection with negative amortization is added to your principal balance annually.

For the PAYE plan, unpaid interest is added to the principal balance (up to a maximum of 10% of the loan balance when you entered PAYE), when you no longer have a Partial Financial Hardship, if you fail to recertify your income by the deadline, and if you choose to leave the plan.

For the REPAYE plan, unpaid interest is added to the principal amount of your loan (no limit to the amount added) if you are removed from the plan for failing to recertify your income by the deadline or if you choose to leave the plan.

Borrowers can change to another payment plan or other IDR plan at any time, but only payments made under an IDR plan or a payment in the amount you would pay under the 10-year standard plan will count toward forgiveness.  If you change from one IDR plan to another, payments under both plans will count toward forgiveness.

When you change from the IBR plan to a different repayment plan, you will first be placed on the Standard Repayment Plan. If you want a repayment plan other than the Standard Repayment Plan, you must make at least one payment under the Standard Plan or one payment under a reduced-payment forbearance before you can switch to another plan.

Loans that are in default are not eligible for any IDR plan. If the loan is consolidated out of default or rehabilitated and in good standing, it will again be eligible for an IDR plan. Payments made while in default do not count towards forgiveness.

You can find additional information about the IDR plans, as well as some valuable FAQ’s here https://studentaid.gov/manage-loans/repayment/plans/income-driven/questions

In April, 2022, the Department of Education announced a one time temporary waiver that may help those pursuing forgiveness under the IDR plans.  You can read about this waiver below.

Below is a summary of the information we know as of April 29^th, 2022 regarding this waiver.  We are expecting a significant amount of additional guidance in the coming months.  Keep an eye on  this page for updates, which will be dated.

On April 19^th, 2022, the Department of Education (ED) announced a one-time waiver for how qualifying payments are counted for the income driven plans (IDR) available to federal student loan borrowers.  This includes those with Federal Family Education Loan (FFEL) program loans as well as those with federal Direct Loans (DL).  The waiver applies to Parent Plus , Graduate Plus, Stafford loans and consolidation loans under both programs.  It is unclear at this time if Parent Plus will need to consolidate to access this waiver.

The waiver, which will be implemented sometime later this year, will give federal student loan borrowers credit for one IDR payment for every month the loan was in a repayment status (other than default) or any deferment status other than an in-school deferment status  if the deferment was in place prior to 2013. Only economic hardship deferments will be counted after 2013.  These credits will count towards the forgiveness component that is part of every IDR plan.  FFEL borrowers will need to consolidate into the DL program via www.studentaid.gov to be given credit for these periods.  DL borrowers do not need to consolidate unless they have loans with multiple periods of repayment in which case they should consolidate so the consolidation loan gets the higher count.  In some cases, periods of forbearance will be counted but the details of how that will be applied are not available yet.

If a loan attains enough payments under the one-time waiver, it will receive forgiveness.  The forgiveness will happen after either 20 years (240 months) or 25 years (300 months).  We are waiting for guidance on which situations will result in forgiveness under which timeline.  It is also unclear how far back these payments will be counted under this one time adjustment.  Our speculation is they will either go back to 1994 when the ICR plan was first available, or 2009 when the first of the other IDR’s were implemented.

If a loan does not have enough months after the one-time waiver is applied, borrowers MUST be under an IDR or ten-year standard plan to accrue additional IDR payments.  Note that for some borrowers this might not be worth it, especially if their income is much higher than their remaining balance and they still have quite a few years left to qualify for IDR forgiveness.  Borrowers can determine their IDR payment amounts by using the loan simulator at www.studentaid.gov  IDR plans include Income Based Repayment (IBR), Pay As You Earn (PAYE), Revised Pay As You Earn (REPAYE) and Income Contingent Repayment (ICR).  Note that Parent Plus loans are only eligible for ICR and only if consolidated under the DL program.  Parent Plus loans that have been consolidated more than once can sometimes obtain eligibility for the other IDR plans.

There are still many outstanding questions about this one-time IDR waiver.  We will update this summary and FAQ’s as information becomes available.  You can find our FAQ’s here.

Please note if it’s not here we don’t know yet.  You can read the announcement here https://studentaid.gov/announcements-events/idr-account-adjustment