Millions Could Lose PSLF Access In 2026 And Beyond

The new Repayment Assistance Plan, or RAP, is set to replace most existing income-driven repayment plans beginning July 1, 2026. Borrowers using the SAVE, PAYE, or ICR plans will be required to transition into a modified version of IBR or RAP, sometime between by July 1, 2026 and June 30, 2028. We expect SAVE plan borrowers specifically to be closer to July 1, 2026.

RAP determines monthly payments based on a sliding percentage of a borrower’s adjusted gross income, with rates starting at 1% and rising to 10%. Like previous income-driven plans, RAP will qualify for PSLF, provided borrowers make 120 on-time monthly payments while working in eligible public service jobs.

The law allows borrowers to switch between RAP and the standard plan at any time, giving some flexibility. But the real pressure comes from knowing which loans and payment plans qualify for PSLF, and which no longer do.

Past Payments Still Count

For borrowers who have already made progress toward Public Service Loan Forgiveness under SAVE, PAYE, ICR, or IBR, the law offers some relief. Qualifying payments made before switching into RAP or the amended IBR will still count toward the 120-payment requirement for PSLF.

Qualifying payments made under previous income-driven repayment plans also count toward's RAP's 360 payment count threshold for loan forgiveness.

That ensures that both regular borrowers and public service borrowers aren’t starting from scratch when repayment plans change. However, tracking those qualifying payments will remain the borrower’s responsibility, especially for PSLF and certifying your employment.

Note: It's important to note that the payment count tracking does NOT go both directions (RAP <-> IBR). The law says that all prior IDR plan payments count towards RAP loan forgiveness. However, if an eligible borrower switches from RAP back to IBR, the RAP payments will not count towards IBR 20 or 25 year loan forgiveness. The result is that, while borrowers can switch (you're not trapped like under previous versions), it would make it less enticing for borrowers to use a lower RAP payment to their advantage, then switch into IBR for 20 or 25 year forgiveness, in lieu of RAP's 30 year forgiveness.

Parent PLUS Borrowers Blocked

For many parents, this is the most consequential change. Beginning July 1, 2026, Parent PLUS loans will be locked out of income-driven repayment entirely. These loans will only be eligible for the Standard Repayment Plan, which doesn’t work for PSLF (it technically qualifies, but the 10 year plan will also repay your loans before any forgiveness).

Currently, some Parent PLUS borrowers can consolidate and repay under ICR, qualifying them for PSLF if they work in public service. But that path will close for new Parent PLUS loans on June 30, 2026.

Existing Parent PLUS borrowers who consolidate before that date may still have access to ICR, and eventually shift into the amended version of IBR. But those who wait too long could lose all access to forgiveness, even if their employment would otherwise qualify.

Here's a video explaining the details:

Time Matters

The new law sets up a compressed timeline, especially for Parent PLUS Loan borrowers. 

All current PSLF-eligible repayment plans will sunset between July 1, 2026 and June 30, 2028. Existing borrowers will migrate to an amended IBR version, but it's essential you check your loans so you remain PSLF eligible.

For Parent PLUS borrowers, the situation is even tighter. The opportunity to consolidate into a PSLF-eligible repayment plan ends on June 30, 2026. But consolidation and enrolling in a repayment plan takes time. Parent borrowers in this situation should start the consolidation process as early as possible, because it can take a month or two to process. Then you still need to opt into the Income-Contingent Repayment plan. 

This tight schedule creates the risk that many borrowers (especially those not tracking these changes) could lose access to PSLF without even realizing it. A missed deadline, or a misunderstanding about loan type or consolidation timing, could end forgiveness eligibility altogether.

What Borrowers Need To Know About Loan Forgiveness Moving Forward

The shift to RAP simplifies repayment plans, but narrows the options for future borrowers who rely on PSLF. For workers already on track for forgiveness, you'll migrate into IBR and be able to continue earning PSLF qualifying payment credits. But you need to track your loans.

Future borrowers, especially those considering Parent PLUS loans, will need to be more strategic. Without access to PSLF, those loans become more rigid and potentially more expensive than private loans.

The Department of Education has yet to issue detailed timelines on when existing borrowers will migrate plans, but borrowers can expect formal rules and system updates beginning later this year.

Until then, tracking your loans, employment, and deadlines is the safest way to preserve eligibility.

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