From SAVE to Forgiveness: A PSLF Guide for Federal Borrowers
If you work in government or at a nonprofit and have federal student loans, you may have gone years without making a single payment. Between the COVID-19 pandemic payment pause and the subsequent SAVE plan litigation, some borrowers who graduated in 2019 have never made a payment at all. Many of those months may still count toward Public Service Loan Forgiveness (PSLF).
The federal government paused student loan payments from March 2020 through September 2023. All months during that payment pause count toward PSLF (Federal Student Aid, n.d.a) as long as you were employed full-time at a qualifying public service employer. You did not need to pay anything for those months to count. That is potentially up to 42 months of credit for work you were already doing.
But there are important steps between here and forgiveness, especially if some of your non-payment period falls outside that automatic window during the pandemic payment pause.
If You Were Auto-Enrolled in SAVE, You Need to Act Now
During the Biden administration, many federal student loan borrowers were automatically enrolled in the SAVE (Saving on a Valuable Education) plan, which offered the lowest monthly payments of any income-driven repayment option. For public service workers, SAVE seemed like the right path toward PSLF.
Then the courts intervened. In June 2024, a federal court blocked parts of the SAVE plan and the Department of Education placed all SAVE borrowers in administrative forbearance (U.S. Department of Education, 2025). Those months were not counting toward PSLF. On March 10, 2026, a U.S. District Court entered final judgment vacating the SAVE Final Rule in full (Missouri v. Trump, 2026). Interest on SAVE accounts resumed on August 1, 2025 (U.S. Department of Education, 2025).
If you were in this situation, you may have spent nearly two years in administrative forbearance that did not build toward your 120 qualifying payments. For borrowers who graduated into the pandemic and were then placed directly into the SAVE forbearance, that gap could represent their entire loan history with no qualifying payments at all.
Act soon if currently in SAVE plan. Starting July 1, 2026, borrowers in SAVE will have 90 days to select a new repayment plan. Borrowers who do not act will be moved automatically to the standard repayment plan or the new Tiered Standard Plan (U.S. Department of Education, 2026). Neither standard plan will qualify for PSLF after July 1. Some servicers have already started communicating this change to borrowers. Switch plans at studentaid.gov/idr.
First: Know Which Months Count and Which Do Not
Pandemic pause (March 2020 to September 2023): counts automatically.
These months count toward your 120-payment requirement (Federal Student Aid, n.d.a) if you were employed full-time in qualifying public service during that period. No payment and no separate application are needed for these months.
SAVE plan administrative forbearance (approximately July 2024 to March 2026): requires Buyback.
Borrowers placed in SAVE forbearance during litigation accumulated up to approximately 20 months that do not count automatically toward PSLF (U.S. Department of Education, 2025). These months may be recoverable through the PSLF Buyback program, but only if buying them back brings your total to exactly 120 qualifying payments.
Your Step-by-Step Path to Forgiveness
Step 1: Log In and Assess Your Situation
Before anything else, log into your account at StudentAid.gov. Everything that follows requires being logged into the Federal Student Aid website. Once you are logged in, use the Loan Simulator. This tool can be used to see your federal student loan types and shows projected payment amounts under each repayment plan in one place, as well as projected forgiveness amount if seeking PSLF.
FFEL and Perkins loans do not qualify for PSLF and must be consolidated into a Direct Consolidation Loan first (MOHELA, n.d.). Loans consolidated on or after July 1, 2026 will only be eligible for the Repayment Assistance Plan (RAP) for income-driven repayment, as IBR, PAYE, and ICR will not be available for newly consolidated loans (U.S. Department of Education, 2025). RAP qualifies for PSLF. Consolidate at studentaid.gov/loan-consolidation.
Step 2: Enroll in a Qualifying Repayment Plan Immediately
If you were auto-enrolled in SAVE and in forbearance since approximately July 2024, any months working for a qualifying employer have not been counting toward PSLF. You need to be on a qualifying income-driven repayment plan for payments to count going forward. This is true even if you have never made a payment before.
Starting July 1, 2026, servicers will send notices with a 90-day enrollment deadline (U.S. Department of Education, 2026). Do not wait for that notice. Your balance has been accruing interest since August 1, 2025, and every month without an active IDR plan is a month without PSLF credit (U.S. Department of Education, 2025). Apply for IBR, PAYE, or ICR now. The new Repayment Assistance Plan (RAP), which also qualifies for PSLF, launches July 1, 2026 (U.S. Department of Education, 2025).
The standard repayment plan and the new Tiered Standard Plan do not qualify for PSLF (U.S. Department of Education, 2025). Borrowers who miss the 90-day window will be auto-enrolled in one of those plans (U.S. Department of Education, 2026), stopping PSLF progress entirely. PAYE and ICR will also be phased out under the One Big Beautiful Bill Act (U.S. Department of Education, 2025). IBR is the most durable existing option for PSLF borrowers.
Step 3: Use the PSLF Help Tool to Certify Your Employment
This is the step that formally enrolls you in the PSLF program. The PSLF Help Tool walks you through employer eligibility verification, Employment Certification Form (ECF) completion, and digital submission to your employer for signature. The entire process happens in one workflow. Submitting triggers the transfer of your loans to MOHELA, the sole servicer for PSLF accounts (MOHELA, n.d.).
Have your employer's federal EIN (from Box b of your W-2) ready. Submit a separate form for each employer and make sure date ranges cover every period you want counted, including the pandemic pause years.
If your employer is not in the database or shows as "undetermined," manually enter their information and upload your W-2 as supporting documentation. Loan transfers take 4 to 6 weeks. Keep making payments during the transfer, as they still count. Submit a new PSLF form every year and whenever you change employers (Federal Student Aid, n.d.b). Illinois borrowers have additional protections during servicer transfers under the Student Loan Servicing Rights Act (110 ILCS 992/, 2019), which requires servicers to respond to inquiries, properly credit payments, and provide accurate information about repayment options.
Step 4: Audit Your Payment History and Identify Gap Periods
Once your employment is certified, review your PSLF payment history and tracker on StudentAid.gov. Pandemic pause months should already appear as qualifying. Other forbearance months will need Buyback (Step 5).
Buyback is only available if you already have 120 months of qualifying employment and buying back the months would result in forgiveness (MOHELA, n.d.). It cannot be used to build up payments gradually earlier in the process.
Step 5: Apply for PSLF Buyback If You Have Non-Qualifying Gap Months
The PSLF Buyback program lets you retroactively convert eligible administrative forbearance months into qualifying payments by paying a lump sum equal to what your IDR payment would have been. The buyback amount is based on the lowest IDR plan payment you would have been eligible for at the time of the forbearance, not the SAVE formula (National Association of Student Financial Aid Administrators, 2025). Costs are likely to be higher than many SAVE borrowers may have expected.
- Gather tax returns (adjusted gross income and family size) for each year of your forbearance period.
- Submit a PSLF Reconsideration request and select "PSLF Buyback" as the request type.
- Track your status and watch for an offer email. Continue making IDR payments while you wait.
- Pay the lump sum via the Pay.gov link in your offer email within 90 days.
The Department of Education reported 88,170 PSLF Buyback applications pending as of February 28, 2026 (American Federation of Teachers v. U.S. Department of Education, 2026). Submit as early as you are eligible. Offers expire after 90 days and may be recalculated at a higher amount if resubmitted.
Step 6: Keep Up with Annual Maintenance
Two things are required every year to stay on track:
- Recertify your IDR plan to keep your payment amount accurate and maintain plan eligibility: studentaid.gov/idr
- Certify the prior year's employment by submitting a new PSLF form via the Help Tool to update your payment count and prevent disputed periods: studentaid.gov/pslf/form
Step 7: Apply for Forgiveness at 120 Qualifying Payments
Once your tracker confirms 120 qualifying payments, submit your final PSLF Application for Forgiveness through the Help Tool.
Unlike cancellation of debt under income-driven repayment plans, which became taxable again at the federal level in 2026 (National Association of Student Financial Aid Administrators, 2026), PSLF forgiveness carries a permanent federal statutory exemption and remains tax-free (Turner, 2025). State income tax treatment varies, so check your state's rules in the year your loans are forgiven.
Questions?
Contact your loan servicer directly for questions about your individual loans and account status. Visit the FSA Feedback Center for disputes or unresolved servicer issues.
Illinois borrowers have state-level resources available as well. The Illinois Attorney General's Office provides student loan debt assistance (Illinois Office of the Attorney General, n.d.) and actively advocates for borrower rights, including challenging federal rules that unlawfully limit access to student loans for professional degree programs (Illinois Office of the Attorney General, 2026). The Illinois Department of Financial and Professional Regulation (IDFPR) licenses and oversees student loan servicers operating in Illinois (Illinois Department of Financial and Professional Regulation, n.d.) and accepts complaints when servicers fail to meet their obligations under state law.
References
American Federation of Teachers v. U.S. Department of Education, No. 1:25-cv-00802-RBW, Status Report (D.D.C. Mar. 16, 2026).
Federal Student Aid. (n.d.a). 5 tips for public service loan forgiveness success. U.S. Department of Education.
Federal Student Aid. (n.d.b). How to manage your public service loan forgiveness (PSLF) progress on StudentAid.gov. U.S. Department of Education.
Illinois Department of Financial and Professional Regulation. (n.d.). Student loan servicers.
Illinois Office of the Attorney General. (2026, May 19). Attorney General Raoul challenges unlawful U.S. Department of Education rule limiting access to student loans for professional degree programs.
Illinois Office of the Attorney General. (n.d.). Student lending and recent actions.
MOHELA. (n.d.). PSLF information. Federal Student Aid.
Missouri v. Trump, No. 4:24-cv-00520-JAR, slip op. (E.D. Mo. Mar. 10, 2026).
National Association of Student Financial Aid Administrators. (2025, January 30). PSLF buyback program: A way to have SAVE plan forbearance months counted towards loan forgiveness.
National Association of Student Financial Aid Administrators. (2026). Welcome to 2026: Some student loan forgiveness is now taxable.
Student Loan Servicing Rights Act, 110 ILCS 992/ (2019). Illinois General Assembly.
Turner, C. (2025, December 23). Federal student loans are changing: Here's what to expect in 2026. NPR.
U.S. Department of Education. (2025). U.S. Department of Education continues to improve federal student loan repayment options, addresses illegal Biden administration actions.
U.S. Department of Education. (2026). U.S. Department of Education announces next steps for borrowers enrolled in unlawful SAVE plan.
AI Use Disclosure: This article was drafted and revised with assistance from an AI tool in accordance with the Student Money Management Center's AI Use Disclosure policy. All content has been reviewed and verified by SMMC staff. Links and program details were current as of the publication date; federal student loan policy changes frequently. Verify current requirements at studentaid.gov before taking action.
