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Department proposes tiered standard repayment plan, removes 'partial financial hardship' from IDR entry test
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Summary
ED staff outlined a new tiered standard repayment plan that changes fixed‑plan repayment periods by borrower balance and proposed replacing the 'partial financial hardship' test in income‑driven repayment with an 'applicable amount' construct; negotiators pressed for operational examples and written follow‑up.
The U.S. Department of Education presented substantial changes to repayment rules during the negotiated rulemaking, proposing a new "tiered standard repayment plan" for direct loans disbursed on or after July 1, 2026, and edits to income‑driven repayment rules that remove the term "partial financial hardship."
Tammy Abernathy described the tiered standard repayment plan as a fixed‑payment option with repayment periods determined by the borrower’s total outstanding principal at the time they enter repayment: under $25,000 — 10 years; $25,000 to less than $50,000 — 15 years; $50,000 to less than $100,000 — 20 years; $100,000 or more — 25 years. The department said standard amortization would apply and that all direct loans would be eligible. ED staff also said they had restructured section 685.208 to put repayment periods next to each plan for clarity.
On income‑driven repayment (IDR), ED proposed removing the statutory term "partial financial hardship" from several provisions and replacing it with a new "applicable amount" metric in the regulations. For example, the department described the IBR calculation as 15 percent of the borrower’s adjusted gross income above 150 percent of the U.S. poverty guideline for the borrower’s family size. Members asked how frequently a borrower could request recalculation and whether the change would trigger capitalization or removal from IDR; ED staff said recalculation could be requested and that operational and capitalization scenarios would be taken back for written clarification.
Negotiators raised multiple operational hypotheticals — borrowers with loans made before July 1, 2026 but entering repayment after that date; borrowers in grace; borrowers with multiple loans or multiple repayment start dates; and how parent PLUS loans interact with wrap or tiered plans. Eric Hardy (Federal Student Aid) and other ED staff said proration across servicers is used now and that some scenarios require additional operational work; ED committed to provide written clarifications and run specific examples off‑table. The department also said the repayment assistance plan (referred to as "WRAP" in the discussion draft) would be kept under review as part of IDR changes and that the department would provide further details in follow‑up materials.
Negotiators were asked to submit complex scenarios in writing so ED can model operational outcomes and return with clarified regulatory text and examples.

