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Committee staff say PSLF credit for tiered-standard-plan payments unlikely; will re-check

Negotiated-rulemaking Committee (U.S. Department of Education) · December 5, 2025

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Summary

A constituency raised whether payments made under a tiered standard repayment plan could be counted for Public Service Loan Forgiveness if they equal the 10-year standard-plan payment; department staff said they do not believe that is permissible but will reevaluate to confirm.

A constituency representative asked whether borrowers placed in a tiered standard repayment plan who make payments equal to what they would have paid under a 10-year standard repayment plan could have those payments count toward Public Service Loan Forgiveness (PSLF).

Tamar Huffman posed the hypothetical and asked whether borrowers could elect to make payments "not less than would have been paid under the 10 year standard under the repayment plan ... in order to qualify for PSLF." A department representative replied, "We do not believe that is permissible. We will reevaluate that just to confirm." The transcript records that department staff will revisit the question to provide firm guidance.

The exchange did not produce a final legal interpretation or formal guidance. Committee members referred the technical question back to department analysts for clarification and indicated the answer would be confirmed after internal review.