Borrowers seeking Public Service Loan Forgiveness now face additional hurdles

Student debt relief has always been a complex equation. For borrowers working in public service, the Public Service Loan Forgiveness (PSLF) program offered one of the few long-term relief paths that aligned with mission-driven careers. A decade of payments, coupled with full-time work in government or qualifying nonprofit roles, was the promise. And for many, it still is.

But recent developments—especially a series of policy shifts and processing breakdowns under the Trump administration—have added new friction. Eligibility may shift. Repayment options are in flux. And thousands of borrowers sit in administrative limbo.

If you're navigating PSLF today, you're not just managing your monthly payments—you're navigating uncertainty. But the right information, paired with calm financial planning, can keep your progress intact. Let’s walk through what’s changed, where the bottlenecks are, and how to protect your long-term plan.

First, it’s important to clarify: PSLF is still in effect. If you are working in a government job or qualifying nonprofit and have made eligible payments, your path toward forgiveness remains valid.

What’s different now is that three concurrent developments have made it harder for borrowers to make uninterrupted progress:

1. A new executive order signed by former President Donald Trump that narrows who qualifies based on employer type.
2. A court-ordered halt to the Biden-era SAVE repayment plan, disrupting how borrowers can remain in qualifying payment plans.
3. A growing backlog in the PSLF Buyback program, which was designed to credit borrowers for missed months.

These aren’t just bureaucratic quirks. Each of these changes carries real risk: delayed progress, disqualified payments, and for some, potential loss of eligibility altogether. But with the right framing, they can also be managed.

1. The Eligibility Question: Which Jobs Still Qualify?

At the core of PSLF is one key requirement: working full-time at a qualifying public service employer. Historically, that meant a government agency or a 501(c)(3) nonprofit. You didn’t need your job to be in education or health. If your employer qualified, your role counted.

But that’s where Trump’s March 2025 executive order introduces uncertainty. The order specifies that organizations involved in activities such as “illegal immigration,” “human smuggling,” “child trafficking,” or “disruption of the public order” may no longer qualify as eligible employers. While this sounds targeted, in practice the definitions are vague—and that’s the problem.

Consider nonprofits that provide aid at the border, legal defense for asylum seekers, or services in protest-prone areas. These could now fall into gray zones. And the Department of Education has yet to publish a definitive list of disqualified organizations.

If your employer has previously been certified as eligible and your PSLF payments are up to date, your existing credits won’t be retroactively stripped. That’s been confirmed by policy experts and legal analysts: the executive order can only apply going forward.

But if you're applying now—or switching jobs soon—your safest course is to choose employers that are unmistakably within the traditional bounds: state departments, public K–12 schools, city agencies, and major hospital systems.

Don’t panic if your current role could be affected. Instead:

• Keep documentation of your employer certifications to date.
• Submit your PSLF Employment Certification Form (ECF) annually or whenever you change jobs.
• Monitor any future Department of Education guidance on the executive order.

And if your employer is later disqualified, your past progress remains valid. What matters most is what you do next.

2. The Repayment Plan Bottleneck: SAVE Is Blocked, But You Still Have Options

Another core requirement of PSLF is that your 120 monthly payments must be made under a qualifying repayment plan. Until recently, the Biden administration’s SAVE plan (Saving on a Valuable Education) was the newest and most affordable option, especially for low- to middle-income borrowers.

But courts have temporarily blocked the Education Department from enrolling new borrowers into SAVE, and many who tried to switch into alternative plans are now stuck. According to court filings, more than 1.5 million borrowers are waiting for their new repayment plan forms to be processed.

That matters because if you're not in the right repayment plan—even if you're paying monthly—you’re not accumulating PSLF credit. Only payments made under qualifying plans (like IBR, PAYE, or the now-blocked SAVE) count.

Here's the nuance: when you submit a request to change repayment plans, your loan often goes into what's called processing forbearance. For up to 60 days, that status still counts toward PSLF. But if your application takes longer than that—or your status is changed to general forbearance—your monthly progress stops counting. Unfortunately, many borrowers are unaware of when this transition happens.

If you're affected by the SAVE plan halt or are unsure whether you're currently in a qualifying plan, take these steps:

• Log in to your Federal Student Aid (FSA) account and check your current repayment plan status.
• If your application is pending, note the date you submitted it. If 60 days have passed and you're still not in an active plan, contact your servicer to confirm whether your loans have entered general forbearance.
• Keep copies of every communication and submission receipt. These can protect you if delays are later contested in court.

The good news, according to expert Mark Kantrowitz, is that eligible borrowers stuck in the backlog will eventually be placed into a PSLF-qualifying plan retroactively—as long as the delay wasn’t their fault. But don’t rely on passive forgiveness. If you’re close to your 120-month target, every delayed payment matters. Staying vigilant is part of your planning strategy now.

3. The Buyback Backlog: Retroactive Credit With a Waiting Game

In response to past inconsistencies, the Education Department launched the PSLF Buyback program to allow borrowers to "buy" credit for missed months during deferment or forbearance—if they were employed full-time at a qualifying job during those gaps. In theory, this was a win: a second chance for those who had been misled by servicers or trapped in administrative delays.

But in practice, Buyback has become a new choke point. As of June 2025, more than 65,000 Buyback requests are pending. And unlike traditional PSLF tracking, these applications involve retroactive assessment and payment verification, making them slower to process. For many borrowers, Buyback is the last step before total forgiveness. But it may also be the longest.

Let’s say you worked for a qualifying nonprofit from 2014 to 2024. But for two of those years, you were placed in deferment due to hardship or paused your payments due to COVID forbearance. Under normal PSLF rules, those 24 months wouldn’t count toward your 120. With Buyback, you can submit a request to retroactively pay for those months—and receive PSLF credit. But it’s not automatic. You need to apply through the FSA's Reconsideration portal, and your employer must confirm your full-time status during that time.

Should you apply?

Yes—if you're past the 10-year mark and only a few months short due to technicalities, Buyback is a valuable tool. But manage your expectations.

• The process takes time.
• The backlog isn’t moving fast.
• And the Department has not announced a formal timeline for clearing it.

Financial advisors recommend applying while also continuing to make active payments under a qualifying plan. Don’t wait passively for Buyback to “finish” your forgiveness.

If you’re managing PSLF in 2025, the goal hasn’t changed—but the route requires tighter coordination. Use this moment to clarify your standing and prevent delays that can compound. Here are four planning questions to ask yourself:

1. Am I in a qualifying repayment plan right now—and is that plan fully processed?
   If not, take action. The longer you're stuck in a processing queue, the greater your risk of hitting non-qualifying status.
2. Have I submitted recent employment certification for PSLF?
   Even if you haven’t changed jobs, submit an updated form. Annual certification creates a paper trail that protects your progress.
3. Is Buyback right for me—and have I initiated the application?
   If you're past 100 qualifying months and missed some due to forbearance, start your Buyback request now. It won’t replace current progress, but it may close the gap.
4. If my employer is at risk of losing eligibility, do I have a transition plan?
   Don’t wait for a surprise ruling. Identify alternative roles now in case future guidance affects your current job.

Planning isn’t about reacting to worst-case scenarios—it’s about making room for better outcomes, even when policies shift.

PSLF has always demanded a high degree of paperwork, patience, and trust in the system. But now, the margin for error is smaller. Legal challenges, political changes, and processing backlogs mean even one misstep can delay forgiveness by months—or years. But even with these changes, PSLF remains one of the most substantial debt relief opportunities for public service professionals.

And it’s still worth protecting.

So don’t let the complexity derail your broader financial goals. Think of PSLF as one part of a long-term stability plan that includes:

• Emergency savings (at least 3–6 months of expenses)
• Retirement contributions (start with 10% if possible)
• Tax planning (especially if forgiven loans may become taxable under future rules)
• Protection planning (disability or income coverage if your career path depends on public service)

The goal isn’t to predict policy. It’s to stay aligned with your bigger picture: clearing debt, building security, and making values-driven career choices without long-term financial penalty.

When forgiveness feels like it’s getting further away, the temptation is to stop engaging—to wait until the system "gets fixed" or the backlog clears. But this is the moment to lean in, not retreat. Because in PSLF, consistent action counts more than perfect timing.

• Each certified job form is one less question later.
• Each qualifying payment—even during forbearance—could tip the scales toward eligibility.
• And each month you remain intentional keeps you aligned with the 10-year finish line.

PSLF is still working. It's just under strain. Your strategy doesn’t need to be aggressive—it needs to be aligned. The smartest moves right now aren’t big leaps. They’re small, consistent steps that preserve progress—until the system catches up.