Key Points
- Two unrelated problems are hitting Public Service Loan Forgiveness borrowers at once: July and August payments that haven’t posted yet, and the Education Department is rescinding qualifying months it says were credited in error during the Biden-era account adjustment.
- Our review of affected borrower accounts points to a narrow pattern: forbearance months other than processing forbearance, plus months in the Extended and Extended Graduated repayment plans that were counted when they shouldn’t have been.
- Borrowers need to validate their own counts using the MyAid TXT File and compare that to their records of PSLF certification and payments.
Borrowers chasing Public Service Loan Forgiveness have spent the past two weeks watching their qualifying payment counts move in the wrong direction. Some lost six months. Some lost more.
The fear running through borrower forums is that the Trump administration is quietly unwinding PSLF, or reversing the one-time income-driven repayment account adjustment that brought millions of borrowers years closer to forgiveness. Based on the accounts we’ve reviewed and what the Department has confirmed on the record, that is not what’s happening.
What is happening is narrower, more technical, and because the Department has explained almost none of it publicly, considerably more damaging to borrower trust than it needed to be. A banner on StudentAid.gov has told borrowers only that their counts are wrong and that a fix is coming. And here’s what were seeing analyzing dozens of reports and borrower accounts.
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Problem One: July And August Payments Haven’t Posted
The smaller of the two issues is a posting lag. Payments made in July and August are not showing up in PSLF counts on StudentAid.gov for a large number of borrowers, a likely side effect of the system overhaul that took effect July 1 to implement new loan limits and repayment plans.
This one is a data problem, not a policy decision. We’ve heard unconfirmed reports that payment counter should update within 60 to 90 days, and payments made during that window still count. However, it’s simply another reminder about why you need to keep your own proof of payment and employment throughout the process.
The frustrating part is the waiting, particularly for anyone sitting at 118 or 119 payments who can’t tell whether they’ve finished. Those borrowers are also the ones most likely to be weighing a PSLF buyback request, which is hard to evaluate when the underlying count is unreliable.
Problem Two: The Department Is Lowering PSLF Counts
The bigger issue is that the Education Department is rescinding qualifying months from borrowers’ trackers. The Department of Education said it noticed the vast majority of affected borrowers, but many have reported simply watched their totals shrink with no communication at all. Sadly, the communication pattern is familiar to anyone who followed the MOHELA false delinquency notices earlier this year.
Call center staff initially described the drops as a data error headed for correction, which many borrowers reasonably read as a promise that the lost months were coming back. Forbes reported on the resulting panic in early August, as borrowers compared notes on Reddit and found no consistent explanation. It fit a long pattern of student loan servicer errors that borrowers are left to untangle themselves.
Then, the Department of Education, in statements to POLITICO and Forbes, said the agency had found “PSLF counter code errors” traceable to changes made in May 2024. The College Investor asked the Department to confirm the specifics. The full statement we received reads:
While revamping the federal student aid systems for the July 1 changes, FSA identified multiple PSLF counter code errors stemming from changes implemented in May 2024 under the Biden Administration. These errors resulted in inaccurate payment counts for some borrowers. Like other missteps caused by the previous Administration, FSA has resolved the issue and already notified the vast majority of affected borrowers of updates to their payment counts. The Department remains committed to ensuring that every qualifying payment is properly credited to a borrower’s account.
The statement confirms the PSLF count changes were intentional and pins them to May 2024, and it says the work is done. It does not say what was corrected, and borrowers still watching their counts move can reasonably read “resolved”. But that doesn’t necessarily bring confidence back.
What The Pattern Actually Shows
The Department has not said which months it removed or why. Our review of borrower accounts and records suggests the reversals cluster around two categories: incorrectly counting forbearance time, and borrowers enrolled in a non-qualifying repayment plan.
The first category: forbearance periods other than processing forbearance. A 60 day processing forbearance while a servicer processes an IDR application counts toward PSLF, while a general or hardship forbearance never have, outside the temporary waivers that closed in 2022 and 2024. Our breakdown of which payments and periods count toward PSLF lays out the full eligibility set.
The second category involves borrowers in the Extended Repayment Plan or the Graduated Repayment Plan from late 2024 forward. That plan has never been a qualifying repayment plan for PSLF, yet payments made under it appear to have been credited anyway.
While it’s frustrating for borrowers relying on the PSLF payment tracker for eligibility, these months were never eligible to be credited, and now they’re being taken back. And that’s cold comfort to a borrower who picked a repayment plan based on a number they believed to be accurate.
Not every reduction fits the patterns above and there may be genuine errors still. If your story doesn’t match these patterns, check your records and file a PSLF Reconsideration Request for missing eligible months.
Why This Isn’t A PSLF Rollback
These changes have sparked concerns that the Department of Education is rolling back public service loan forgiveness. From what we’ve seen, this really isn’t the case.
Borrowers should note that PSLF is written into statute. The Secretary of Education cannot repeal it by memo, and forgiveness already granted and discharged is, for practical purposes, final. We walked through in detail in our analysis of whether a president can claw back student loan forgiveness.
Adjusting a payment counter is different. No debt is being un-forgiven, just a tracker is being changed. That’s legal for the Department to do and they should be doing it, especially if there were incorrect payment counts.
The frustrating part for borrowers is that they rely on this data to be accurate. This is just another issue in the 10-plus-year string of errors and changes that PSLF borrowers have dealt with.
The Real Failure Here Is Silence
We put five questions to the Department: which categories of months were pulled, how many borrowers were affected and by how many months, whether any counts were reduced in error and if those months will be restored automatically, the current processing time for a reconsideration request, and when July and August payments will post. None were answered.
Beyond that statement, the Department has released nothing publicly describing what it corrected or whether borrowers who lost legitimate months get them back. Advocacy groups including the Student Debt Crisis Center have called for a payment pause until the errors are sorted out, echoing the long waits already dogging PSLF buyback requests.
That lack of transparent communication turned a technical correction into a panic. Had the Department published a plain-language notice naming the forbearance types and repayment plans involved, most borrowers could have checked their own history in an afternoon.
What To Do Right Now
- Analyze your data. Log into your StudentAid.gov aid summary and download the My Aid Data TXT file. It shows qualifying counts loan by loan, which the dashboard tracker doesn’t — and loan-level detail is what exposes a bad repayment plan or forbearance period.
- Reconcile month by month. Match your counts against your payment history and approved employment certification forms. Our PSLF checklist covers what a complete file looks like.
- Keep both sets of records permanently. Approved ECFs and payment histories are the only evidence you control, and fixing servicer errors on your record is far easier with documentation in hand.
- File a PSLF reconsideration request if a period was removed in error. It’s currently the only formal channel, and there’s no published turnaround time. If it stalls, the student loan ombudsman is the next escalation point.
- Don’t stop paying or switch plans in a panic. Confirm your plan qualifies first. For PSLF, the qualifying payment plans are IBR, ICR, PAYE, RAP, and the Standard 10-year plan.
Editor: Colin Graves
Robert Farrington is the founder of The College Investor and is widely recognized as one of the nation’s leading voices on student loan debt and saving for college. He holds an MBA from UC San Diego Rady School of Management and has spent over 15 years researching, writing, and advising on student loans, 529 plans, financial aid programs, and saving and investing for young professionals.
Robert has been featured in the The New York Times, The Wall Street Journal, The Washington Post, NBC News, and Forbes, where he has been a regular personal finance contributor for over a decade. His work combines both professional expertise and personal experience – he successfully navigated his own student loan repayment journey and has helped thousands of readers do the same.
He is committed to making the intersection of personal finance and education transparent and accessible. You can learn more about Robert on the About Page or on his personal site RobertFarrington.com.