Financial Planning and Analysis

Do PSLF Payments Have to Be 10 Consecutive Years?

Get clear on Public Service Loan Forgiveness. Understand how 120 qualifying payments are counted towards debt forgiveness, regardless of their sequence.

The Public Service Loan Forgiveness (PSLF) program is a federal initiative that forgives the remaining balance on Direct Loans for borrowers who have made 120 qualifying monthly payments. This program encourages careers in public service by offering significant student loan debt relief. A common question is whether these 120 payments must be consecutive. This article clarifies the PSLF requirements and process.

Core PSLF Eligibility Requirements

To qualify for Public Service Loan Forgiveness, borrowers must meet several criteria. Only loans received under the William D. Ford Federal Direct Loan (Direct Loan) Program are eligible. Other federal loan types, such as Federal Family Education Loan (FFEL) Program loans or Perkins Loans, must be consolidated into a Direct Consolidation Loan to become eligible. However, only payments made on the new Direct Consolidation Loan count toward the 120-month payment requirement.

Qualifying employment is also a key factor. Eligible employers include U.S. federal, state, local, or tribal government organizations, including U.S. military service. Most not-for-profit organizations tax-exempt under Section 501(c)(3) of the Internal Revenue Code also qualify. Other not-for-profit organizations providing specific public services may qualify if most of their full-time employees are in those areas. Employment must be full-time, generally at least 30 hours per week, or the employer’s definition of full-time, whichever is greater.

Payments must also be made under a qualifying repayment plan. These primarily include income-driven repayment (IDR) plans like Income-Based Repayment (IBR), Income-Contingent Repayment (ICR), Pay As You Earn (PAYE), and Saving on a Valuable Education (SAVE). While the standard 10-year repayment plan also qualifies, borrowers on this plan often pay off their loans before reaching 120 payments. IDR plans are typically more advantageous for PSLF, as they base monthly payments on income and family size.

Understanding the 120 Qualifying Payments

A common misconception is that PSLF payments must be consecutive; they do not. The 120 qualifying monthly payments do not need to be consecutive, meaning breaks in employment or payments do not disqualify a borrower. Such interruptions merely extend the overall time to reach the required 120 payments.

A qualifying payment must meet specific criteria. Each payment must be made after October 1, 2007, for the full amount due, and no later than 15 days after the due date. The payment must also be made while the borrower is employed full-time by a qualifying employer and under a qualifying repayment plan.

Periods of deferment or forbearance generally do not count toward the 120 payments. However, specific exceptions exist, such as the COVID-19 payment pause, where paused payments counted if employment was certified. If a borrower changes jobs between qualifying employers or temporarily leaves qualifying employment, their payment count does not reset. Progress simply pauses until they resume qualifying employment and payments.

Certifying Employment and Payments

Certifying employment and payments is a proactive step to ensure PSLF progress is accurately tracked. The Public Service Loan Forgiveness (PSLF) Employment Certification Form (ECF), often completed through the PSLF Help Tool on the Federal Student Aid website, serves this purpose. Submitting this form regularly verifies qualifying employment and correct payment counts.

Borrowers should submit the ECF annually or whenever they change qualifying employers. This consistent submission builds a reliable record of eligible employment and payments, preventing potential issues when applying for forgiveness. The form requires borrower and employer details, plus specific employment dates, certified by an authorized official from the employer.

After ECF submission, the loan servicer reviews the information to determine employer eligibility and update the borrower’s qualifying payment count. This updated count can typically be viewed online through the borrower’s student loan account. Regular ECF submission allows for timely identification and correction of discrepancies, helping borrowers monitor progress toward the 120 qualifying payments.

The PSLF Forgiveness Application Process

Once a borrower has made 120 qualifying payments, the final step is to submit the application for forgiveness. Borrowers should apply only after completing their 120th payment. It is also important that the borrower is still employed by a qualifying employer at the time of application and when forgiveness is granted.

The forgiveness application is known as the PSLF and Temporary Expanded PSLF (TEPSLF) Application. This form is available on the Federal Student Aid website, and the PSLF Help Tool can assist in its completion. The tool guides borrowers through the necessary steps and can pre-fill portions of the form based on previously certified employment.

Completed applications can be submitted electronically through the Federal Student Aid website, which is often recommended, or by mail or fax. After submission, the loan servicer reviews the application to confirm all eligibility requirements. This review process may involve requests for additional information. Borrowers are then notified of the forgiveness decision, with processing times typically ranging from 30 to 90 days for discharge after the 120th payment is confirmed.

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