Public Service Loan Forgiveness has long drawn criticism because of high ineligibility rates fueled by strict and detailed requirements and miscommunication from federal student loan providers.
Over the past several years, the Department of Education has sought to address eligibility barriers and confusion through the Temporary Expanded Public Service Loan Forgiveness program, or TEPSLF, and the limited PSLF waiver, as well as permanent regulation changes.
New Restrictions Coming in 2026
Uncertainty has grown as changes are being made to the definition of a PSLF “qualifying employer.” President Donald Trump issued an executive order in March 2025 that instructed Secretary of Education Linda McMahon to “exclude organizations that engage in activities that have a substantial illegal purpose” from eligibility as PSLF employers.
The order gives several examples of such activities, among them “aiding or abetting violations of … federal immigration laws;” supporting terrorism or aiding terrorist organizations; and engaging in child abuse, including “chemical and surgical castration or mutilation of children or the trafficking of children to so-called transgender sanctuary states for purpose of emancipation from their lawful parents.”
After several months of public hearings and negotiated rulemaking, the department released a final rule in October 2025 that would amend the definition of “qualifying employers” to “exclude organizations that engage in unlawful activities such that they have a substantial illegal purpose, including supporting terrorism and aiding and abetting illegal immigration.” Changes will go into effect July 1, 2026.
Some leaders in higher education are skeptical of the changes.
“?There was very little change — even after a lot of pushback from folks at the negotiating table and a lot of outcry from the nonprofit world and direct service organizations and education advocates,” says Michele Zampini, associate vice president of federal policy and advocacy at The Institute for College Access & Success. “Our sense is their goal is to put organizations doing the kind of work that the administration does not support in a position where they either have to fight against the administration’s designation of them as not eligible or take preemptive action to try and protect their employees from getting in the administration’s crosshairs regarding eligibility.”
However, Stacey MacPhetres, senior director of education finance for EdAssist by Bright Horizons, says the use of “substantial” in the final rule’s language is key.
[Related:Private vs. Federal Student Loans: What’s the Difference?]
“I think the reality is the vast majority of organizations that fall under PSLF eligibility are not that,” she says. “The department has actually said in one of their announcements that they think this will be less than 10 organizations a year. A lot of folks were saying, ‘Is this going to affect health care?’ ?The ‘substantial’ illegal purpose is important because if you’re a health care provider and you provide all things on the spectrum of health care, your substantial purpose is not any of those things that are defined.”
Here’s what borrowers should know about PSLF and how to qualify.
What Is Public Service Loan Forgiveness?
PSLF was introduced in 2007 as an incentive for more people to pursue careers in public service, in exchange getting some of their federal student loan debt erased. The program aims to help borrowers who become teachers, nurses or police officers, for example.
Qualification Requirements
The forgiveness comes with stipulations. Borrowers must make 120 qualifying monthly payments, which takes at least 10 years, while being employed full time in a qualifying job at an eligible employer. Any federal student loan debt left after that point is forgiven.
Many borrowers, however, have been stymied by the program’s logistics over the years and have lost out on forgiveness — often on a minor technicality.
A student loan payment meets requirements for PSLF if it is made after Oct. 1, 2007, under a qualifying repayment plan. Consecutive payments are not required and paying more per month does not reduce the time it takes to earn loan forgiveness.
Eligible Employers
To participate, you must be employed by a federal, state, local or tribal government organization, including the U.S. military; a nonprofit organization that is tax-exempt under Section 501(c)(3) of the Internal Revenue Code; or be a full-time AmeriCorps or Peace Corps volunteer.
Nonprofits without 501(c)(3) status are still considered a qualifying employer if they offer one of the following public services: emergency management, military service, public safety, law enforcement, public interest law services, early childhood education, public service for individuals with disabilities and the elderly, public health, public library services, school library or other school-based services.
Labor unions, partisan political organizations and for-profit organizations are ineligible for PSLF.
To see if your employer meets the qualifications, use the PSLF Help Tool on the Education Department’s Federal Student Aid website.
Other Requirements
There are certain loan and repayment plan requirements, as well. Only direct federal student loans qualify, so the Federal Family Education Loan and Federal Perkins Loan programs are not accepted unless you combine them into a federal direct consolidation loan.
As for repayment plans, there are two options: an income-driven repayment plan or the 10-year standard repayment plan. But given the 10-year timeline with the standard repayment plan, a borrower who goes that route and sticks to the plan would have no remaining balance to forgive.
End of a Loan-Repayment Option
The Biden administration rolled out an income-driven repayment option, SAVE, or the Saving on a Valuable Education plan, in August 2023. In this plan, monthly payments decrease from 10% to 5% of a borrower’s discretionary income, and no one earning less than the equivalent of $15 an hour annually has to make payments.
But SAVE is on pause due to lawsuits challenging it. Enrolled borrowers are in forbearance — a temporary status that allows reduced or no payments — and interest began accruing Aug. 1, 2025. The legal resolution may be moot because SAVE will be phased out by July 1, 2028 as part of the One Big, Beautiful Bill Act.
[See: How Average Student Loan Debt Has Changed in 10 Years.]
“Borrowers should be aware that at some point between now and then, likely before then, they’ll be in a position where they have to switch plans,” Zampini says.
“If a borrower is in a position to be more proactive and apply for enrollment in a different income-based plan, then I would advise them to get that process started as soon as possible — just given the backlog and application processing that we’re seeing from the servicing side. However, if a borrower needs to stay in that safe forbearance, that’s certainly an option as well. But I would warn them that (it) could change at any time between now and the termination of the plan. They should just be prepared for what they would do in the event that it was terminated more quickly.”
How to Apply for PSLF
It’s recommended that a borrower fill out an employer certification form annually, which requires a recent W-2 form or a federal employer identification number. Use the PSLF Help Tool to search for qualifying employers, generate information automatically in the form and provide further clarification regarding eligibility requirements.
Borrowers who choose not to fill out the form each year will be required, prior to forgiveness, to submit employment certification for every employer they worked for while making the required monthly payments.
Digital signatures — hand-drawn, not typed — are needed from both the borrower and employer or employers. The completed form can be submitted digitally instead of being mailed or faxed.
If a borrower is approved and makes more than 120 qualifying payments, those extra payments will be refunded in most cases. Processing time after forgiveness approval varies depending on several factors, such as your number of employers, gaps in employment or if documentation was submitted previously.
History of Changes to PSLF
The program has faced criticism and investigations for its high ineligibility rates. The first round of applications for an expanded PSLF were accepted and reviewed in 2017, and by June 2018, 99% of applicants had been rejected. This was often for minor details such as incomplete paperwork.
TEPSLF was created in 2018 to reduce barriers and to extend relief to borrowers of direct student loans who made some or all of their on-time, monthly payments in the wrong repayment plan. But with confusion on eligibility requirements, little funding distributed and COVID-19 challenges, the Education Department announced establishment of the limited PSLF waiver in 2021.
Between Oct. 6, 2021 and Oct. 31, 2022, any prior period of repayment qualified for PSLF, regardless of the loan program or repayment plan type. But for repayment to be valid, all nondirect federal student loans, like Perkins or FFEL program loans, needed to be consolidated into the direct loan program before the limited waiver deadline.
Although the limited waiver deadline ended, regulations to improve PSLF were implemented July 1, 2023. For instance, certain periods of deferment or forbearance — such as for cancer treatment or military service — count toward PSLF. Borrowers also receive credit for payments made late, in installments or in a lump sum, and an average of 30 hours a week is considered the standard for full-time employment, according to the department.
With changes being made to the “qualifying employer” definition, Zampini encourages borrowers to continue making payments while also speaking directly with their employer’s HR or legal team.
“Borrowers’ best source of information is their employer because it’s such a case by case (basis given) that nebulous, unspecific language,” she says. “Any appeals or any pushback would have to go through the employer versus the borrower. A borrower can’t make an individual appeal saying, ‘Oh, I was denied. I’m appealing that denial.’ It’s an employer-based denial on an employer-based appeals process.
Zampini adds that she “would hope employers are also communicating proactively with their employees to kind of say, ‘We’re monitoring this. We’re working with counsel to determine if we’re at risk.’ Keeping them looped in that way, because communications from the department itself are unlikely to shed much light for borrowers.”
[Read: What You Need to Know About College Tuition Costs.]
Help With PSLF
Generally, borrowers should download any account statements and payment records, Zampini says.
That way, “they have their own record of all the payments made, especially if they’re tracking toward PSLF, for example,” she says. “Given servicing transfers and issues with data retention and everything going on with the administration attempting to dismantle the department, I would always err on the side of caution with keeping your own records of payments you’ve made and things like that.”
It’s also good to see if your employer has an assistance program, such as student loan coaching, MacPhetres says.
Borrowers may also refer to the FSA website to learn more about eligibility requirements — or reach out to their student loan servicer for more tailored assistance, experts advise.
“There are resources out there, it’s just a matter of doing a little bit of homework,” MacPhetres says. “This is probably one of the more complicated debt sources; paying student loans in general. It’s changed and continuing to change so much that anybody who needs help should seek any help that they can get.”
Zampini advises borrowers who are “unhappy or concerned” about the final rule to reach out to their Congressional representatives.
“Let the offices know that a lot of borrowers are affected by this,” she says. Talk about “how it affects industries such as education and teachers and health care professionals and social workers, and the impact on the ground. I think the more that members of Congress hear from individual borrowers in their district that are impacted, the more they have the ability to kind of push back on the department trying to take away benefits for borrowers.”
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All About Public Service Loan Forgiveness originally appeared on usnews.com
Update 12/05/25: This article was published at an earlier date and has been updated with new information.
