transcript

transcript  PSLF Webinar Recording 2024_02_09

Transcript:

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Arwen Thoman: Thank you for joining us. I'm Arwen Thoman, and I'm the student loan Ombudsman here in the Massachusetts Attorney General's office.

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Erica Harmon: and I am Erica Harmon, the deputy student loan Ombudsman.

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Arwen Thoman: We're here today to talk about historic student loan debt relief opportunity for government and nonprofit workers.

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Arwen Thoman: 15 years ago Congress created the Public Service Loan Forgiveness Program, also known as PSLF.

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Arwen Thoman: The PSLF program was intended to provide public service workers with an affordable path out of Federal student loan debt.

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Arwen Thoman: But until recently the program has pretty much been a disaster. We've heard countless stories from public service workers over the years about their inability to access loan forgiveness through PSLF, due to the program’s complex rules and poor administration of the program by loan servicers.

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Arwen Thoman: To fix this and to restore borrowers’ credit toward PSLF, the US Department of Education is giving borrowers credit for past repayment periods that would not otherwise count toward forgiveness.

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Arwen Thoman: Through this payment count adjustment, thousands of public service workers will have their loans forgiven, and hundreds of thousands more will get closer to loan forgiveness.

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Arwen Thoman: But to receive this adjustment, some of you need to consolidate your Federal loans into the Direct Loan program before April 30th of this year. In today's presentation, we're going to provide an overview of the PSLF program and the payment count adjustment and explain the steps you need to take not only to benefit but to maximize forgiveness.

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Erica Harmon: So first off, we want to explain how the PSLF program works and provide some background.

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Erica Harmon: The program was created in 2007, and it was intended to provide debt relief to Federal loan borrowers who work in public service for at least 10 years under new and improved regulations that took effect back in last July.

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Erica Harmon: You can receive forgiveness of your remaining Direct Loan balance

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Erica Harmon: after you've made the equivalent of 120 monthly payments in a qualifying repayment plan, that usually entails for paying in an Income Driven Repayment plan,

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Erica Harmon: while working at least 30 h per week for the government or certain types of non-profit employers.

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Erica Harmon: The PSLF program used to have much more complex rules, and those rules, in combination with deficient loan servicing and poor administration left millions of public service workers unable to access loan forgiveness, often because they had the wrong loan type, or they were making payments in a non-qualifying repayment plan.

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Erica Harmon: In fact, in 2017, as the first group of borrowers began reaching 10 years of service, that initial rejection rate was 99%. The payment count adjustment is intended to address these past problems by restoring borrowers credit towards PSLF.

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Arwen Thoman: So through the adjustment, you can get credit toward forgiveness for past repayment periods and certain types of forbearances and deferments that would not otherwise count toward forgiveness.

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Arwen Thoman: This includes payments you made on ineligible Federal loan types,

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Arwen Thoman: payments you made before consolidating your loans, payments you made under non-qualifying repayment plans,

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Arwen Thoman: Any late or partial payments you may have made,

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Arwen Thoman: and forbearances that were 12 consecutive months long or 36 cumulative months long.

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Arwen Thoman: Additionally, all deferments prior to 2013 will count, other than in school deferments

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Arwen Thoman: and certain deferments after 2013 will count, including economic hardship deferments.

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Arwen Thoman: To benefit from the payment count adjustment, all you really need is qualifying employment at some point after October 1, 2007, while your loans were in repayment status.

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Arwen Thoman: and it's important to understand that this qualifying employment doesn't have to be consecutive to count. You can leave public service and come back to it.

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Arwen Thoman: It's also important to understand that the PSLF credits that you receive through the adjustment - they're permanent. So even if you don't reach the 120 months that are needed for outright loan forgiveness,

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Arwen Thoman: you can continue earning more credit under the new PSLF Rules, adding to those credits that you receive from the adjustment.

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Arwen Thoman: Now, some of you may be wondering if your past employer, or your current employer, qualifies for PSLF. Qualifying employers include the government,

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Arwen Thoman: 501 c. 3. non-profit organizations, and other nonprofits that provide qualifying services such as public education or public health.

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Arwen Thoman: You can check to see if your employer qualifies for PSLF by using the US Department of Education's PSLF employer search tool on studentaid.gov. For-profit companies, labor unions or partisan political organizations -

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Arwen Thoman: they do not qualify for PSLF.

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Arwen Thoman: The new PSLF regulations that Erica mentioned have new rules about how many hours per week you must work, and under these new rules which will be used to evaluate both your past and your current employment, you have to work for one or more qualifying employers for at least 30 h per week.

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Arwen Thoman: Now, this means you can have 2 part time jobs at the same time, so long as those hours add up to 30 h per week.

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Arwen Thoman: Teachers, professors, and instructors, only need to work 30 h per week for the 8 months in which they are teaching in order to earn credit for the entire year,

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Arwen Thoman: and there are also some new and helpful rules for calculating hours for college adjunct faculty.

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Arwen Thoman: Now we do want to take a moment here to just highlight how significant and truly life changing public service loan forgiveness and the payment count adjustment can be. The average borrower who achieves PSLF receives an astounding $97,000 in tax-free debt relief.

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Arwen Thoman: Now we know first-hand that many of you have become frustrated or even given up on PSLF. But we want you to understand that the payment adjustment is a game changer.

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Arwen Thoman: Through the adjustment we've already seen many public service workers receive forgiveness or get years closer to forgiveness. But there are still hoops that some of you have to jump through, so we urge you to pay close attention as we move into the next part of this presentation, and you may even want to take some notes.

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Erica Harmon: So let's get into the steps that you're going to need to take to access the adjustment.

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Erica Harmon: First, you're going to need to log in to your studentaid.gov account to identify your Federal loan types to see if you need to switch any of your loans into the Direct Loan program through a process called consolidation.

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Erica Harmon: Second, if you have any non-Direct Loans, you'll need to apply to consolidate those loans into the Direct Loan program by April 30.

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Erica Harmon: Third, even if you already have Direct Loans, you should evaluate whether consolidating by April 30, could help you get forgiveness faster, and this is going to be a consideration for those of you with loans that have been in repayment for different lengths of time.

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Erica Harmon: Fourth, you need to make sure that your employment certifications are up to date by working with your HR Department to certify all the qualifying employment you've held since the October 1, 2007 start date of the PSLF Program.

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Erica Harmon: and finally, to keep earning credit towards public service loan forgiveness, you'll need to apply for an Income Driven Repayment plan by July 1.

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Erica Harmon: So remember, the adjustment is only available until April 30 of this year. If you need to change your loan type through consolidation, you must do so by April 30.

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Erica Harmon: And while we'd recommend certifying your past employment by that date. You can do it later if need be.

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Erica Harmon: So this first step is to identify your loan types to see if you need to consolidate. Federal loan borrowers can have several different types of loans, including Direct Loans, Perkins loans, and Federal Family Education Loans known as FFELS. As you can see on this chart, only Direct Loans are eligible for PSLF and the adjustment.

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Erica Harmon: You must apply to consolidate any Federal loans that are not Direct Loans, such as FFELs or Perkins loans, into the Direct Loan program by April 30 of this year.

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Arwen Thoman: to identify your loan types, you need to go online and navigate to studentaid.gov.

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Arwen Thoman: Studentaid.gov is the US Department of Education's main website for Federal student aid, and it's really your portal to access information about all your Federal student loans, and take certain actions with respect to managing your payment. It's worth noting that this account is distinct from the account you may have with the private company that services your Federal student loans.

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Arwen Thoman: To get into your studentaid.gov account you're going to need to log in with something called an FSA ID and password. Now, if you don't have an FSA ID, you should go ahead and create one, and it may take a couple of days for your account to be activated while the Social Security Administration confirms your personal information.

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Arwen Thoman: And if it's been a long time since you've logged into this account, it's possible you'll have trouble getting back in, if for example, your phone number and your email have changed.

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Arwen Thoman: If you find that you need help creating or accessing your account, you can call the US Department of Education at 1-800-433-3243.

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Arwen Thoman: After you've logged into studentaid.gov, you'll see your account dashboard, which is what we're looking at right here, and, as you can see, it shows your total Federal loan balance along with any grants that you've received.

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Arwen Thoman: To find out what loan types you have click on this view details button.

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Arwen Thoman: Alright, so in this view,

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Arwen Thoman: we've clicked that view details button and we've scrolled down to the loan type section, which is where you'll see your loans grouped into several different categories.

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Arwen Thoman: Now, from this view, you'll be able to see whether you have an outstanding Perkins loan because it's its own loan category.

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Arwen Thoman: But to find out if you have any of these FFEL program loans, you'll need to expand each of the other loan type categories to see a breakdown of all the individual loans within each category.

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Arwen Thoman: In this picture we've clicked on the subsidized loan category,

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Arwen Thoman: and as you can see, there are a bunch of loans within this category. We're looking to see whether there's an outstanding balance on a loan that is not a Direct Loan. In this example, there are 2 loans with outstanding balances.

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Arwen Thoman: One is a Direct Loan,

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Arwen Thoman: but the other is a FFEL program loan. The FFEL program loan will need to be consolidated.

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Arwen Thoman: and keep in mind that you need to carefully review each loan category to see if any of them contain loan types other than Direct Loans.

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Arwen Thoman: Now, while we really want everyone to go into their studentaid.gov account and look at their loan types, we are going to just briefly highlight some of the big warning signs that may indicate that you have FFEL program loans or Perkins loans that need to be consolidated by April 30.

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Arwen Thoman: First, some of you may have received a letter or an email from our office explicitly warning you that you have privately owned Federal student loans.

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Arwen Thoman: Second, if your Federal loans are serviced by Navient or AES, I should say, still being serviced by Navient or AES, this is like a huge red flag that you have FFEL program loans.

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Arwen Thoman: Now you can have FFEL program loans if you have another servicer, but at this point nearly all of the Federal student loans serviced by Navient and AES are these FFEL program loans.

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Arwen Thoman: Similarly, you could have a Perkins loan if you have Federal student loan serviced by ECSI Heartland, or your school. But once again, there are other services that service Perkins loans.

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Arwen Thoman: and just generally you can really only have FFEL program loans if you took out your Federal loans before 2011, and that's because the fell FFEL ended in mid-2010.

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Arwen Thoman: So if you took your loans out in or after 2011, you probably don't have FFEL loans, you could have a mix of Perkins and Direct Loans.

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Arwen Thoman: Another indication that you have FFEL or Perkins loans that need to be consolidated is if your Federal loan payments weren't automatically paused in March 2020, when the pandemic began.

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Arwen Thoman: So if you find out that you have any of these Federal loans that are not Direct Loan, the second step is to consolidate those loans into the Direct Loan program and you can fill out and submit a consolidation application in about 20-30 minutes on studentaid.gov.

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Arwen Thoman: Under this loan repayment tab, you're going to need to select consolidate loans from the dropdown menu.

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Arwen Thoman: Now, after you fill in some personal information, you will be shown a list of all your Federal student loans, and you'll be asked which ones you're trying to consolidate.

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Arwen Thoman: Again, you're going to need to consolidate all your non-Direct Loans. Now, some people may also want to consolidate their Direct Loans,

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Arwen Thoman: and we're going to discuss that scenario in a few minutes. But for the purposes of this example, we're just working on our non-Direct Loans, so make sure to select all your FFEL loans for consolidation by checking the box next to each FFEL loan.

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Arwen Thoman: and if you want your Perkins loan to receive credit under the payment count adjustment, you'll need to consolidate it to. I will note that if you consolidate your Perkins loan, it won't be eligible anymore for Perkins loan cancellation, which is a completely separate program from PSLF

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Arwen Thoman: and is available to borrowers in very specific professions, including teachers, nurses, and public defenders. If you're interested in Perkins loan cancellation, you can learn more about it on studentaid.gov.

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Arwen Thoman: I also just want to note here that at the top of the page you're going to see a toggle button that offers to help you to decide which loans to consolidate for public service loan forgiveness. Don't check this toggle button. If you do, it's going to provide a warning that hasn't been updated to account for the payment adjustment.

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Arwen Thoman: The warning is going to tell you that consolidating will reset your PSLF qualifying payment count to 0,

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Arwen Thoman: but you should disregard this warning as long as you're applying to consolidate by April 30.

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Arwen Thoman: On the next screen you'll be asked whether you want to delay processing your application. Go ahead and click “Do not delay processing”.

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Arwen Thoman: You'll then be asked whether you're consolidating for public service loan forgiveness. Check “Yes” and Mohela will be automatically assigned as your servicer. Mohela is the designated servicer for the PSLF program.

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Arwen Thoman: Now, as part of your consolidation application, you're going to need to choose a repayment plan for your new consolidation loan.

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Arwen Thoman: Now keep in mind, if you don't reach the 120 payments required for forgiveness through the payment adjustment, you're going to need to continue earning credit toward PSLF starting in July of 2024, which is when the adjustment is expected to occur.

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Arwen Thoman: And for most borrowers, this is going to require making payments under an Income Driven Repayment plan. So you're going to want to select the box here that says “repay based on my income”.

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Arwen Thoman: To calculate your income driven payments, the US Department of Education needs access to your income information and there's a nice new feature where you can authorize the Department to just annually access your Federal tax returns so that it can just automatically recalculate your payments each year.

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Arwen Thoman: We definitely recommend providing this authorization so that you aren't burdened with providing your income information every single year by the deadline set by your loan servicer – we’ve seen a lot of problems with that in the past, so we'd suggest reviewing the authorization and clicking approve at the bottom of the page.

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Arwen Thoman: After you answer a series of questions about your marital status, your family size, and your income, you will be shown your payments under the 4 Income Driven Repayment plans, as you can see right here.

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Arwen Thoman: Now, as a rule of thumb SAVE, which is the newest Income Driven Repayment plan, will likely offer the most affordable payments. SAVE is replacing the old REPAYE plan, and it offers a lot of benefits that we'll discuss later in the presentation. But it is possible that if you have a particularly small loan balance, Income Contingent Repayment may offer a lower payment amount.

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Arwen Thoman: And we do want to highlight that if you turn on this “public service loan forgiveness” toggle button up here at the top of the page,

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Arwen Thoman: it is going to assume that your loans are going to be forgiven 120 months from now.

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Arwen Thoman: So unless you're truly just getting started in public service, or you only just graduated from school, and your loans are just entering repayment for the first time, the forgiveness estimates that it puts up on this page are wrong, and you should disregard them. This page for most people is really only useful to get a sense of what your monthly payments will be, but you can't use it to understand how much you're going to pay over the life of the loan, or how much forgiveness you're likely to receive.

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Arwen Thoman: And you can actually change your repayment plan once your consolidation is processed, so if for whatever reason you choose the wrong plan in this moment, you can change that later.

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Erica Harmon: All right. So we've been stressing the need to consolidate non-Direct Loans because these loans can't benefit from the payment count adjustment unless they're consolidated into the Direct Loan program.

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Erica Harmon: But even if some or all of your Federal loans are already Direct Loans, if you worked at least 30 h per week for a qualifying employer between taking out your older and your more recent loans. Forgiveness will come faster on your more recent loans if you consolidate them with your older loans.

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Erica Harmon: So, for example, if you had qualifying employment between your undergrad and graduate school studies, consolidating all your loans together, will speed up forgiveness on your more recent graduate school loans.

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Erica Harmon: So this third step is to evaluate whether this scenario applies to you, and whether you should consolidate all of your loans together.

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Erica Harmon: To demonstrate how this works,

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Erica Harmon: If your undergraduate loans were going to receive a hundred qualifying payments through the adjustment, but your graduate school loans were only going to receive 50 qualifying payments, by consolidating them together, the resulting consolidation loan would receive a hundred qualifying payments which would speed up forgiveness on your more recent graduate school loans.

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Erica Harmon: We hear from a lot of people who are worried about their interest rates increasing if they consolidate, so we want to explain how this works.

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Erica Harmon: The interest rate on your direct consolidation loan will be a fixed rate equal to the weighted average of the interest rates on the loans being consolidated. If that weighted average is between eighths of a percentage point.

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Erica Harmon: It will then round up to the nearest eighth. So the effect of this rate increase, if there is one, is quite minimal and not something to be worried about

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Erica Harmon: As a reminder, a weighted average takes into account both the loan balances and the interest rates

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Erica Harmon: and the weighted average alone is never going to increase your interest rate.

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Erica Harmon: So to give an example of how this works, if you had a FFEL consolidation loan, just one loan, a fell consolidation loan with a 4.3% interest rate,

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Erica Harmon: The interest rate on your new direct consolidation loan would round up to 4.375%.

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Erica Harmon: And that's only a .075% increase.

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Erica Harmon: We’ll mention too that enrolling in auto debit on your new direct consolidation loan

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Erica Harmon: would give you a .25% interest rate reduction.

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Erica Harmon: So if your interest rate does round up by consolidating, by enrolling in auto pay, you would more than offset that increase.

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Erica Harmon: You can also see what your interest rate will be ahead of time by logging into studentaid.gov and completing Step 1 of the consolidation application.

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Erica Harmon: We do want to mention that there's one exception to this rule.

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Erica Harmon: And that is, it's a somewhat rare situation, but some FFELs are subject to special interest rate borrower benefit programs. So to give an example, a 1.5% rate reduction for making 48 months of on time payments,

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Erica Harmon: consolidating does end these special interest rate reductions.

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Erica Harmon: So there are a couple special circumstances relating to consolidating that could arise for just some borrowers that we're going to run through. The first is if you've made more than 120 payments on an existing Direct Loan,

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Erica Harmon: by consolidating, you'll be giving up a refund of any payments you may beyond the 120 required for forgiveness. But with that being said, depending on how much credit you get towards forgiveness on your more recent loans by consolidating, it could be worth giving up this refund.

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Erica Harmon: The US Department of Education has made it clear that refunds will not be available for payments made on FFEL or Perkins loans,

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Erica Harmon: so this refund consideration only applies to consolidating Direct Loans. Second,

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Erica Harmon: if you have Parent PLUS loans, consolidating them with your own student loans will restrict the entire resulting direct consolidation loan to the more expensive Income Contingent Repayment, an ICR plan,

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Erica Harmon: unless you're able to take advantage of advantage of a special double consolidation loophole to access the SAVE plan which we're going to discuss just a little later in our presentation.

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Erica Harmon: There's one more factor to be aware of. If you've spent significant time in deferment or forbearance that you do not expect to get credit for through the payment count adjustment,

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Erica Harmon: there's a new buyback process in the new PSLF regulations we've mentioned that allows Direct Loan borrowers to buy back past qualifying employment periods that they didn't get PSLF credit for

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Erica Harmon: due to being in a forbearance or deferment.

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Erica Harmon: Through the process, borrowers can obtain credit towards PSLF by paying what they would have been required to pay under an Income Driven Repayment plan.

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Erica Harmon: But unfortunately consolidating will prevent you from buying back these past qualifying employment periods. But keep in mind some of these forbearance and deferment periods may automatically receive PSLF credit through the payment count adjustment for free,

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Erica Harmon: so you may not actually need to use it at all. You can learn more about this buyback process on the US Department of Education's website.

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Erica Harmon: Alright, so at this point, we've talked about how to identify your loan types, which loans to consolidate, and issues to consider when consolidating.

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Erica Harmon: The next step to getting the benefits of the adjustment is to ensure that your employment certifications are up to date with Mohela, the current PSLF Servicer.

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Erica Harmon: The government can’t give you credit for your public service if it doesn't know about it. So, if you don't have approved employment certifications on file for all of your past qualifying employment periods since that October 1, 2007 start date of the program,

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Erica Harmon: you should file a PSLF form to certify your employment for each uncertified period. While we'd recommend getting it done by April 30, you can do it later if you need to.

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Erica Harmon: If you're not sure whether you've successfully certified your employment, to be on the safe side, you should file or refile a PSLF form.

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Erica Harmon: To certify your employment, you need to work with your employer to fill out a PSLF form. You can download the PSLF form as a PDF and you and your employer can complete all the sections before you submit it to Mohela.

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Erica Harmon: Alternatively, you can use the PSLF help tool on studentaid.gov to assist you in starting the PSLF form.

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Erica Harmon: If you use the PSLF help tool, it will provide an option to use the US Department of Education's E-signature and electronic Submission process,

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Erica Harmon: but you will need to double check with your employer as to what email address to use for that. You can also print the partially completed form that the help tool generates for you and your employer to manually sign.

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Erica Harmon: You would then need to submit that form to Mohela. Unfortunately, the PSLF help tool is difficult to use, and shows confusing warnings that don't account for the payment count adjustment,

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Erica Harmon: so we often find it simpler to just download a blank PSLF form, fill out and sign page one, and then ask your employer to fill out and sign page 2,

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Erica Harmon: and then submit the completed form to Mohela.

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Erica Harmon: Here's what the form looks like. Page 1 requests some basic personal information at the top

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Erica Harmon: and then immediately after the section, it offers you the option to put your loans in forbearance if you believe you've reached the 120 payments required for forgiveness. If you don't think you have the 120 payments required or you just aren't sure,

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Erica Harmon: don't check this box, because if you do, you'll be put in a forbearance while the application is processed and you won't get credit towards forgiveness for those months.

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Erica Harmon: Don't forget to sign and date page 1 at the bottom of the page.

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Erica Harmon: Here's what Page 2 looks like. We really think it's best for your employer to complete this page.

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Erica Harmon: Your HR Department may have already provided instructions on how to how to send your PSLF form to them, but if you're not sure how to get your PSLF form to your HR Department, you should reach out to them.

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Erica Harmon: If you're filling out a PDF of the PSLF form, keep in mind that signatures for you and your employer must be hand drawn.

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Erica Harmon: Typed signatures, even if made to mimic a hand-drawn signature or security certificate-based signatures are not accepted.

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Erica Harmon: Before submitting your PSLF Form, review it carefully for completeness.

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Erica Harmon: We've seen a lot of forms rejected for missing signatures or missing dates. You should send the completed form to Mohela, the servicer for the PSLF program.

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Erica Harmon: and if Mohela is already your servicer, you can upload your completed form on Mohela's website, but otherwise you can fax or mail it.

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Erica Harmon: and we recommend saving a copy of your employment certifications for your records.

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Arwen Thoman: So step 5, the final step in all this, is to make payments under an Income Driven Repayment planx.

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Arwen Thoman: To continue running credit toward public service loan forgiveness, most borrowers are going to need to apply for an income-driven repayment plan by July 1.

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Arwen Thoman: And while some of you will have had the opportunity to apply for IDR at the time you submitted a consolidation application, those of you who are not consolidating will need to apply.

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Arwen Thoman: Income Driven Repayment plans or IDR plans base your payments on your income and your family size. And there is good news. There is a new, more affordable Income Driven Repayment plan called SAVE.

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Arwen Thoman: The new SAVE plan is the most affordable IDR plan in history.

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Arwen Thoman: Rather than protecting income under 150% of the Federal poverty line as past income driven plans did, the SAVE Plan protects income under 225% of the Federal poverty line.

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Arwen Thoman: This means it will cut monthly payments to $0 per month if you make less than about $33,000 per year individually, or under $67,500 for a family of 4.

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Arwen Thoman: Another great feature of the SAVE plan is that it eliminates any remaining interest after a scheduled payment is made.

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Arwen Thoman: So, for example, if your loan accrues $50 in interest each month, and your SAVE payment is only $30, that extra $20 in interest just isn't charged.

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Arwen Thoman: Additionally married borrowers who file their taxes separately can exclude their spouse's income from their payments calculation.

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Arwen Thoman: So some borrowers may want to give some consideration to changing their future tax filing status in order to lower their monthly payment.

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Arwen Thoman: The chart on the left here illustrates how SAVE payments change based on income and family size, and you should be able to use it to ballpark what your SAVE payment should be.

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Arwen Thoman: For example, someone with a family size of 3 making $60,000 per year, would have a $34 monthly payment.

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Arwen Thoman: And you can see here on the right, the example of Alexander, a single borrower with no dependents who makes $38,000 per year,

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Arwen Thoman: he would have had to pay $134 per month under the old REPAYE plan, but only have to pay $43 per month under SAVE.

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Arwen Thoman: And it's also important to note that beginning in July 2024, payments on undergraduate loans are going to be cut in half

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Arwen Thoman: under the SAVE plan.

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Arwen Thoman: So you can apply for SAVE online at studentaid.gov/idr. The online application is more efficient, and it allows you to see your payments before you apply,

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Arwen Thoman: but you can also apply for SAVE by downloading a PDF version of the Income Driven Repayment application available at studentaid.gov/forms-library.

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Arwen Thoman: Now, since the SAVE plan replaced the old REPAYE plan, if you were in REPAYE before the start of the pandemic in March of 2020, you should have been automatically placed in SAVE.

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Arwen Thoman: Alright. We're going to try to talk now about Income Driven Repayment plans for Parent PLUS loans. And before trying to get into this, we do want to just highlight up front that we have some very detailed, step by step, instructions for how to access this double consolidation loophole that we're about to talk about. If you think you could benefit from the loophole, we definitely encourage you to visit this link: mass.gov/parentplus to take a look at our more detailed instructions.

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Arwen Thoman: Okay, so, Parent PLUS loans that have never been consolidated, they're not eligible for any Income Driven Repayment plan, including the new SAVE plan.

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Arwen Thoman: But until July 1 of 2025

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Arwen Thoman: Parent PLUS borrowers, with at least 2 Federal loans, can use a double consolidation loophole to access SAVE.

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Arwen Thoman: Now for this loophole to work, you basically have to consolidate any Parent PLUS loan that you have twice.

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Arwen Thoman: Now, unfortunately, if you have a single Parent PLUS loan or a single direct consolidation loan that paid off one or more Parent PLUS loans, you're probably not going to be able to use the loophole.

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Arwen Thoman: In that circumstance you can instead apply for the Income Contingent Repayment plan once your Parent PLUS loan has been consolidated into a direct consolidation loan.

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Arwen Thoman: Although the Income Contingent Repayment plan is a qualifying payment for PSLF purposes, it typically offers higher payments than the SAVE plan, which is why we're promoting this loophole.

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Arwen Thoman: To illustrate how the double consolidation loophole works, if you had 2 Parent PLUS loans, and you consolidated each one of those Parent PLUS loans separately into 2 direct consolidation loans,

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Arwen Thoman: and then consolidated those 2 consolidation loans together, your final consolidation loan would be eligible for the SAVE plan. But remember, you only have until July 2025 to complete all the necessary consolidations in order for that final direct consolidation loan to be eligible for SAVE

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Arwen Thoman: and there may even be advantages to getting the consolidations done before April 30, so that you could fully maximize the payment count adjustment.

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Arwen Thoman: For everyone pursuing public service loan forgiveness, be they parent or student borrowers, we need you to be aware that the standard repayment plan for consolidation loans, the graduated repayment plan and the extended repayment plan, these plans do not qualify toward PSLF.

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Arwen Thoman: So, although the government is saying, you know

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Arwen Thoman: we get it, people didn't understand that they couldn't pay under these plans in the past, and we're willing to give you credit for payments you made through these plans in the past, that's all coming to an end on July 1. So if you're in one of these plans, you need to apply by July 1 to switch to an Income Driven Repayment plan to continue earning credit toward PSLF.

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Arwen Thoman: Now we do hear from people who come to us and say, oh, but I can't afford these Income Driven payments. This typically occurs with higher income borrowers, particularly borrowers who are married and filing joint tax returns,

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Arwen Thoman: and there are a couple of avenues to explore. If you find yourself in this situation, first, you could try asking your servicer to place you in a 10 Year Standard plan which is

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Arwen Thoman: technically a qualifying payment plan for PSLF.  Traditionally, people would never pay under a 10 Year plan if they were pursuing PSLF, because inherent in paying in a 10 year plan is the fact that you'll pay off your loans within 10 years.

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Arwen Thoman: But depending on how much credit you get through the adjustment on top of any time your loans are paused as a result of the pandemic,

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Arwen Thoman: you know, you could actually end up receiving PSLF

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Arwen Thoman: forgiveness before paying off your loans, even if you're paying under a 10 year plan. So for example, if you have 7 years towards forgiveness, as a result of the adjustment, you could potentially pay for another 3 years under a 10 year plan, and still have something left to forgive.

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Arwen Thoman: Second, if you're married and you file your taxes jointly with your spouse, you could consider changing your tax filing status to married filing separately. If you do this, your IDR payment will be calculated using only your income.

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Arwen Thoman: And you'd have to discuss with a tax professional to find out what you'd be giving up on your taxes and weigh this against

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Arwen Thoman: how much you'd be saving on your student loan payments. Finally, there is a sort of a high-risk alternative if you can't afford to pay either an Income Driven plan or the 10 Year Plan, and it's called Temporary Expanded Public Service Loan Forgiveness, TEPSLF.

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Arwen Thoman: and it does offer more repayment plan flexibility, including allowing for payments made under extended, graduated and consolidation standard repayment plans.

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Arwen Thoman: The TEPSLF program was basically an early attempt by Congress to fix at least some of what was wrong with the PSLF program, but the problem with it is that it has limited funding.

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Arwen Thoman: So unless you're really close to forgiveness, it may be risky to rely on TEPSLF, and again, that's because it has this finite amount of funding, it's possible that TEPSLF won't exist by the time you reach 120 qualifying payments.

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Arwen Thoman: And were this to occur, the payments that you made after July 1 of this year under TEPSLF eligible repayment plans, they would not count for forgiveness under PSLF, and you could find yourself stranded with respect to loan forgiveness.

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Erica Harmon: So separate from the payment count adjustment, if your Federal loans were subject to the pandemic payment pause and 0% interest rate beginning in March 2020, you'll receive credit towards PSLF for each month for which you certified qualifying employment, even if you didn't make a payment.

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Erica Harmon: We also want to briefly go over what comes next. After you've taken the steps we've outlined today,

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Erica Harmon: you're not going to see the results of the payment count adjustment immediately. The adjustment is being run every 2 months through July of 2024, and if you don't receive PSLF through the adjustment, you should plan to regularly recertify your employment so that you can continue to see updates to your qualifying payment count.

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Erica Harmon: And remember, the government is only going to give you credit for your public service that it knows about, so we suggest certifying

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Erica Harmon: once a year and every time you switch employers.

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Erica Harmon: After your loans transfer to Mohela, we recommend registering an account on Mohela’s website.

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Erica Harmon: In this way you can keep track of your certified employment periods and be sure that each form is processed. You can also monitor your qualifying payments towards PSLF and identify any issues that could arise right away.

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Erica Harmon: Lastly, you may want to consider paying by auto debit, because you'll get that .25% interest rate reduction for using it.

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Erica Harmon: So to recap,

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Erica Harmon: in order to benefit from the payment count adjustment for PSLF. First, you need to log in to your studentaid.gov account to identify your Federal loan types, to see if you have any non-Direct Loans.

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Erica Harmon: Second, if you have any non-Direct Loans, you'll need to apply to consolidate those loans into the Direct Loan program by April 30.

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Erica Harmon: Third, even if you already have Direct Loans, you should evaluate whether consolidating by April 30 could help you get forgiveness faster. And again, this is only going to be a consideration for those of you with loans that have been in repayment for different lengths of time.

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Erica Harmon: Fourth, you'll need to ensure that your employment certifications are up to date by working with your employer to certify all the qualifying employment you've held since the October 1, 2007 start date of the PSLF program.

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Erica Harmon: And finally, to keep earning credit towards public service loan forgiveness, you'll need to apply for an Income Driven Repayment plan by July 1.

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Erica Harmon: These are the steps you're going to need to take, and we hope that you feel more confident about what you need to do. Thank you for joining us.