Student Loan Forgiveness Under IBR: A Shifting Landscape and Unexpected Pause

Today, July 22, 2025, the landscape of federal student loan repayment and forgiveness is as complex and uncertain as ever, particularly for those relying on Income-Based Repayment (IBR) plans. While IBR has historically been a cornerstone for borrowers seeking relief, recent developments have introduced a new layer of confusion and frustration, with the U.S. Department of Education unexpectedly pausing IBR forgiveness.

The IBR Pause: “System Updates” Amidst Broader Changes

Despite IBR being the only major income-driven repayment (IDR) plan with explicit legal authorization from Congress for loan forgiveness after 20 or 25 years of qualifying payments, the Department of Education has quietly halted the processing of IBR forgiveness. The official reason provided is “system updates” in response to ongoing legal challenges and court injunctions affecting other IDR plans like SAVE, PAYE, and ICR.

However, critics and legal experts argue that IBR discharges should not be impacted by these updates, as its legal authority for forgiveness is distinct. This pause is leaving thousands of eligible borrowers who have reached their forgiveness milestone in limbo, some waiting since mid-2024 for their promised relief.

This comes amidst significant disruption across the federal student loan system, including massive processing delays for IDR applications and major policy shifts under the current administration.

The “Big, Beautiful Bill” and the Future of Repayment

Adding to the complexity is the recently signed “One Big Beautiful Bill Act” (OBBB) by President Trump on July 4, 2025. This comprehensive legislation brings sweeping changes to the federal student loan system, aiming to reshape both current and future repayment options.

Key takeaways from the OBBB include:

  • New Repayment Assistance Plan (RAP): A new IDR plan, the Repayment Assistance Plan (RAP), will replace SAVE, PAYE, and ICR. RAP is expected to be available by July 1, 2026. While current IBR borrowers will be allowed to remain enrolled and qualify for forgiveness, new borrowers won’t have access to IBR once RAP takes over. RAP is notable for requiring a minimum monthly payment of $10, even for low-income borrowers, unlike existing IDR plans that can have $0 payments. It also extends the forgiveness window to 30 years in some cases, a notable increase from the 20-25 years under existing plans.
  • IBR’s Shifting Eligibility: The OBBB eliminates the “partial financial hardship” requirement to qualify for IBR. This change, effective immediately, makes IBR accessible to a wider range of borrowers, including those with loans made on or after July 1, 2014, who previously only had access to ICR with higher payment percentages and longer forgiveness periods. Additionally, certain Parent PLUS loan borrowers with consolidation loans will now be able to enroll in IBR.
  • Loan Caps: The OBBB imposes new lifetime borrowing caps, significantly impacting graduate and professional students. For example, graduate students will be limited to $100,000 in federal loans, replacing the previous ceiling of around $138,000. Law or medical school students will have a limit of $200,000. Parent PLUS borrowers will be limited to $65,000 per child.
  • PSLF Integration: The OBBB amends the Public Service Loan Forgiveness (PSLF) program to allow payments made under the new RAP to count toward loan forgiveness, effective immediately, once the RAP program launches.

Understanding IBR: The Basics

For existing borrowers, IBR remains a vital income-driven repayment option. Here’s a quick refresher on its core features:

  • Payment Calculation: Monthly payments are generally 10% or 15% of your discretionary income, depending on when you took out your loans. For new borrowers on or after July 1, 2014, it’s 10%. For those who borrowed before that date, it’s 15%.
  • Discretionary Income: This is the difference between your adjusted gross income (AGI) and 150% of the federal poverty guideline for your family size.
  • Payment Cap: Your monthly payment will never be more than what you would pay under a 10-year Standard Repayment Plan.
  • Loan Forgiveness: Any remaining loan balance is forgiven after 20 years of qualifying payments for new borrowers (on or after July 1, 2014) and 25 years for those who borrowed before July 1, 2014.
  • Annual Recertification: Borrowers must recertify their income and family size annually to ensure their payments are adjusted accordingly. This can now be streamlined by consenting to the Department of Education accessing federal tax information.

What Borrowers Need to Do Now

Given the current state of flux, borrowers, especially those previously enrolled in the legally challenged SAVE plan, are being urged to take action. As interest on SAVE loans is set to restart on August 1, 2025, and SAVE is being phased out, borrowers need to consider their alternatives.

The Department of Education is encouraging SAVE borrowers to consider enrolling in IBR, as it is the only existing IDR plan not currently affected by court injunctions and is set to remain available to existing borrowers after the implementation of the OBBB’s RAP plan.

If you are a borrower:

  • Assess Your Situation: Use the Federal Student Aid Loan Simulator to compare available repayment plans and determine which option best suits your financial goals.
  • Consider IBR: If you were on SAVE, or if you’re looking for an IDR plan that currently has clearer legal standing, IBR is a strong option.
  • Stay Informed: The student loan landscape is rapidly evolving. Continuously check official sources like StudentAid.gov and the Department of Education’s press releases for the latest updates and guidance.
  • Contact Your Servicer: For personalized advice and to discuss your specific loan situation, reach out to your loan servicer.

The current pause on IBR forgiveness is a frustrating development for many, but the underlying mechanisms of IBR remain in place for existing borrowers. As the new “Big, Beautiful Bill” begins to reshape the federal student loan system, understanding these changes and proactively managing your repayment plan will be crucial for navigating the path to financial freedom.

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