SAVE Forbearance FAQ
A federal court issued an injunction preventing the U.S. Department of Education (ED) from implementing parts of the Saving on a Valuable Education (SAVE) Plan and other IDR plans, including—for example—SAVE’s monthly payment formula and loan forgiveness under the SAVE, PAYE, and ICR Plans. Borrowers currently enrolled in the SAVE plan are being placed into a forbearance and IDR applications for SAVE are paused while the court cases are proceeding. While borrowers will not accrue interest while on this forbearance, the time while on this forbearance will not count towards IDR forgiveness or PSLF and so will impact alumni who are on SAVE and currently participating in the Law School's Loan Repayment Assistance Program (LRAP).
Below are some basic questions and answers about the SAVE injunction and forbearance and how it interacts with LRAP, both for 2024 as well as for 2025. The most up to date Department of Education FAQs can be found at studentaid.gov/announcements-events/save-court-actions. We recommend checking this website frequently for updates from ED and your servicer.
We last updated this FAQ page on November 6, 2024. We caution alum that guidance from ED is changing rapidly and our understanding of the updated repayment processes, and as such LRAP eligibility, may change.
General IDR Application Issues
I'm a recent grad from the Class of 2024 and I'm having trouble submitting an online IDR application. What do I do?
UPDATED 11/6/2024: We did become aware in mid-October that servicers would not be able to process an IDR application for a newly graduated borrower prior to their grace period ending. Our understanding from servicers at that time was that the IDR application would be available at studentaid.gov at least 45 days prior to the borrower's grace period ending (which for our students is typically early December) and that servicers would begin processing IDR application to enroll in an IDR plan once their grace period has ended.
We are now hearing from some Class of 2024 alumni that they are unable to submit the IDR application online, even though as of today, we are within that 45-day window. Outside of submitting a PDF IDR application to your servicer, our best advice right now is to log into studentaid.gov in early December (or once your grace period ends) to see if the IDR application is available. If it is and you submit it at that time, our understanding is that your servicer will place you into a processing forbearance while they process your IDR application before a payment would be due (this is in line with the Department of Education’s guidance at https://studentaid.gov/announcements-events/save-court-actions). We would also recommend reaching out to your servicer to confirm how long it would take them to place you into this processing forbearance, and to potentially be put into a general forbearance if you won't be placed into the processing forbearance prior to your payment due date.
If the IDR application is not available once your grace periods ends, we recommend submitting a paper IDR application to your servicer via their online portal and then reaching out to your servicer to alert them that you have submitted a paper IDR application and ask for a short forbearance while they update your account and process the forbearance.
LRAP and the SAVE Forbearance
I've received LRAP benefits for the 2024 calendar year. How do the court proceedings impact my remaining 2024 benefits?
The LRAP Committee has revised its guidance based on updates received from ED and servicers and is no longer requiring a separate appeal to retain your August 2024 through December 2024 LRAP funding. If you received 2024 LRAP benefits and were repaying your loans on SAVE when the SAVE forbearance went into effect, then your LRAP benefits from August 2024 to December 2024 can be retained and applied towards your federal student loans. You must still submit documentation to UChicago Law showing that you paid your 2024 LRAP benefit towards your federal student loans, whether made as a regular payment or as a payment towards the principal loan balance.
If you are an alum currently repaying your loans on IBR or PAYE, then there is no impact to your repayment terms or LRAP eligibility and benefits. If you decide to switch from PAYE, you must switch to IBR while these court cases are proceeding in order to maintain your LRAP benefit eligibility.
I'm a recent grad from the Class of 2024 or an alum currently in repayment. What are my options regarding my 2025 calendar year LRAP eligibility and benefits?
See below for guidance based on your LRAP participation status. All alumni who want to apply for LRAP benefits for the 2025 calendar year, including borrowers on SAVE, should still complete the LRAP application process by the March 31, 2025 deadline and then send any updated loan documentation to the Financial Aid Office. We cannot guarantee calendar year 2025 LRAP benefits if you apply past the March 31, 2025 application deadline, even if the SAVE court cases are resolved after that date.
Please contact the Financial Aid Office at financialaid@law.uchicago.edu with any questions.
Alumni Already in Repayment
Our most recent understanding is that borrowers on SAVE who have been administratively placed in forbearance will remain in the forbearance and may not be able to switch repayment plans until the court cases are resolved, but can continue to make payments towards their student loans. In line with our LRAP policy, the LRAP Committee has decided that LRAP participants who were administratively placed in the SAVE forbearance can continue to receive LRAP benefits while the court cases are ongoing. In this case, your 2025 LRAP benefit will be based on your most recently required documented SAVE repayment amount (in most cases, the amount of your required payment in June 2024, before the forbearance began). All other LRAP eligibility criteria will apply, including the requirement to submit monthly proof of payment towards your federal student loans, whether made as a regular payment or as a payment towards the principal loan balance.
If you participated in LRAP during the 2024 calendar year and were administratively placed into the SAVE forbearance but do not plan to apply for 2025 LRAP benefits, you must still submit proof of payment to financialaid@law.uchicago.edu to document that you applied your 2024 LRAP benefit towards your federal student loans.
You can also choose to apply for LRAP by the March 31, 2025 deadline and ask that we hold any LRAP benefits pending resolution of the court cases. In this case, contact us at financialaid@law.uchicago.edu once you have submitted the LRAP application.
If you are an alum repaying your loans on IBR or PAYE, then there is no impact to your repayment terms or LRAP eligibility and benefits as long as you continue in those repayment plans. If you switch to SAVE after the forbearance period began, you would not be eligible for LRAP benefits while in the SAVE forbearance.
Class of 2024 Graduates
For recent grads, we recommend enrolling in the IBR repayment plan to be eligible for LRAP during the SAVE forbearance period. Eligibility for LRAP while enrolled in SAVE during this forbearance only applies to those borrowers who were in active repayment on SAVE and administratively placed into the forbearance by their servicer. If you enrolled in SAVE after the forbearance period began, you would not be eligible for LRAP benefits while in the SAVE forbearance.
As ED states on their SAVE Court Actions website, if you submit an IDR application and choose SAVE, "have my loan servicer select my plan", or “lowest monthly payment amount”, your IDR application will not be processed while these court actions remain ongoing. Therefore, if you want to receive LRAP benefits as a new participant, you must choose the IBR plan when completing the IDR application while the SAVE forbearance is ongoing. Contact our office at financialaid@law.uchicago.edu with any questions or to update us on any IDR application processing issues.
You can also choose to apply for LRAP by the March 31, 2025 deadline and ask that we hold any LRAP benefits pending resolution of the court cases. In this case, contact us at financialaid@law.uchicago.edu once you have submitted the LRAP application.
Can I switch to another IDR plan? How would that impact my LRAP benefits?
Alum who were in repayment prior to the start of the SAVE forbearance can submit an IDR application to switch from SAVE to IBR, but servicers may not process this application while the SAVE forbearance is in effect. ED also announced on October 24th that they will take action to reopen the PAYE repayment plan to new enrollees who otherwise meet the eligibility requirements.
In all cases, any change to your monthly payment while you are participating in LRAP must be communicated to the Financial Aid Office at financialaid@law.uchicago.edu within 30 days.
Alumni Already in Repayment
If you submit an IDR application to switch to IBR, our current understanding based on ED guidance is that your servicer will process your application, but we are unsure at this time if servicers will process IDR applications to switch from SAVE to IBR right away or if applications to switch to IBR will remain paused. ED says on their FAQs that borrowers should expect a lengthy delay in processing of applications.
If you are on PAYE, you can remain on PAYE.
If/when your servicer begins to process your IDR application to switch from SAVE to IBR, servicers will move the borrower into a processing forbearance for up to 60 days. Interest accrues during this short-term processing forbearance, and it is eligible for PSLF and IDR for up to 60 days. If the borrower’s application is not processed within 60 days, the borrower will be moved into a general forbearance that does not count toward PSLF or IDR until their application is processed. Interest will not accrue in this general forbearance.
As ED states on their SAVE Court Actions website, processing for SAVE IDR applications and IDR applications where borrowers selected "have my loan servicer select my plan" or “lowest monthly payment amount” will remain paused. Therefore, if you want to switch to IBR, you must choose the IBR plan when completing the IDR application while the SAVE forbearance is ongoing. But bear in mind that your IDR application may not be processed while the SAVE forbearance is ongoing.
Class of 2024 Graduates
If you submit an IDR application and choose IBR, our current understanding based on ED guidance is that your servicer will process your application once your grace period is over. Grace periods for Class of 2024 graduates are set to end as of December 1st based on the June 2nd graduation date, so your IDR application will only be processed on or after December 2nd. At that time, servicers will move the borrower into a processing forbearance for up to 60 days. Interest accrues during this short-term processing forbearance, and it is eligible for PSLF and IDR for up to 60 days. If the borrower’s application is not processed within 60 days, the borrower will be moved into a general forbearance that does not count toward PSLF or IDR until their application is processed. Interest will not accrue in this general forbearance.
We do not know how long the servicers will take to process initial applications for IBR. ED says on their FAQs that borrowers should expect a lengthy delay in processing of applications and they do not currently share an estimate of how long this will take.
As ED states on their SAVE Court Actions website, if you submit an IDR application and choose SAVE, "have my loan servicer select my plan", or “lowest monthly payment amount”, your IDR application will not be processed while these court actions remain ongoing. Therefore, if you want to receive LRAP benefits as a new participant, you must choose the IBR plan when completing the IDR application while the SAVE forbearance is ongoing. If SAVE remains available after the court cases are resolved, SAVE will continue to be considered an LRAP-eligible repayment plan.