NCLC submitted this comment to the U.S. Department of Education in response to its request for comments regarding its intent to engage in rulemaking to change the regulations governing the income-driven repayment (IDR) and Public Service Loan Forgiveness (PSLF) programs for federal student loans.
NCLC urged the Department to reconsider the timing of the proposed rulemaking in light of current efforts by Congress to dramatically change IDR, noting that borrowers have already been through unprecedented disruption and change and that introducing additional, short-lived changes could further frustrate borrowers’ attempts to understand and navigate their student loan repayment options. NCLC recommended that the Department instead implement only surgical fixes to the IDR program now using the interim final rule process to restore uncontroversial, common sense aspects of the 2023 IDR rules.
To the extent the Department does move forward with a rulemaking now, NCLC urged the Department to honor its contractual commitments to existing borrowers to the benefits of current IDR plans and to improve the IDR program to make repayment more affordable and successful for low-income borrowers and to reduce default. NCLC offered several specific recommendations towards those ends.
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