The forgiveness plan was blocked by courts before most borrowers received relief

President Biden announced a student loan forgiveness plan in August 2022 that would have cancelled up to $20,000 in federal student loans for borrowers earning under $125,000 per year. The plan never took effect. In June 2023, the Supreme Court ruled 6–3 that the administration did not have the legal authority to cancel debt on this scale without approval from Congress. Borrowers who had already submitted applications received no forgiveness.

A much smaller forgiveness program did move forward: the Public Service Loan Forgiveness (PSLF) Limited Waiver, which ran from October 2021 to October 2023. This program allowed borrowers working in government or nonprofit jobs to count past payments toward forgiveness, even if those payments were made under the wrong repayment plan or while in deferment. Over 700,000 borrowers received forgiveness through this route.

Key Takeaways

  • The broad forgiveness plan announced in 2022 was blocked by the Supreme Court and never went into effect for most borrowers.
  • The Public Service Loan Forgiveness Limited Waiver did run from 2021 to 2023 and forgave loans for over 700,000 public service workers.
  • Borrowers can still pursue forgiveness through existing programs like PSLF, Income-Driven Repayment forgiveness, and Teacher Loan Forgiveness if they meet the requirements.
  • Federal student loan payments resumed in October 2023 after a pause that began in March 2020.

What the Supreme Court decision actually said

The Supreme Court's ruling focused on a legal question: whether the Secretary of Education had the power to cancel debt under the Higher Education Relief Opportunities for Students (HEROES) Act, a law passed after 9/11 that allows the Secretary to waive or modify loan obligations during national emergencies.

The Court found that the HEROES Act did not give the Secretary broad enough power to cancel $430 billion in debt across millions of borrowers. The majority opinion stated that such a large action required explicit congressional approval. The decision did not address whether Congress could pass a law to forgive student loans — only that the executive branch could not do it alone.

After the ruling, the administration explored other legal pathways. In 2023 and 2024, the Department of Education announced forgiveness for specific groups: borrowers with permanent disabilities, borrowers defrauded by their schools, and borrowers who had been in repayment for 20 or 25 years under income-driven plans. These programs moved forward because they used existing legal authority rather than new executive action.

The Public Service Loan Forgiveness Limited Waiver — what it covered

The PSLF Limited Waiver was a temporary program that ended in October 2023. It allowed borrowers employed by government agencies or nonprofit organizations to count payments toward the 120 payments required for PSLF forgiveness, even if those payments did not normally count.

Normally, PSLF requires 120 on-time payments while working full-time for a may have access to employer. The Limited Waiver allowed borrowers to count payments made under the wrong repayment plan, payments made while in deferment or forbearance, and payments made for loans that were later consolidated. This waiver was one-time only and did not reopen after October 2023.

If you worked in public service and made payments before October 2023, you can check whether you received forgiveness through this program by logging into your Federal Student Aid account or contacting your loan servicer. If you did not receive forgiveness and believe you should have, contact your servicer to ask about your PSLF count.

Forgiveness programs that are still available

Several forgiveness routes remain open to borrowers who meet specific requirements. Public Service Loan Forgiveness (PSLF) forgives remaining balances after 120 on-time payments while working full-time for a government agency or nonprofit. Income-Driven Repayment (IDR) forgiveness cancels remaining balances after 20 or 25 years of payments under an income-driven plan, depending on the plan type. Teacher Loan Forgiveness cancels up to $17,500 for teachers who work in low-income schools for five consecutive years.

Borrowers with permanent disabilities can have their loans discharged through the Total and Permanent Disability (TPD) discharge program. Borrowers who attended schools that closed while they were enrolled or shortly after they left may be covered under Closed School Discharge. Borrowers who were defrauded by their schools may may have access to for Borrower Defense to Repayment.

Each program has different requirements and timelines. The Department of Education's website provides applications and may be able to access details for each route. Your loan servicer can also tell you which programs you might may have access to for based on your employment and payment history.

What happened to the payment pause

Federal student loan payments were paused in March 2020 during the COVID-19 pandemic. The pause was extended multiple times and remained in effect while the forgiveness plan was being debated. When the Supreme Court blocked the forgiveness plan in June 2023, the payment pause ended on September 30, 2023, and regular payments resumed on October 1, 2023.

During the pause, borrowers did not have to make payments and interest did not accrue. No payments made during the pause counted toward forgiveness programs like PSLF or IDR forgiveness. Borrowers who had been in deferment or forbearance before the pause had those periods extended automatically.

What borrowers who applied should know

Borrowers who submitted applications for the broad forgiveness plan before it was blocked did not receive forgiveness. The Department of Education did not process applications after the Supreme Court ruling. If you submitted an application, you can check the status of your application through the Federal Student Aid website, though most will show as denied or not processed.

You are not responsible for any fees or penalties related to the application. If you received communications asking you to pay to "reapply" or "appeal" a denial, those are scams. The Department of Education does not charge fees for loan forgiveness programs.

Frequently Asked Questions

Can Congress still pass a law to forgive student loans?

Yes. The Supreme Court ruling only said the executive branch could not forgive loans without congressional approval. Congress could pass legislation to forgive student loans, but this would require approval from both the House and Senate and the President's signature. No such law has been passed.

Will there be another forgiveness plan?

The Biden administration has not announced a new broad forgiveness plan since the Supreme Court ruling. Future administrations or Congress could propose forgiveness, but there is no current plan in place. Borrowers should focus on existing programs they may may have access to for.

Do I have to pay back my loans now?

Yes. Federal student loan payments resumed in October 2023 after the payment pause ended. If you have federal student loans and have not made a payment since September 2023, contact your servicer to set up a payment plan or explore income-driven repayment options that may lower your monthly payment.

What if I was told I would get forgiveness and now I won't?

Many borrowers felt misled when the plan was blocked. You have no legal recourse against the government for the blocked forgiveness, but you can explore the forgiveness programs that do exist. If a private company charged you money to help you get forgiveness, you may be able to report them to your state's attorney general or the Federal Trade Commission.

Does the PSLF Limited Waiver still exist?

No. The Limited Waiver ended in October 2023 and did not reopen. However, the regular PSLF program is still available. If you work in public service and have made 120 payments, you can request forgiveness through the standard PSLF program by submitting an Employment Certification Form to your servicer.