Page 2 GAO-24-107150 Federal Student Loans
Education expects the SAVE plan to result in lower monthly payments for most borrowers
compared to other IDR plans.
4
On July 18, 2024, the U.S. Court of Appeals for the Eighth Circuit
granted an emergency motion for a stay temporarily prohibiting Education from implementing
the SAVE plan.
5
On July 19, 2024, Education announced that borrowers enrolled in the SAVE
plan would be placed in an interest-free forbearance while the litigation was ongoing.
6
Education also established temporary relief options for certain borrowers during the initial period
of resuming repayment. Education instituted a 12-month “on-ramp” to repayment, running from
October 1, 2023, to September 30, 2024, so that financially vulnerable borrowers who miss
monthly payments during this period are not reported as delinquent to credit bureaus, placed in
default, or referred to debt collection agencies. These protections are provided automatically to
borrowers who miss payments—there is no action needed from borrowers. Education also
implemented Fresh Start, a temporary program running through September 2024 that allows
borrowers with defaulted loans to restore them to good standing without the typical requirement
of loan consolidation or loan rehabilitation.
7
Borrowers who restore their loans to non-defaulted
status gain access to IDR plans and postponement options to help them manage repayment.
8
You asked us to provide information on the resumption of student loan repayment. This report
describes the extent to which
(1) borrowers were current on their student loan payments, and
(2) borrowers enrolled in the SAVE repayment plan.
On June 5, 2024, we briefed congressional staff on our preliminary observations. This report
transmits a final version of the briefing slides. We have updated the slides to include information
about relevant ongoing litigation and the status of the SAVE plan after the briefing (see
enclosure I). We have ongoing work examining other related topics, including Education’s
4
Lower monthly payments for borrowers enrolled in the SAVE plan are possible because Education set payment by a
smaller proportion of their income compared to other IDR plans. Monthly payments are set as a proportion of the
borrower’s discretionary income, which Education defines as adjusted gross income that exceeds 225 percent of the
applicable poverty guideline for the SAVE plan, 100 percent of the applicable guideline for the Income-Contingent
Repayment plan, and 150 percent of the applicable guideline for the Income-Based Repayment and Pay As You Earn
plans. Also, under the SAVE plan, if a borrower makes a full monthly payment, the borrower will not be charged any
remaining accrued interest that month. However, for some borrowers with higher income, the SAVE plan may result
in higher payments compared to repayment plans that cap monthly payment amounts at less than or equal to the
fixed monthly payment amount under the Standard 10-year repayment plan.
5
In addition, as of July 19, 2024, there was other litigation involving SAVE that was ongoing. Specifically, on June 24,
2024, the federal court for the District of Kansas issued a preliminary injunction enjoining Education from
implementing parts of the SAVE plan. On June 30, 2024, the U.S. Court of Appeals for the Tenth Circuit granted an
emergency motion for a stay of that preliminary injunction pending appeal.
6
Forbearance allows eligible borrowers to temporarily postpone making payments.
7
Loan consolidation and loan rehabilitation are two options that allow eligible borrowers to get their loans out of
default after they make a series of voluntary on-time monthly payments. For example, borrowers who make at least
three on-time monthly payments can pay off defaulted loans by consolidating one or more loans into a single loan
with a fixed interest rate. Borrowers who make nine on-time monthly payments within 10 months may be eligible for
loan rehabilitation, which entitles them to have the default removed from their credit report. However, borrowers may
rehabilitate a loan only once.
8
As part of the Fresh Start program, Education opted not to resume collections on defaulted loans, such as wage
garnishments and offsets on tax refunds or federal benefit payments.