Why It’s a Bonus, Not a Plan

A lot of borrowers are stressed about whether PSLF Buyback will still exist by the time they qualify.It makes sense — when you’ve spent years working toward forgiveness, the thought of losing credit for past payments can feel like a punch in the gut.The PSLF Buyback program was created to help people who were steered into forbearance instead of income-driven repayment (IDR).It’s a way to “buy back” those lost months so they count toward the 120 needed for Public Service Loan Forgiveness (PSLF).

It’s a great idea in theory.And it has worked for some borrowers, but the reality is messy.The backlog is enormous, the rules are murky, and the entire thing exists because of a temporary regulation, not a permanent law.That matters, because regulations can change a lot faster than laws can.

So if you’re hoping PSLF Buyback will erase years of lost credit, it’s time to understand what’s really going on and how to protect yourself if it goes away.Why PSLF Buyback exists and why the system’s straining Buyback wasn’t designed as a sweeping forgiveness program.It started as a small fix for a specific problem: servicers who pushed borrowers into forbearance because it was faster than setting up income-driven repayment.Under the Biden-Harris administration, the Department of Education gave borrowers a way to correct those mistakes once they reached 120 months of qualifying public service employment.

You could submit your employment certification, apply for PSLF Buyback, and get retroactive credit for those wrongly labeled months.Then everything exploded.When millions of borrowers were placed into SAVE forbearance in 2024, a huge chunk of them (roughly 9 million) became eligible for Buyback.Since around a quarter to a third of borrowers are on PSLF-eligible repayment plans, that meant roughly 3 million people suddenly qualified.

To date, about 70,000 have applied and only around 7,000 have been processed.That ratio keeps getting worse as more borrowers reach eligibility.Combine that with a severely understaffed Department of Education and you’ve got a recipe for long waits, inconsistent communication, and a growing sense of panic.To make things even more complicated, the American Federation of Teachers has filed a lawsuit to force the Department to process Income-Based Repayment (IBR) and PSLF according to existing laws and regulations and not slow-walk things.

Why PSLF Buyback might not survive Here’s the uncomfortable truth: PSLF Buyback isn’t part of the PSLF law.It’s just a regulation.That distinction is everything.Public Service Loan Forgiveness itself is written into federal statute.

But Buyback is a regulation.That means with the negotiated rulemaking that the Department of Education is doing, they could turn off PSLF Buyback — and frankly, I think they probably will.If there’s a change, it wouldn’t happen overnight.Let’s say a new regulation was published in late 2025.

It likely wouldn’t take effect until July 2026, which means borrowers who’ve already hit 120 months and submitted their applications before that window closes might still qualify.How to protect yourself while waiting If there’s one rule I’d want every borrower to remember, it’s this: don’t build your financial life around PSLF Buyback working.Think of it as a nice surprise if it comes through, not something you can count on.Keep doing what you can control: Certify your employment every year or whenever you change jobs.

Stay on an eligible IDR plan.  Keep making payments while you wait.If you overpay, you’ll be refunded when forgiveness hits.Apply as soon as you hit 120 months of qualifying employment.Don’t try to “time” the system or pause payments hoping PSLF Buyback will do all the work.

That’s a gamble with too much at stake.The smart move is to keep stacking PSLF credit the old-fashioned way while Buyback processes in the background.If it disappears, you’re still progressing toward regular PSLF forgiveness.If it stays, you might just get extra months counted that bring you across the finish line faster.

Either way, you win.When Buyback doesn’t matter (and when it does) For most borrowers, PSLF Buyback is icing on the cake.You’ll hit 120 months eventually through continued qualifying work, even if it takes a bit longer.Where it really matters is for borrowers right at the edge.

Those sitting on 118 or 119 months who could apply soon.For them, timing is critical.Submit early and get yourself in the queue, because if the regulation changes, being “in process” could make the difference between getting approved or losing the opportunity altogether.There’s also a subset of older borrowers who take a very different approach: the “die-with-debt” strategy.

If you’re in your 70s or 80s, with lower income and decades of accumulated student loans, it can make sense to minimize payments, use forbearance strategically, and plan for the debt to die with you.  Federal loans aren’t collected from your estate, and if you’re planning to rely on Medicaid or long-term care in later life, it’s smart to coordinate with an estate attorney.Protecting your home or assets through proper trust planning can make a huge difference.That might sound extreme, but for many retirees, it’s the most practical route.The point is that your plan has to fit your life, not the other way around.

PSLF Buyback was never intended to be a mass fix for everyone with student loans.It was a targeted remedy that ballooned into something much bigger once millions of people qualified all at once.The good news: Some borrowers are getting approvals and refunds.  The bad news: The queue is long, the rules could change, and the Department of Education is already underwater processing existing forgiveness programs.So keep moving forward with your PSLF plan.

Certify employment, make payments, stay eligible.That’s the solid ground.If PSLF Buyback comes through, fantastic! You’ll shave months or even years off your forgiveness timeline.If it doesn’t, you’ll still be on track for full PSLF forgiveness, which remains secure and tax-free under federal law.