The Department of Education regularly releases PSLF data. We’re continuing to see high rates of updated PSLF counts from ECF’s, hovering in the 98-99%. That means most people submitting ECF’s met employment certification requirements, resulting in an updated qualifying payment count to track PSLF/TEPSLF progress.
Perhaps due to the PSLF limited waiver initiated in October 2021, more student loan borrowers may have submitted ECF’s even though they did not have any Direct Loans (required for PSLF). As a result, the PSLF data shows an increase in ECF’s that did not meet yet meet the PSLF requirements, from 0.3% and 0.4% in January and February 2022 to 1.2% and 1.1% in April and May 2022, respectively. So around 900 borrowers did not have Direct Loans that qualified in January, but there’s a huge jump to 8,500 borrowers who did not have qualifying Direct Loans in May.
The Department of Education emphasizes in a footnote that those borrowers without Direct Loans may qualify due to the limited waiver:
“**Under the waiver process, borrowers could submit employment certification data for non-DL federal loans, but borrowers would still be required to consolidate into Direct Loans to benefit from the PSLF waiver. In these cases, the PSLF servicer will evaluate the employer for eligiblity, but also advise the borrower to consolidate their non-DL loans into a Direct Loan to be eligible for PSLF. Once the borrower consolidates into a Direct Loan, the borrower will not be required to submit a new form (assuming the employer was eligible); instead, the form submitted prior to the loan consolidation will be reevaluated to ensure the borrower gets any applicable PSLF credit.”
So the PSLF program is improving even if the data looks otherwise.
Take a look at the data below: