Student Loans After SAVE: From the Court Block to the Repayment Assistance Plan

Education Department appeals the PSLF vacatur to the First Circuit

The department notified the court on August 27 that it would appeal Judge Myong J. Joun's June 30 decision, which granted summary judgment to the plaintiffs and vacated the PSLF employer-eligibility rule, to the U.S. Court of Appeals for the First Circuit. The vacatur stays in effect while the appeal is pending, so the 'substantial illegal purpose' employer test is not being applied.

• NASFAA · Aug 28, 2026 · “The vacatur remains in effect while the appeal is pending.”

responded to Judge Joun vacates the PSLF 'substantial illegal purpose' rule hours before it takes effect.

Editor's note: Hand-checked against the NASFAA report; the court is identified via Judge Joun.

Labor unions file RISE professional-degree lawsuit

AFL-CIO, AFSCME, American Federation of Teachers, and National Nurses United filed a lawsuit challenging the RISE professional-degree definition. The complaint also challenged RISE restrictions on transition protection for some already-enrolled borrowers.

• U.S. District Court for the District of Columbia · Aug 11, 2026 · “This lawsuit thus pursues objectives germane to the AFL-CIO’s purposes.”

Editor's note: The complaint identifies AFL-CIO, AFSCME, AFT, and NNU as plaintiffs and challenges both the RISE Rule’s professional-student definition and restrictions on its interim exception for certain already-enrolled borrowers. It is stamped as filed on 08/11/26, and the quoted sentence appears in the AFL-CIO standing allegations.

Massachusetts judge denies nursing groups' RISE injunction request

A Massachusetts federal judge denied without prejudice nursing associations' request for preliminary relief from the RISE professional-degree definition. The court found the plaintiffs likely to succeed on their contrary-to-law argument but found no present irreparable harm requiring an injunction.

• U.S. District Court for the District of Massachusetts, via Justia docket filing · Aug 10, 2026 · “Plaintiffs’ motion for preliminary injunction and a stay (Dkt. 14) is DENIED without prejudice to supplementation or renewal consistent with this opinion.”

Editor's note: The memorandum and order is dated 2026-08-10 and denies the plaintiffs' preliminary-injunction and stay motion without prejudice. It finds plaintiffs likely to succeed on their contrary-to-law claim but concludes they have not shown likely irreparable harm warranting preliminary relief at that time.

Havens v. Education Department: SAVE borrowers ask for an emergency order to halt the forced plan moves

Four borrowers who sued in March 2026, arguing the department must implement SAVE or, failing that, the REPAYE plan it replaced, filed their response to the government's motion to dismiss and asked the D.C. district court to pause the transfer of roughly seven million borrowers out of the SAVE forbearance. The department argued the Eighth Circuit had already found REPAYE forgiveness had the same legal defect as SAVE and that Congress ends REPAYE on July 1, 2028 regardless.

• The College Investor · Aug 7, 2026 · On August 7, the four borrowers behind the case filed their response to the Education Department's request to throw the case out, and they asked the judge for an emergency order that would pause the forced move of roughly 7 million borrowers into new repayment plans.

GAO finds gaps in Education's servicer-change instructions

The U.S. Government Accountability Office reported that servicers faced implementation challenges because Education did not consistently provide clear advance instructions for program changes. GAO recommended criteria for early coordination with servicers, and the U.S. Department of Education disagreed with that recommendation.

• U.S. Government Accountability Office · Jul 13, 2026 · “We found servicers faced challenges implementing program changes due to a lack of clear upfront instruction from Education.”

Editor's note: The page states that servicers faced challenges due to a lack of clear upfront instruction from Education, recommends formal criteria for early coordination, and says Education disagreed. It lists the report as published on 2026-07-13.

Judge Joun vacates the PSLF 'substantial illegal purpose' rule hours before it takes effect

Judge Myong J. Joun of the U.S. District Court for the District of Massachusetts granted summary judgment to the plaintiffs and vacated the Public Service Loan Forgiveness employer-eligibility rule on June 30, the day before its July 1 effective date. On July 13 Federal Student Aid said it was removing the employer attestation it had just added to the PSLF form to comply with the order.

• U.S. District Court for the District of Massachusetts · Jun 30, 2026 · “The Final Rule is VACATED.”
• Federal Student Aid · Jul 13, 2026 · “The Department is now removing the attestation from the PSLF form in order to comply with the court order.”

was answered by Education Department appeals the PSLF vacatur to the First Circuit.

Editor's note: Hand-checked: Justia docket order and the FSA July 13 notice both quoted.

Federal Student Aid reports about nine million borrowers in default

Federal Student Aid released portfolio reports containing data through March 31, 2026. The reports showed approximately nine million federally managed loan recipients in default, 8.4 million recipients in forbearance, and approximately 13 million borrowers in IDR plans.

• Federal Student Aid · Jun 23, 2026 · “This update refreshes more than 70 quarterly application, disbursement, and loan portfolio reports to include data through March 31, 2026.”

Editor's note: The announcement is posted June 23, 2026, states that more than 70 reports were refreshed with data through March 31, 2026, and reports approximately nine million borrowers in default, 8.4 million in forbearance, and approximately 13 million enrolled in IDR plans.

One-point interest rate cut for borrowers on auto pay, if they enroll by September 30

To push borrowers into the new plans and back onto automatic payments, the department offered a 1 percentage point interest reduction from July 1, 2026 through June 30, 2028 for anyone enrolled in auto pay by September 30, 2026, up from the usual 0.25 point discount. It said auto-pay enrollment had fallen from more than 80 percent of borrowers in active repayment before the pandemic to 40 percent.

• U.S. Department of Education · Jun 18, 2026 · Today, the U.S. Department of Education (the Department) announced that federal student loan borrowers enrolled in auto pay will be eligible for a 1 percent interest rate reduction beginning July 1. Borrowers who enroll in auto pay by September 30, 2026, or who are already enrolled, will benefit from the interest rate reduction through June 30, 2028.

Glitches and bad payment estimates hit borrowers two weeks before the July 1 switch

Borrower-assistance groups told CNBC that the department's online income-driven repayment application was showing wrong plan eligibility and monthly payment estimates, servicers were sending erroneous delinquency notices to borrowers still in forbearance, and some borrowers were being told to consolidate unnecessarily, as nearly seven million SAVE enrollees prepared to change plans with an agency that had lost close to half its staff.

• CNBC · Jun 16, 2026 · But student loan borrowers are encountering technical issues and misinformation in the weeks leading up to the massive changes, advocates say.

Multistate coalition challenges RISE professional-degree definition

A multistate coalition sued the U.S. Department of Education over the RISE rule's professional-degree definition. North Carolina Attorney General Jeff Jackson said the definition affected nursing, physician-assistant, therapy, occupational-therapy, and audiology programs.

• North Carolina Department of Justice · May 19, 2026 · “What Congress didn’t do was change the pre-existing definition of professional degrees.”

Editor's note: The page says Attorney General Jeff Jackson sued the U.S. Department of Education over a rule narrowing the definition of a professional degree and identifies nurses, physician assistants, physical therapists, occupational therapists, and audiologists as affected. It is dated Tuesday, May 19, 2026, and includes the quoted sentence.

Federal Student Aid updates portfolio reports through December 2025

Federal Student Aid released updated portfolio reports containing data through December 31, 2025. The reports showed 7.7 million federally held loan recipients in default, more than 6.5 million borrowers in SAVE forbearance, and nearly 12.9 million borrowers enrolled in IDR plans.

• Federal Student Aid · Mar 13, 2026 · “This update refreshes more than 70 quarterly application, disbursement, and loan portfolio reports to include data through Dec. 31, 2025.”

Editor's note: The page is readable and was posted March 13, 2026. It states that more than 70 quarterly reports were refreshed through Dec. 31, 2025, and supports the cited default, SAVE forbearance, and IDR enrollment figures.

Judge Ross throws out the SAVE case rather than bless the settlement

Judge John Ross of the Eastern District of Missouri dismissed the lawsuit and the proposed settlement, finding no live controversy because both sides now wanted SAVE gone and Congress had already scheduled its end for July 1, 2028. The order neither revived nor struck down SAVE, leaving seven million enrollees in limbo and prompting a separate borrower suit demanding the plan be implemented.

• NASFAA · Mar 2, 2026 · On Friday, in a court order, Judge John Ross of the U.S. District Court for the Eastern District of Missouri dismissed this settlement, arguing that there is “no longer a live case or controversy sufficient,” therefore, the court doesn’t have authority to enter a judgment.

Nonpayment data: more than 1,800 colleges have a quarter or more of borrowers not paying

Alongside new default-management guidance, the department published updated institution-level nonpayment rates as an early warning for cohort default rates, which can cost a school its access to federal aid at 30 percent for three years or 40 percent in one. Under Secretary Nicholas Kent said institutions 'cannot benefit from taxpayer dollars while ignoring' the numbers.

• U.S. Department of Education · Feb 18, 2026 · The Department also released updated nonpayment rates by institution, which may serve as an early indicator of whether a college or university may be at risk of failing the CDR measure. The new data show that over 1,800 institutions have nonpayment rates at or exceeding 25 percent.

Proposed rule published: loan caps, program-level limits and the two new repayment plans

The department issued its notice of proposed rulemaking to implement the law, with a 30-day comment window. Beyond the statutory caps it proposed letting colleges set program-level loan limits below the statutory maximums, and it carried the RISE committee's narrow professional-degree definition. The department later said it received 80,793 comments.

• U.S. Department of Education · Jan 29, 2026 · The U.S. Department of Education (the Department) today issued a Notice of Proposed Rulemaking (NPRM) aimed at reducing the cost of higher education and simplifying federal student loan repayment, as outlined in President Trump’s historic Working Families Tax Cuts Act (the Act).

Wage garnishment and Treasury offsets delayed weeks after the first notices were due

Having told defaulted borrowers in December that garnishment notices would start the week of January 7, the department reversed course and delayed all involuntary collection, both Administrative Wage Garnishment and the Treasury Offset Program, saying the new law's repayment plan and second-chance rehabilitation should be in place first. The delay ran into tax-refund season and was not given an end date.

• U.S. Department of Education · Jan 16, 2026 · The U.S. Department of Education (the Department) today announced that it will delay the implementation of involuntary collections on federal student loans, including Administrative Wage Garnishment (AWG) and the Treasury Offset Program (TOP). The temporary delay will enable the Department to implement major student loan repayment reforms under the Working Families Tax Cuts Act (the Act) to give borrowers more options to repay their loans.

Wage garnishment to begin the week of January 7 for the first time since 2020

The department told reporters it would start administrative wage garnishment on defaulted borrowers in early January 2026, with notices to a first group of about 1,000 borrowers and more each month, allowing up to 15 percent of disposable pay to be withheld after a 30-day notice. Borrower advocates called the decision cruel while nearly a million income-driven repayment applications sat unprocessed.

• Protect Borrowers · Dec 23, 2025 · Beginning the week of January 7, 2026, the U.S. Department of Education (ED) plans to start garnishing wages from student loan borrowers in default. This will be the first time that borrowers in default are subject to losing their pay over student loans since the COVID-19 pandemic—approximately five years.

Department and Missouri agree to end SAVE outright

Rather than litigate to judgment, the department and Missouri Attorney General Catherine Hanaway proposed a joint settlement under which the department would enroll no new borrowers in SAVE, deny pending applications and move all enrollees into other plans. The department put SAVE's ten-year cost at more than $342 billion and said more than seven million borrowers were still in the forbearance.

• U.S. Department of Education · Dec 9, 2025 · As part of the proposed joint settlement agreement, the Department will not enroll any new borrowers in the illegal SAVE Plan, deny any pending applications, and move all SAVE borrowers into legal repayment plans.

RISE negotiators reach consensus on the whole loan package, including who counts as a 'professional' student

The RISE committee agreed on all 17 regulatory provisions implementing the law's loan changes: eliminating Grad PLUS, capping Parent PLUS, sunsetting the older repayment plans and creating the Repayment Assistance Plan. It also adopted a definition of professional degree drawn from existing regulatory text, the provision that would later be challenged in court.

• U.S. Department of Education · Nov 6, 2025 · Today, the U.S. Department of Education (the Department) concluded its negotiated rulemaking session, where the Reimagining and Improving Student Education (RISE) Committee reached consensus on the entire package of federal student loan-related changes advanced by the One Big Beautiful Bill Act (OBBBA).

PSLF final rule lets the Secretary disqualify employers with a 'substantial illegal purpose'

The department finalized a rule, effective July 1, 2026, amending the definition of a qualifying Public Service Loan Forgiveness employer to exclude organizations it finds engage in illegal activity such as supporting terrorism, aiding illegal immigration or providing gender-transition care to minors. It followed Executive Order 14235 of March 7, 2025, a July negotiated rulemaking and nearly 14,000 public comments.

• U.S. Department of Education · Oct 30, 2025 · The final rule amends the definition of “qualifying employer” to exclude organizations that engage in unlawful activities such that they have a substantial illegal purpose, including supporting terrorism and aiding and abetting illegal immigration.

IBR loan forgiveness resumes after a summer pause

Servicers and borrower advocates confirmed to CNBC that discharges under Income-Based Repayment, which the department had paused in July while it 'responded to court orders', had restarted for borrowers who reached 20 or 25 years of payments. IBR is the one income-driven plan whose forgiveness is written into statute, which made the pause especially contentious.

• CNBC · Oct 6, 2025 · The Trump administration has resumed forgiving student debt for some borrowers enrolled in a program that's been partially paused since July, a trade group told CNBC.

Department sets up the RISE committee to write the new law's loan rules

The Office of Postsecondary Education announced negotiated rulemaking to implement the law, with a Reimagining and Improving Student Education (RISE) committee to handle loan provisions in five-day sessions in September and November and a separate AHEAD committee for Workforce Pell and accountability. A public hearing was set for August 7.

• U.S. Department of Education · Jul 24, 2025 · The Department will create a Reimagining and Improving Student Education (RISE) Committee to address federal student loan-related changes. The RISE Committee will have five-day sessions in September and November.

Involuntary collections begin: 195,000 Treasury offset notices, garnishment warnings to 5.3 million

On the day collections resumed, Treasury started sending 30-day notices to about 195,000 defaulted borrowers that their federal benefits, including Social Security payments and tax refunds, would be offset, with the first offsets hitting June checks. The department said all 5.3 million defaulted borrowers would be told later in the summer that their wages could be garnished, and sent colleges a Dear Colleague letter warning about cohort default rates.

• U.S. Department of Education · May 5, 2025 · Starting today, approximately 195,000 defaulted student loan borrowers will begin receiving an official 30-day notice from the U.S. Department of Treasury notifying them that their federal benefits will be subjected to the Treasury Offset Program. The first monthly benefit checks subject to offset are those scheduled for early June. Later this summer, all 5.3 million defaulted borrowers will receive a notice from Treasury that their earnings will be subject to administrative wage garnishment.

Collections on defaulted loans to restart May 5 for the first time since March 2020

Secretary Linda McMahon announced that Federal Student Aid would resume collecting on the defaulted portfolio on May 5, 2025, through the Treasury Offset Program and later wage garnishment. The department said 42.7 million borrowers owed more than $1.6 trillion, more than five million were in default, four million more were in late-stage delinquency, and only 38 percent of borrowers were current on their loans.

• U.S. Department of Education · Apr 21, 2025 · The U.S. Department of Education today announced its Office of Federal Student Aid (FSA) will resume collections of its defaulted federal student loan portfolio on Monday, May 5th. The Department has not collected on defaulted loans since March 2020.

AFT sues the Education Department for taking down the income-driven repayment application

The American Federation of Teachers filed AFT v. U.S. Department of Education in federal court in Washington, arguing that removing the IDR and consolidation forms and telling servicers to stop processing applications unlawfully cut millions of borrowers off from affordable payments and from progress toward Public Service Loan Forgiveness. The case became the vehicle for court-supervised commitments on the application backlog later in the year.

• Protect Borrowers · Mar 19, 2025 · Last night, the 1.8 million-member AFT sued the U.S. Department of Education (ED) for effectively breaking the student loan system, denying borrowers’ access to affordable loan payments and blocking progress towards Public Service Loan Forgiveness (PSLF), in violation of federal law.