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Student Loans: A Timeline of Actions Taken in Light of the COVID-19 Pandemic (IF12136, Version 1)

Summary

Version 1 of a Congressional Research Service timeline, IF12136, dated June 21, 2022, of waivers and flexibilities that lawmakers and the Department of Education (ED) offered federal student loan borrowers during the COVID-19 national emergency. As of December 31, 2021, approximately $1.6 trillion in federal student loans, borrowed by or for 43.4 million individuals, remained outstanding. The CARES Act of March 27, 2020 suspended interest, payments and involuntary collections on Direct Loan program loans and counted the suspended months toward Public Service Loan Forgiveness. ED then extended the suspensions repeatedly, the latest on April 6, 2022 through August 31, 2022, when it also promised borrowers with paused loans a fresh start. ED estimated over 550,000 borrowers would gain PSLF credit under its waiver.

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                                                                                                                June 21, 2022
Student Loans: A Timeline of Actions Taken in Light of the
COVID-19 Pandemic
Since the onset of the COVID-19 national emergency,                about $3.4 billion, representing debt for approximately
lawmakers and the U.S. Department of Education (ED)                1.2 million borrowers, and ED held nearly $1.1 billion
have made available a number of waivers and flexibilities          in Perkins Loans, representing debt owed by
for federal student loan borrowers. For most borrowers,            approximately 358,000 borrowers.
these flexibilities include the suspension of (1) interest
accrual, (2) the requirement that borrowers make monthly        Loan Waivers and Flexibilities
payments on their loans, and (3) involuntary collections        The following timeline provides information on selected
activities, as well as waivers of requirements to qualify for   actions taken by lawmakers and ED to provide relief to
various student loan forgiveness or discharge benefits.         HEA federal student loan borrowers during, and at least in
While Congress authorized a subset of these flexibilities for   part due to, the COVID-19 national emergency. The
a temporary period, ED has extended those flexibilities         timeline focuses on flexibilities that primarily address ED-
numerous times since their initial expiration and has           held student loans. During the COVID-19 national
effectuated other flexibilities.                                emergency, ED has taken a variety of other student-loan
                                                                related actions that are seemingly unrelated to the COVID-
This In Focus provides an overview of the Higher                19 pandemic. Only administrative actions for which ED has
Education Act (HEA; P.L. 89-329, as amended) Title IV           explicitly referenced the COVID-19 pandemic are included
federal student loan programs affected by the COVID-19          in the timeline below.
pandemic-related flexibilities and a timeline of actions
taken by lawmakers or ED authorizing, effectuating, or          For an in-depth description of flexibilities and waivers
extending such flexibilities.                                   available to federal student loan borrowers in light of the
                                                                COVID-19 pandemic, see CRS Report R46314, Federal
HEA Student Loans                                               Student Loan Debt Relief in the Context of COVID-19.
HEA Title IV authorizes the operation of three federal
student loan programs: the William D. Ford Direct Loan          2020
(Direct Loan) program, the Federal Family Education Loan
(FFEL) program, and the Federal Perkins Loan program.
                                                                 March 20, 2020: ED announced that all borrowers of
                                                                   ED-held loans would automatically have their interest
While new loans are currently authorized to be made only
                                                                   rate set to 0% for at least 60 days; each borrower would
through the Direct Loan program, previously made FFEL
                                                                   have the option to suspend their payments for at least
and Perkins Loans remain outstanding and borrowers
                                                                   two months; and borrowers who were more than 31 days
remain responsible for repaying them. As of December 31,
                                                                   delinquent on their loans as of March 13, 2020 (or who
2021, approximately $1.6 trillion in HEA Title IV loans,
                                                                   became more than 31 days delinquent thereafter) would
borrowed by or on behalf of 43.4 million individuals,
                                                                   automatically have their payments suspended.
remained outstanding.
                                                                 March 27, 2020: Congress and the President enacted the
 Direct Loan program loans are held by ED. As of                  Coronavirus Aid, Relief, and Economic Security Act
   December 31, 2021, approximately $1.4 trillion in these         (the CARES Act; P.L. 116-136). The CARES Act
   loans, borrowed by or on behalf of 37.2 million                 suspended interest accrual, monthly loan payments, and
   individuals, was outstanding.                                   involuntary collections on Direct Loan program loans
                                                                   and ED-held FFEL program loans through September
 FFEL program loans may be held by private lenders,               30, 2020. It also specified that suspended payments
   guaranty agencies (GAs), or ED. As of December 31,
                                                                   were to count toward the 120 monthly payments
   2021, approximately 10.0 million borrowers owed about
                                                                   required under the Public Service Loan Forgiveness
   $225.7 billion in FFEL program loans. Of that, about
                                                                   (PSLF) program, toward the 20- or 25-year repayment
   $117.7 billion was held by private lenders, representing
                                                                   periods under the income-driven repayment (IDR) plans,
   debt for about 4.5 million borrowers; $25.3 billion was
                                                                   and toward the nine voluntary payments required for
   held by GAs, representing debt for about 1.1 million
                                                                   individuals to rehabilitate their defaulted loans. Soon
   borrowers; and about $82.7 billion was held by ED,
                                                                   thereafter, ED specified that these policies would apply
   representing debt for between 2.8 million and 5.5
                                                                   to ED-held Perkins Loans.
   million borrowers.
 Perkins Loan program loans may be held by                      August 21, 2020: ED announced, in accordance with a
   institutions of higher education (IHEs) that made the           Presidential Memorandum dated August 8, 2020, an
   loans or by ED. As of September 23, 2021, IHEs held             extension of the interest, payment, and collections
                                                                   suspensions through December 31, 2020.
                                               https://crsreports.congress.gov
                                           Student Loans: A Timeline of Actions Taken in Light of the COVID-19 Pandemic

 December 4, 2020: ED announced an extension of the             Borrowers may also receive PSLF payment credit for
   interest, payment, and collections suspensions through        periods of military service deferment, or forbearance for
   January 31, 2021.                                             active military state duty or military mobilization.

2021                                                             As of May 2022, more than 127,000 borrowers have
                                                                 qualified for forgiveness benefits as a result of the
 January 21, 2021: ED announced an extension of the
                                                                 waiver. ED estimated that over 550,000 borrowers who
   interest, payment, and collections suspensions through
                                                                 consolidated their loans prior to the waiver would see an
   September 30, 2021.
                                                                 increase in their PSLF qualifying payment counts, with
 March 29, 2021: ED announced a suspension, through             the average borrower receiving an additional two years
   the end of the COVID-19 emergency, of the requirement         of progress toward forgiveness, and that many more
   that certain borrowers who received a Total and               borrowers who had not yet consolidated their loans
   Permanent Disability (TPD) discharge provide                  would see progress toward receipt of PSLF benefits.
   subsequent earnings documentation in accordance with
   the three-year post-TPD monitoring period. ED also
                                                               December 22, 2021: ED announced an extension of the
                                                                 interest, payment, and collections suspensions through
   announced that TPD loan discharges would be restored
                                                                 May 1, 2022.
   for borrowers whose loans were reinstated because they
   did not submit earnings documentation in accordance
                                                              2022
   with the three-year monitoring period between March
   13, 2020, and the end of the COVID-19 emergency. ED         April 6, 2022: ED announced an extension of the
   estimated more than 41,000 borrowers who had $1.3             interest, payment, and collections suspensions through
   billion in loans reinstated would have their discharge        August 31, 2022. ED also announced that “all borrowers
   restored and that 190,000 borrowers in their three-year       with paused loans” will receive a “fresh start on
   monitoring period would not be required to submit             repayment by eliminating the impacts of delinquency
   earnings documentation.                                       and default and allowing them to reenter repayment in
                                                                 good standing.”
 March 30, 2021: ED announced the suspension of
   interest accrual and involuntary collections on GA-held     April 19, 2022: ED announced the establishment of IDR
   FFEL program loans, retroactive to March 13, 2020. ED         plan account adjustments to provide credit toward loan
   also announced the transfer of some GA-held FFEL              forgiveness. Through these adjustments, ED will
   program loans that defaulted on or after March 13, 2020,      conduct a one-time revision to the accounts of
   to ED and the placement of such loans in good standing.       borrowers with Direct Loan and ED-held FFEL program
   In effect, this ensured that the transferred loans would      loans. Borrowers are to receive credit toward the IDR
   be considered held by ED and subject to the interest,         plan loan forgiveness period for any months in which
   payments, and collections suspensions, retroactive to         they had time in repayment status, “regardless of
   March 13, 2020. ED estimated that up to 1.14 million          payments made, loan type, or repayment plan”; 12 or
   borrowers would be affected by this action.                   more months of consecutive forbearance or 36 or more
                                                                 months of cumulative forbearance; months spent in
 August 6, 2021: ED announced an extension of the               deferment (excluding in-school deferment) prior to
   interest, payment, and collections suspensions through        2013; and any time in repayment prior to consolidation.
   January 31, 2022.                                             Borrowers with loans that have accumulated time in
 August 19, 2021: ED announced an indefinite extension          repayment for 20 or 25 years will receive automatic loan
   of the suspension of the requirement that certain             forgiveness, even if they are not currently enrolled in an
   borrowers who received a TPD discharge provide                IDR plan. Borrowers with FFEL program loans not held
   subsequent earnings documentation during the three-           by ED may qualify for the account adjustment by
   year post-TPD monitoring period. While ED did not             consolidating their loans into the Direct Loan program
   specifically reference COVID-19 in making this                before ED completes implementation of the changes,
   announcement, it is an extension of the policy                which ED estimates will be no sooner than January 1,
   announced March 29, 2021, for which ED did reference          2023. Account adjustments will also apply toward the
   COVID-19.                                                     120 monthly payments required for PSLF.
 October 6, 2021: ED announced the establishment of the         ED estimated that several thousand borrowers would
   PSLF Limited Waiver. Under the waiver, through                receive immediate IDR plan loan forgiveness, more than
   October 31, 2022, borrowers may receive PSLF                  3.6 million borrowers would receive at least three years
   payment credit for, among others, periods of repayment        of additional progress toward IDR plan loan
   on Direct Loan, FFEL, and Perkins Loan program loans,         forgiveness, and over 40,000 borrowers would receive
   regardless of whether payments were made according to         immediate PSLF program forgiveness under these
   a nonqualifying repayment plan, made late, made for           changes.
   less than the amount due, or made prior to consolidation
   into the Direct Loan program. Borrowers with loans not     Alexandra Hegji, Analyst in Social Policy
   made under the Direct Loan program must apply to
   consolidate their loan(s) into the Direct Loan program                                                          IF12136
   by October 31, 2022, to receive payment credit.


                                             https://crsreports.congress.gov
                                            Student Loans: A Timeline of Actions Taken in Light of the COVID-19 Pandemic




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                              https://crsreports.congress.gov | IF12136 · VERSION 1 · NEW


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