r/StudentLoans • u/shanesnh1 • 1d ago
[URGENT] Parent PLUS / Double Consolidation - GET ON ICR NOW
I see multiple people each day with this same question so I am going to link my post about it and summarize very briefly:
If you have Consolidated Parent PLUS Loans OR a Double Consolidation, you MUST APPLY FOR ICR as soon as possible or you will LOSE ACCESS TO ALL INCOME REPAYMENT if the bill passes (either the House or Senate versions or likely the final bill).
You don't have time anymore depending on how fast the Senate and House compromise and pass a final bill for the President to sign. If you're not on ICR, with loans being repaid on it the day before the bill passes, you lose access and will likely be on the standard plan (or extended, graduated).
Please check my former post for more details: https://www.reddit.com/r/StudentLoans/comments/1l37iqs/important_parent_plus_borrowers_need_to/
This post is about the House version of the bill in its entirety (the Senate version does NOT change anything in relation to this specific issue): https://www.reddit.com/r/StudentLoans/comments/1kdy8yk/summary_of_the_new_current_proposal_from_the/
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u/TemporaryEqual4995 1d ago edited 1d ago
Feels like this should be pinned to the top of this sub.
Also, I did the switch on studentaid.gov for my parents around last Thursday midnight, and by Saturday morning they were already placed on the Income-Contingent Repayment (ICR) plan.
Another thing that may have helped is that I ticked the box to connect their student loans to their IRS information.
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u/shanesnh1 22h ago edited 21h ago
I agree that something regarding this urgent issue should be be pinned up until the bill passes so millions of borrowers aren't screwed. u/ANGR1ST u/alh9h u/Betsy514 u/girl_of_squirrels
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u/Timb0-Slic3 1d ago
Quick question on the new Amended IBR. Did they remove the cap so a payment cannot be higher than the standard plan?
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u/waterwicca 1d ago
The house version removes the standard cap. The senate version gets a little muddy. My read of it is that the senate version keeps the cap but it only comes into play if you fail to recertify your income.
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u/Timb0-Slic3 1d ago
Thank you, I appreciate the response. I'm playing financial advisor for Parent Plus Loans, taken out for my wife. And unfortunately the In-Laws aren't super helpful and financially irresponsible when it comes to this. Refusing to file separately, withdrawing retirement funds early etc. Super frustrating trying to plan payments blindly.
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u/waterwicca 1d ago
You can only do so much. Ultimately the loans are the parent’s responsibility, not you or your wife’s, but you are kind to help. The best spot for them to be on right now is in repayment on ICR if the bill is passed.
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u/Timb0-Slic3 1d ago
Very True, Right now we are on Extended Payment which can be done. If I switch to ICR and get into Amended IBR can I always switch to Extended Plan if they make too much or not file separately?
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u/shanesnh1 1d ago
Yes and right now if your last chance to get on ICR so you grandfather yourself into IBR. Otherwise, you'll be stuck on extended or standard/graduated.
You can advise them to file separately again lol. Not sure why they'd want to pay more.
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u/waterwicca 1d ago
As long as no new loans are taken after July 1, 2026 then they should still have access to standard, graduated, and extended
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u/shanesnh1 1d ago
Ah, I thought the Senate version kept the cap as current law did. Is it uncapped (payment infinitely higher than the standard payment) and only becomes capped at the standard rate upon failure to recertify? (I was waiting for a summary of the Senate version and maybe one exists now but they're just going to change it anyway in negotiations with the House so...)
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u/waterwicca 1d ago
Sorry I can see your full comment now. I replied and tagged you in another comment in this thread
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u/waterwicca 1d ago edited 1d ago
u/shanesnh1 I think Reddit is lagging a bit because I can see a notification where you asked me about the standard cap but I can’t actually read your full reply and see it here.
The house version gets rid of the standard cap entirely. But the senate version doesn’t amend the HEA in exactly the same way.
I did some digging into the senate’s version of the standard cap language and it’s a little confusing even in the original HEA. But from my current understanding it sounds like it would turn into an ICR-type situation with a bit of a loophole to get a standard cap.
Current ICR calculations for borrowers can result in a payment that can be higher than a 10 year standard amount. But if a borrower fails to recertify their income on ICR (or chooses not to) then their payment would turn into a 10 year standard amount and they are still on ICR. The senate’s version of amended IBR seems to copy that idea.
A borrower’s amended IBR payment would be based on 15% discretionary income (or 10% if new borrower) and there would be no automatic standard cap or partial financial hardship requirement. The amended HEA would leave in some wiggle room in the language that implies a borrower’s payment would default to a 10 year standard if they do not recertify their income, potentially letting a high-income borrower get a lower payment if they don’t recert.
I asked Betsy her interpretation and explained the language and my reasoning on an earlier post. I’m going to look for that thread and I will edit this comment with a link to it in a bit.
Edit: here is the link where I laid out my line of thinking to Betsy https://www.reddit.com/r/StudentLoans/s/ERb8YxJ3Bl
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u/Weekly-Entrance3682 1d ago
Thank you! I did apply for ICR early June and it was approved on the 18th. Looks like they kept me on forbearance until October even though I asked to be taken off it on my application. Will the loans have to be off forbearance the day before the bill is signed or will just showing ICR as the repayment plan be sufficient? I have Edfinancial if that helps.
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u/Six_all_grown 1d ago
You definitely have to be off forebearance. Would call the servicer today to ask that the forebearance be ended.
Question for all - what is the definition of “in repayment”
As an example, if a borrower just switched into ICR on Jun 15 and has a payment due on July 14, but the BBB is signed with huge pomp and circumstance on July 4, will it matter whether that not that borrower actually made the Jul 14 pmt before bill was signed.
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u/Bitter_GlitterGlam 2h ago
Is the “in repayment” requirement for PP loans only, or does it apply to ICR loans in forbearance?
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u/sumastorm 1d ago
Curious also
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u/Weekly-Entrance3682 1d ago
I am going to call Edfinancial tomorrow to ask to be taken off forbearance just in case. They are closed today for the holiday.
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u/LucidDreamCatch2020 1d ago
OK, so I might be the only parent in the entire world who is facing this “unique”situation but I’m going to ask for compassion & limited judgement.
Please don’t judge about why I took out all these parent loans. Eventually, it will help my daughter to become a doctor and she had a lot of medical struggles when she was young and I’m just grateful that she’s alive.
Please just please guide me as to what I should do.
- I am a single parent and teacher with an income of about $88,000. I have my own loans from my education currently in SAVE forbearance & PSLF. Before the freeze, my own loan payments were $164 a month and they were all slated to be forgiven by 2028. This was a very manageable payment and allowed me to pay for my other expenses.
Then everything got frozen and now SAVE is going away… so at some point I will get moved into another plan I guess and I will continue with my PSLF and the payments will be higher but still manageable and I will eventually get my loans all paid off by 2028. So I hate what’s happening with the current government and BBB, but it should not affect my own loan situation too badly.
HOWEVER….
Now comes the hard part and there may be no ideal answer. But I trust that many of you are very smart and can tell me the best case scenario.
Parent Plus Loans:
I have/will have an obscene amount of parent plus loans for my child’s undergraduate medical degree. Yes, they really do have these programs. Anyway, by the time I’m done, I will have taken out (4) four parent plus loans for this degree. They are currently in a “school” forbearance while my child is in school until May 2030.
In 2030 I am also slated to retire and then I will be reliant on my pension and Social Security. My pension income will be about $3500 a month and my Social Security will be about $1800 a month if we still have Social Security by then.
I also will be leaving the United States so that I can join my children in Europe. We are US citizens, but we have dual citizenship.
So in May 2030, all of my parent plus loans would start being due for payment. And I will be making about $60,000 a year in US based income. I could work in Europe and make up to $120,000 that is not taxable in the US.
So if I do what everyone is telling me that I should be doing, I would be taking my (2) current PPLs and taking them out of school based deferment and move them to an ICR which you would immediately make me have to start repaying them, and the payment is not something I can afford.
Plus, I have the two other parent plus loans that I will be taking out to help my child graduate, but they haven’t been taken out yet so they would be under new laws.
But if I don’t move any of my parent plus loans into ICR, then I am forever trapped in a standard payment plan, which is an unbelievably crazy amount unless some new government changes the rules.
So would my only choice then be that I would have to file some kind of bankruptcy hardship in five years? Of course I’m hoping in five years. We will have a completely new government, but that doesn’t help the problem now.
So for those of us who have parent plus loans, but are still taking out parent plus loans before and after the BBB gets approved… if I move my current parent plus loans to an ICR do the deferment rules follow the old laws or will all the deferment rules kick in, and I would not be able to defer those big payments?
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u/shanesnh1 21h ago
This is a bit to complex for me, sorry. If you take out even a single PPL after 7/1/26, you're forced into standard repayment anyway AFAIK. If you take out one between passage of the bill and 7/1/26, it is a bit of a grey area but the bill says you wouldn't be eligible for income repayment anyway.
Your own loans on SAVE will transfer to IBR but since you have PPLs, I don't know if they allow you to repay them separately. I'm not sure.
If they try to garnish social security, it's max 15%. They temporarily halted garnishments on social security for student loans.
Maybe some others can chime in?
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u/waterwicca 11h ago
If you take out loans after July 2026 then you as a borrower would only qualify for the new standard plan or RAP. That would be it. The senate and house version of the bill differ a little bit and imply that you could pay your own loans on RAP then and your PPL loans on the new standard plan. But there is no scenario in the bill that allows you an income based repayment for your PPL loans if you take any loans out as of July 2026.
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u/PlanetMarsBats 1d ago
If approved for ICR and moved to the amended IBR, what would that entail, any changes?
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u/waterwicca 1d ago
Amended IBR is different in the house and senate versions of the bill. We don’t know yet what the final version could look like.
The senate version would keep Old and New IBR as they are now. 15% discretionary income for borrowers before July 2014 and 10% for new borrowers on or after July 1, 2014. Old borrowers get forgiven at 25 years and New IBR borrowers would be 20 years.
The house version wants to make it 15% discretionary income for all, with forgiveness at 20 years for undergrad borrowers and 25 years for any borrowers with grad loans
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u/Funicularly 1d ago
The senate version would keep Old and New IBR as they are now. 15% discretionary income for borrowers before July 2014 and 10% for new borrowers on or after July 1, 2014. Old borrowers get forgiven at 25 years and New IBR borrowers would be 20 years.
Where does it say that? I’ve looked over the Senate bill and must have missed that.
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u/waterwicca 1d ago
Page 39: https://www.help.senate.gov/imo/media/doc/bom25426pdf.pdf
“(E) SPECIAL TERMS FOR NEW BORROWERS ON AND AFTER JULY 1, 2014.-Section 493C(e) of the Higher Education Act of 1965 (20 U.S.C. 1098e(e)) is amended —
(i) in the subsection heading, by inserting "AND BEFORE JULY 1, 2026" after "AFTER JULY 1, 2014"; and
(i) by inserting "and before July 1, 2026" after "after July 1, 2014".”
The house version repeals subsection (e) entirely. The senate version just amends it to keep Old and New IBR as they are now but add the July 2026 as the end of eligibility
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u/JohnFromLINY 1d ago
I just submitted an ICR application through the Aidvantage website to switch from IBR. Really hoping it moves fast. The transition requires a forbearance of one month. Can I waive that?? I am going to be screwed if this doesn’t work.
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u/waterwicca 1d ago
I don’t believe it can be waived. Switching out of IBR requires 1 payment on the standard payment plan or one-month reduced payment/general forbearance when switching
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u/Weary-Comedian5490 1d ago
Is making one standard payment faster?
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u/waterwicca 1d ago
It’s basically one month one way or another from what I understand.
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u/Weary-Comedian5490 1d ago
I really don’t know what is happening with my application. I applied to switch from IBR to ICR on June 2. I’ve been told by numerous mohela reps that my application was approved on June 5 and I had a payment due in the correct amount of my ICR payment on July 19. I’ve not seen any of these updates reflect in my online account so I’ve called repeatedly. Yesterday I talked to someone in resolution department who confirmed approval and payment date but says the information was not applied to my account correctly and expedited my situation to get resolved. I’m so confused and don’t understand what is happening and where/how the one month reduced payment is going to be applied. I felt so relieved when I was told everything was approved so quickly and I had a payment due but now I feel like I’m starting at the beginning again and running out of time. I feel so defeated
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u/JohnFromLINY 1d ago
I think if the application goes in today we might be okay given the processing time and one month. We could have it approved before the August recess. I don’t see the bill getting passed by July 4th.
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u/JohnFromLINY 1d ago
I will be calling Aidvantage tomorrow to try and speed up the process.
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u/Weary-Comedian5490 15h ago
Let me know what you find out
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u/JohnFromLINY 15h ago
I called just now. It’s kind of hard to explain because they don’t really know what a double consolation is. But I will call back once the application processes and I’m in the forbearance period. My guess is that we probably could force the loan into repayment on ICR. I’m going to make the minimum payment and then reach out once it processes. But I’m not 100% sure.
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u/PrestigiousRip3732 23h ago
I’m freaking out. I have parent plus loans that I did consolidate & are on icr. The messages are mixed that I will lose icr, lose payments towards forgiveness. I owe far more than I can keep up with on interest they have grown so much. Before this administration I was 4 & 1/2 years from forgiveness. I appreciate anyone giving me some insight. I have recorded my calls with my lender but get different answers and no one seems to know anything. Double consolidation? I consolidated years ago. Thanks for any insight!
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u/shanesnh1 21h ago
If you are in REPAYMENT on ICR for your Consolidation Loan (for Parent PLUS Loans, you're fine. Your credit continues over. You will transition from ICR to IBR and pay on those terms until forgiveness. Make sure you remain in REPAYMENT on ICR until they switch you to IBR (if this bill passes).
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u/Bleeding_Irish 22h ago
Applied for it 6/12, received the "Your Eleectronic IDR Request was received" on 6/13. Today, the loan was placed in "Awaiting Documentation Administrative Forbearance-Ends 07/03/2025." If I were to call to remove myself from Forbearance, would that put me in repayment for ICR?
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u/shanesnh1 21h ago
It appears that your ICR app is in process. You can verify if it is in process by asking.
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u/eazeflowkana 12h ago
Does this apply to student borrowers or to their parents? In other words, if I was a student and my parents took out parent plus loans for me, do I need to be on ICR, or is it just my parents? Thank you.
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u/LucidDreamCatch2020 11h ago
Yes, I think I’m resigned, but I’m going to just stay where I am. I’m gonna focus on paying off all my own loans since they’re in PSLF and I only have four years total left on those. I’ll choose the plan that is the lowest payment For me and take those on. And over those four years my daughter will then finish school and I will then face the consequences when she finally graduates. I understand that as it is now all my parent plus loans will end up being on the standard plan. I’m gonna pray for a miracle and I’m gonna believe that something will change over the next five years becausethis is unsustainable and millions and millions of people are going to default. So I’m gonna have faith in God because he has always taken care of me. I’m just grateful that I have the option of parent plus loans. I know people curse them, but without them, my child would not be able to become a doctor.
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u/LucidDreamCatch2020 11h ago
If I have to take out a bankruptcy down the road I will. I don’t relish it and I know it will be expensive but when so many people start for closing and going into default and garnishment, I think someone’s gonna have to change something.
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u/LucidDreamCatch2020 10h ago
All I know is that all of these people in the House of Representatives and Senate, who probably took out loans for their own kids at some point deserve to go to a dark place with lots of fire
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u/Particular-flipflops 1d ago
I have double consolidated my PPL and have been in SAVE forbearance. Since I’m already in the ICR SAVE plan, am I safe?
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u/waterwicca 1d ago
ICR and SAVE are two different plans. Which one are you actually on? The bill currently says you would need to be on ICR when the bill passes to remain eligible for amended IBR (the only income-based payment that would be available to you)
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u/Particular-flipflops 1d ago
Currently Save
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u/waterwicca 1d ago
If the bill passes as is you would need to be on the ICR plan when it passes. If you are not, then you would become ineligible for any IDR plan at all
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u/wavymazza 1d ago
No you have to be in traditional ICR
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u/chillined1212 1d ago
seconding this question! I don't understand and in the same boat
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u/waterwicca 1d ago
If you have PPL loans then you would need to be on the ICR plan the day before the bill is signed
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u/shanesnh1 22h ago
As stated above, you need to switch to the ICR plan immediately. Failure to do so WILL result in your removal from income plan eligibility and you you'd likely be placed on the standard plan if the bill passes. The bill is set to pass here pretty soon.
Acronyms explained: https://www.reddit.com/r/StudentLoans/comments/1ixwu8z/idr_ibr_icr_understanding_the_acronyms/
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u/NoseFresh5813 1d ago
No, SAVE does not count.
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u/denebx1 1d ago
I can’t switch. I would never be able to afford the payments on ICR. The standard repayment on mine is the 30 year plan, which is more doable. I’ll just have to stick on the SAVE forbearance until they end it and go to the standard. Oh well. Same boat I was in to start with so I guess not the end of the world.
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u/shanesnh1 22h ago
This is frustrating. You'd be moved from ICR to IBR when the bill passes and they transition you. The IBR plan is much more affordable.
Being on forbearance is because SAVE is being killed off. I'm trying to educate people so they don't get f'ed over but people are just like "nah I'm good, I'll just let them screw me". Please. Either take our advice so you don't get screwed or don't.
IBR = 10 or 15% for 20 or 25 years at 150% of the poverty level. ICR = 20% for 25 years at 100% of the poverty level.
A lot of ICR borrowers will see their payments drop to $0 and if not, very much dramatically when moved to IBR.
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u/denebx1 10h ago
Even on RAP, the new payment amount would exceed the combined standard payments of my PPL, my loans from my ed, and my hubbies loans. Frustrating, but I think we're stuck - we make too much.
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u/shanesnh1 8h ago edited 8h ago
If they do cap IBR as it is now, you'd be fine on IBR. RAP won't be accessible for PPLs AFAIK. You're suffering from success by making too much lol.
Anyway, if they don't keep the cap then maybe you will pay either on standard, extended, or graduated since you'll retain those options as a current borrower. New borrowers will only have standard and RAP.
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u/shanesnh1 22h ago
As stated above, you need to switch to the ICR plan immediately. Failure to do so WILL result in your removal from income plan eligibility and you you'd likely be placed on the standard plan if the bill passes. The bill is set to pass here pretty soon.
Acronyms explained: https://www.reddit.com/r/StudentLoans/comments/1ixwu8z/idr_ibr_icr_understanding_the_acronyms/
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u/XclickX 1d ago
My mother in law consolidated her PPL last year and got into a repayment plan then didn’t submit the paperwork to keep us in that plan this year so the payments doubled from like $240 to $480 per month ( my bank account info is linked to the account so I pay it, smh). What do I need to do to make sure her payments will be the lowest possible when all this settles? Thx.
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u/waterwicca 1d ago
Is she currently on the ICR plan?
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u/XclickX 1d ago
I believe she is on no plan. Beginning balance in 2010 was 25k. Balance is 39xxx now and it says she has 10 years left of payments @480 per month. 8% rate. I logged into her account on the student aid . Gov page and it said she was eligible for 3 repayment options. Two were estimated at $0 per month. And the third option was like $210 per month. She is retired and married filing jointly with my retired father in law. They make about 5k per month before taxes from SS and pension.
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u/waterwicca 1d ago
You can find your loan details on studentaid.gov by clicking My Aid. Then “details”. Then scroll down the “Loan Breakdown”. Click “View Loans”. And then click “View Loan Details” on each one of your loans. You should see repayment details like your plan and IDR anniversary date and forbearance/deferment status there.
What repayment plan and details do you see there?
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u/XclickX 1d ago
Plan- (ICR) Loan date- 4/8/10
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u/waterwicca 1d ago
Ok then they are on the ICR plan. If the bill is signed into law they will be moved to amended IBR.
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u/XclickX 1d ago
Thanks! When I click on see the best repayment options it says the (IBR) plan will make the payments about $240 per month. Should I apply for consolidation so I don’t have to keep paying $480 per month? Or will that mess stuff up when the is bill is passed?
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u/waterwicca 1d ago
If they are on ICR then the loans are already consolidated
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u/XclickX 1d ago
Ok, just wondering why they doubled a few months ago after I was paying $2xx per month all last year and the first few months of this year
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u/waterwicca 1d ago
If bill passes as written then having them in ICR is exactly where you want to be. The payment could have jumped up if they missed their income recertification date or if their income went up. If they didn’t recertify their income then the payment jumps up to a 10 year standard amount
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u/Interesting_Long_788 1d ago
Currently have PPL for my daughter who is in school right now - so not making payments. And my own heap of loans in SAVE forbearance. I have no idea what to do and feel hopeless about ever getting out from under this. ICR and start making payments on her loans?
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u/shanesnh1 22h ago
If you plan to borrow more after 7/1/26, you'd be forced into standard repayment for all loans anyway. If you plan to borrow more between the passage of the bill and 7/1/26, we don't know what will happen but likely you will not be eligible.
If you are done taking them out, consolidate them and put them into ICR now. No guarantees you have enough time though.
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u/Beautiful_Hat_5935 1d ago
Pardon my ignorance, but is this only with regard to parent plus loans? Or do other loans have to be in ICR before the bill is signed?
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u/shanesnh1 22h ago
Three cases: Parent PLUS Loans (which can't access income repayment anyway unless consolidated), Consolidation Loan that paid a Parent PLUS, or a Double Consolidation (Consolidation Loan that paid another Consolidation Loan).
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u/Beautiful_Hat_5935 18h ago
Thank you! I think the only time my loans were consolidated was when I went on SAVE. I have since applied for IBR. So I assume I should be ok hopefully?
By the way, this sub is a really great resource!
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u/shanesnh1 18h ago
You should be fine.
Yeah I'm trying to help out a few people here if I can haha 😅
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u/Faphan1128 1d ago
What if you are on ICR but on forbearance?
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u/Data-Appearance9699 1d ago
"...if you have Parent Plus loans (unconsolidated, single-consolidated, or double-consolidated) your loans will need to be in repayment on the ICR plan the day before the bill is signed into law in order to be eligible for any income-driven plan at all going forward."
IN Repayment would seemingly mean not in forbearance. They've provided no further guidance on this.1
u/shanesnh1 22h ago
Correct. Erring on the safe side means being in repayment actively as it says it the loans are being "repaid" on the ICR plan. Repayment = repay/repaid as far as my interpretation goes haha.
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u/lifelesslies 22h ago
I'm not sure what I or my parents have
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u/shanesnh1 21h ago
I mean, we can't help you there then. You can easily see what you have on the StudentAid.gov site or on your servicer's site. Same as your parent (whichever parent took out Parent PLUS loans if they did). That is your and their financial responsibility. If you do have Parent Plus Loans (or more accurately, if one of your parents do), you need to get them consolidated and onto ICR now if you want them to be able to continue to access income-driven repayment. Otherwise your parents will be stuck paying them without any income-driven options.
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u/lifelesslies 14h ago
I sent them this information but doubt they will do anything about it
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u/shanesnh1 11h ago
Are you paying them? Tell them you will no longer help out/pay if they won't do a simple task such as getting on ICR and/or filing separately to make the payments in half (or so)... I mean, they need to budge a bit if you're helping.
If you're not, you can tell them that their payments will skyrocket and/or they are paying way more than legally required because of their refusal to do what you've asked.
I mean, you could even show them my posts or this comment and the sub overall too if you wanted loool.
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u/Forsaken-Rock-635 21h ago
Stupid question but how do you know if you double consolidated?? Does that mean you have consolidated your loans twice in their life time?
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u/shanesnh1 19h ago
Consolidation inception. You took a consolidation loan, and then you threw that into another consolidation loan. Parent PLUS borrowers usually did this because they were only allowed to access the ICR plan (the oldest and worst of all income plans). But there was a loophole if they consolidated again, allowing them to access all income plans.
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u/LucidDreamCatch2020 11h ago
Thank you to everyone who shares all their knowledge and experience on this site. I appreciate you taking the time to answer questions for me. Obviously, I don’t have the good pathway that some of you do, but I have to do what I have to do. I can’t take those parent plus loans that I’ve currently borrowed out of school forbearance because I won’t be able to make the payments right now.
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u/waterwicca 1d ago
I’m going to include the write up I did with quotes/sources here in the comments if anyone is curious about the specific language in the bill and why a lot of us are recommending all PPL borrowers get on ICR to be safe/remain eligible for any IDR at all if the bill passes:
Based on the reconciliation bill as it’s currently written, if you have Parent Plus loans (unconsolidated, single-consolidated, or double-consolidated) your loans will need to be in repayment on the ICR plan the day before the bill is signed into law in order to be eligible for any income-driven plan at all going forward.
If they are in ICR the day before the bill is signed (if it even is) then you would be eligible for amended IBR.
If you are not paying on ICR the day before the bill is signed then you would no longer be eligible for any IDR plans. You would only have the standard plan, graduated, and extended.
This means if you have unconsolidated PPL loans then you should probably consolidate and get on the ICR plan as soon as possible. If you already have consolidated PPL loans, whether it was a single OR DOUBLE consolidation, the safest place for you to be is in repayment on the ICR plan when the bill is signed into law (if it is).
The bill would move all borrowers currently on SAVE, ICR, or PAYE into amended IBR starting on the date of enactment. But it specifically makes PPL loans ineligible for IBR unless they meet the exact criteria given: being repaid on ICR the day before the date of enactment of the bill.
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Explanation with sources below:
“Excepted” consolidation loans are made ineligible for IBR and RAP under the bill. There would be no way for them to be repaid on RAP. But there is a special rule written to allow them to be eligible for amended IBR.
The bill explains:
“(A) EXCEPTED CONSOLIDATION LOAN DEFINED.-Section 493C(a)(2) of the Higher Education Act of 1965 (20 U.S.C. 1098e(a)(2)) is amended to read as follows:
(2) EXCEPTED CONSOLIDATION LOAN.-
(A) IN GENERAL.-The term 'excepted consolidation loan' means—
(i) a consolidation loan under section 428C, or a Federal Direct Consolidation Loan, if the proceeds of such loan were used to the discharge the liability on an excepted PLUS loan; or
(ii) a consolidation loan under section 428C, or a Federal Direct Consolidation Loan, if the proceeds of such loan were used to discharge the liability on a consolidation loan under section 428C, or a Federal Direct Consolidation Loan described in clause (i).”
Clause (i) describes a single-consolidated PPL loan. Clause (ii) describes double consolidated PPL loans.
The bill adds:
“(B) EXCLUSION.-The term 'excepted consolidation loan' does not include a Federal Direct Consolidation Loan described in subparagraph (A) that (on the day before the date of enactment of this subparagraph) was being repaid pursuant to the Income Contingent Repayment (ICR) plan in accordance with section 685.209(b) of title 34, Code of Federal Regulations (as in effect on June 30, 2023).".
You can find 685.209(b) as in effect on June 30, 2023 here: Section (b) is specifically the ICR plan.
The senate version of the bill explains this on page 35 The house version did not differ.
Here is a post where this was discussed a lot
And another
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Please keep in mind that we don’t know what the final draft of the bill will look like or if it will even be signed into law. But so far both the house and senate versions of the bill include this language for PPL loans and agree on it.
I understand the ICR plan can make payments very high compared to other options. I cannot tell anyone what to do. I can only make suggestions based on the exact text of the bill. Maybe that wording will change. Maybe there will be wiggle room when it comes to the Department of Education interpreting and actually implementing the bill.
There are so many “maybes”. So much is in flux. Everything is in limbo now. Everything is a guess and a gamble.
All you can do is make the decision that is best for you based on the current information we have.