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The U.S. Department of Education has paused student loan forgiveness under the Income-Based Repayment plan (IBR), a decision that has stirred uncertainty among borrowers. The IBR plan is unique among income-driven repayment options as it faces no legal obstructions like its contemporaries. While the SAVE, ICR, and PAYE plans are embroiled in legal disputes that block their operation, IBR's underpinning statute, approved by Congress, specifically permits loan forgiveness after a repayment term ends.
The suspension is supposedly linked to system updates needed to count qualifying months not encompassed by court injunctions aimed at other plans. This update ties back to a court decision expanding its injunction on SAVE, potentially affecting IBR indirectly. Despite the absence of a court order to stop IBR discharges, loan forgiveness under the plan is halted, causing concern among eligible borrowers who have reached the necessary threshold but find themselves without discharge.
Some former officials have accused previous administrations of unlawfully blocking IBR debt relief, with suggestions that technical delays in updating loan forgiveness payment counts could be a contributing factor. At a broader level, the federal student loan system is in the midst of upheaval, with a substantial backlog of over 1.5 million income-driven repayment plan applications. The backlog's creation has been partially attributed to complying with regulations related to the halted SAVE plan.
In the face of these challenges, the Department of Education is encouraging borrowers on stalled or legally contentious plans to switch to IBR to progress toward discharge, as IBR was legislated by Congress, ensuring it remains a viable option.
Further complications arise as recent legislative changes introduce a new program, the Repayment Assistance Plan (RAP), which alters how rapidly borrowers might expect discharge, extending the duration before forgiveness eligibility under RAP compared to current conditions. However, IBR remains an option for current borrowers, although new challenges might arise as policy and court decisions evolve.
Borrowers stuck in limbo without loan forgiveness under IBR due to the suspension have limited options: they may continue payments in anticipation of later discharge and refund of any excess payments or request a forbearance, during which interest would accrue unless otherwise specified.
The Department of Education has not detailed the duration of this suspension, creating a continuing cloud of uncertainty. As student loan repayment procedures adapt to legislative, administrative, and legal adjustments, the tension between established statutes and evolving policy persists, underscoring the complexities borrowers face in navigating federal student loan forgiveness options.

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