Department of Education Revises Income-Driven Repayment Request Form Following Court Injunction
The U.S. Department of Education (ED) has announced proposed revisions to the Income-Driven Repayment (IDR) Plan Request Form—a key document used by federal student loan borrowers to enroll in or manage their income-driven repayment plans. This update is being issued in response to a federal court injunction that blocked the implementation of the Final Rule tied to the new Saving on a Valuable Education (SAVE) Plan and other IDR provisions.
What You Need to Know
The revision affects the Information Collection Request (ICR) under OMB Control Number 1845-0102, which governs how borrowers apply for or recertify IDR plans under the William D. Ford Federal Direct Loan and Federal Family Education Loan (FFEL) programs.
Here’s what’s changing:
Removal of SAVE Plan Option: Due to a court injunction issued on February 18, 2025, the Department is removing all references to the SAVE Plan from the form. This follows litigation that not only paused new provisions under the SAVE Plan but also halted components that had already been implemented under the broader IDR Final Rule, effective July 1, 2024.
Reinstatement of Prior Definitions: The form will revert to pre-July 1, 2024 definitions, including:
The original definition of family size
Elimination of interest subsidies that were introduced as part of the now-enjoined Final Rule
User Experience Enhancements: ED has made formatting and clarity improvements to ensure the form is user-friendly and reflective of current legal guidance.
Why This Matters
Institutions and servicers working with borrowers need to be aware that any forms or systems referencing the SAVE Plan or related 2024 rule changes will need to be updated. Borrowers will no longer be able to enroll in SAVE, and all income documentation and family size certifications must align with earlier IDR plan criteria.
These changes have a direct impact on the counseling and support institutions provide borrowers navigating repayment. Clear communication will be key to minimizing confusion and ensuring borrowers remain in good standing.
Public Comment Period Open Until July 30, 2025
Stakeholders—including financial aid administrators, servicers, and borrowers—are encouraged to submit comments on this revised information collection by July 30, 2025. Comments may address:
The necessity and clarity of the form
Accuracy of burden estimates
Suggestions for reducing respondent burden
To comment, visit www.reginfo.gov, select “Department of Education” under Currently Under Review, and check the “Only Show ICR for Public Comment” box.
Additional Context
This revision reflects broader legal and regulatory developments tied to student loan repayment policy. The SAVE Plan, intended to simplify and reduce monthly payments for millions of borrowers, was halted by legal challenges that culminated in the February 2025 injunction. Until the courts issue further guidance or a new rulemaking process begins, borrowers and institutions must adhere to the pre-2024 IDR framework.
Final Thoughts
For institutions that support borrowers through the repayment process, it's essential to ensure that staff are up to date on these regulatory shifts. Form templates, FAQs, and digital platforms should be reviewed to reflect the current legal status of IDR options.
