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(GEN-16-18) (GEN-16-18) Subject: Revision of the Income-Driven Repayment Plan Request Form for the Direct Loan and FFEL Programs

Publication Date: October 11, 2016

DCL ID: GEN-16-18

Subject: Revision of the Income-Driven Repayment Plan Request Form for the Direct Loan and FFEL Programs

Summary: This letter announces the approval of changes to the Income-Driven Repayment Request form (IDR Request) for the Direct Loan and FFEL programs.

Dear Colleague:

The Office of Management and Budget (OMB) has approved changes to the IDR Request form OMB Control Number 1845-0102. There is no change to the form’s current expiration date of October 31, 2018. The revised version of the IDR Request form is for use by borrowers who have received loans under the William D. Ford Federal Direct Loan (Direct Loan) Program and the Federal Family Education Loan (FFEL) Program, and covers the following repayment plans:

  • Revised Pay As You Earn (REPAYE) Plan - Direct Loan borrowers only

  • Pay As You Earn (PAYE) Plan - Direct Loan borrowers only

  • Income-Contingent Repayment (ICR) Plan - Direct Loan borrowers only

  • Income-Based Repayment (IBR) Plan - Direct Loan and FFEL borrowers

The revised IDR Request is attached to this letter.

Changes to the IDR Request

Questions for married borrowers

The questions for married borrowers in Section 4 have been revised to allow individuals who most recently filed a joint federal income tax return with their spouse to indicate that they are separated from their spouse or cannot reasonably access their spouse's income information. If a married borrower indicates that this is the case, the borrower is required to provide alternative documentation of his or her individual income, which will be used to calculate the IDR plan monthly payment amount. The prior version of the IDR Request form allows married borrowers to indicate that they are separated or cannot reasonably access their spouse’s income information only if they most recently filed a separate tax return from their spouse.

Borrowers who wish to change from IBR to a different income-driven repayment plan

Under the terms and conditions of the IBR Plan, a borrower who wants to leave the IBR Plan must first be placed on the Standard Repayment Plan and then make at least one payment under the Standard Repayment Plan, or at least one payment under a reduced-payment forbearance, before changing to a different repayment plan. Section 6 of the IDR Request form has been revised to incorporate an automatic request for a one-month reduced-payment forbearance in the amount of the borrower’s current monthly IBR payment or $5, whichever is greater (unless the borrower requests a different amount or declines the reduced-payment forbearance), for any borrower currently repaying under IBR who is submitting the form for the purpose of changing to a different IDR plan. On the prior version of the form, a borrower repaying under IBR who wants to change to a different IDR plan must check a box to request a reduced-payment forbearance. Experience with the prior version of the form has shown that many borrowers overlook the check box, and as a result are required to make a monthly payment under the Standard Repayment Plan. This is a hardship for many borrowers, as the Standard Repayment Plan payment amount is generally much higher than the monthly payment amount required under the IBR Plan. Making the reduced-payment forbearance request automatic will facilitate the change to a different IDR plan for borrowers currently repaying under IBR.

Other changes

In addition to the changes explained above, we have revised language in various places throughout the form for greater clarity.

Use of the Revised IDR Request Form by Married FFEL Program Borrowers

Like the prior version of the IDR Request that it replaces, the attached revised IDR Request requires all married borrowers who filed separate federal income tax returns to provide documentation of their spouse's income (unless certain exceptions apply, as noted earlier in this letter). The reason for this requirement is to accommodate instances where the borrower is not eligible for his or her initial IDR plan choice but is eligible for the REPAYE Plan. Under the REPAYE plan, a spouse's income is included in the calculation of the borrower's REPAYE payment amount regardless of whether the borrower and spouse filed a joint federal income tax return or separate returns.

For FFEL Program borrowers, the IBR Plan is the only available IDR plan. If a married FFEL borrower who files a separate federal income tax return from his or her spouse does not comply with the instructions to submit documentation of spousal income, the FFEL lender or servicer may not require the borrower submit that documentation. This is because spousal income information is required for the IBR Plan only if a married borrower files a joint tax return.

Implementation and Transition to Revised Form

FFEL Program participants may begin distributing the attached OMB-approved form to borrowers immediately. Beginning January 1, 2017, only the revised version of the form that is attached to this letter may be provided to borrowers. However, the previous version of the form may continue to be accepted from borrowers and processed through January 31, 2017.

For loans that are held by the Department, the federal loan servicers will implement the updated IDR Request on October 30, 2016. Beginning on that date, only the revised version of the form will be made available to borrowers. However, the Department’s federal loan servicers will continue to accept the prior version of the form from borrowers through January 31, 2017. After January 31, 2017, federal loan servicers will reject prior versions of the form and will request that the borrower complete the updated IDR Request.

Printing Instructions

To improve accessibility for visually impaired borrowers, we are providing the form only in PDF format. Loan holders, servicers, and guaranty agencies are responsible for ensuring that the form they use is identical to the attached OMB-approved form. No changes may be made to the form except as expressly provided below.

The loan holder, servicer, or guaranty agency must print the form on white paper with black ink. The typeface, point size, and general presentation of the form may not be changed from the attached version. Loan holders and servicers may use any blank spaces at the top, bottom, or sides of the form for bar coding or other loan holder- or servicer-specific information. Also, loan holders and servicers may pre-populate their contact and submission information in the section of the form designed for that purpose.

Sincerely,

Jeff Baker, Director
Policy Liaison and Implementation
Federal Student Aid
U.S. Department of Education