Does Forbearance Count Towards PSLF: Exceptions and Buyback

Standard forbearance does not count toward Public Service Loan Forgiveness. PSLF requires 120 separate qualifying monthly payments made while you work full-time for an eligible employer, and months where your payments are simply paused under a general forbearance don’t satisfy that requirement.¹ Several specific forbearance types are exceptions, though, and other paths exist to recover credit for months that didn’t count the first time.

Why a Regular Forbearance Doesn’t Count

PSLF credit is built around active repayment. To earn one of the 120 qualifying payments, you generally have to be in a repayment status on a qualifying plan during a month when you also work full-time for an eligible employer. A general or discretionary forbearance — the kind you request because of temporary financial hardship — pauses your obligation entirely. No payment is due, so no payment can qualify.

Qualifying repayment plans are not limited to income-driven repayment. The 10-year Standard Repayment Plan qualifies, as does any plan where your monthly amount equals or exceeds the 10-year standard payment. In practice, though, 120 payments on the standard plan pay the loan off, leaving nothing to forgive. That’s why nearly every PSLF borrower uses an IDR plan.

Forbearance Periods That Do Count

Federal law and Department of Education policy treat certain forbearance types as qualifying time even without a payment. You still need to have been working full-time for an eligible employer during those months.

COVID-19 Administrative Forbearance

The CARES Act placed federally held student loans into an administrative forbearance starting March 13, 2020, with all required payments suspended and no interest accruing. Later extensions kept the pause in place through September 2023, with payments restarting in October 2023. Every month during that window counts as a qualifying PSLF payment as long as you were working full-time for an eligible employer at the time.² For many borrowers that’s up to 43 months of credit — more than a third of the 120 required.

Federally Declared Natural Disaster Forbearance

When your loan servicer places you in forbearance because of a federally declared natural disaster, those months count toward PSLF. The initial period runs up to 90 days, and 30-day extensions are available up to a total of 12 monthly billing cycles from the date of the disaster.³

Military Service Deferment or Forbearance

Active-duty service members whose loans were placed in deferment or forbearance during their service receive PSLF credit for those months. The Department of Education addressed this specifically after service members discovered that time on deployment hadn’t been counting toward forgiveness.⁴

Administrative Processing Forbearance

When your loans are transferred between servicers or held up in administrative processing — something many borrowers experienced during the 2022–2023 transition to MOHELA — the resulting forbearance can also count. These are months where you would have paid if the system had let you, and the Department has treated them as qualifying rather than penalizing borrowers for servicer-side delays.

The One-Time IDR Account Adjustment

The Department of Education completed a one-time account adjustment in the fall of 2024 that retroactively credited certain forbearance periods toward PSLF and IDR forgiveness. Updated payment counts began appearing on borrower accounts in January 2025.⁵ The adjustment targeted borrowers who had been steered into long-term forbearances instead of being placed on affordable repayment plans.

To qualify for retroactive forbearance credit under the adjustment, your loans needed to show either 12 or more consecutive months of forbearance or 36 or more cumulative months of forbearance, excluding the COVID-19 pause (which already counted separately). Where those thresholds were met, the forbearance months were treated as time in repayment for both IDR and PSLF.⁵ More than 3.6 million borrowers received at least three years of additional credit, and some saw their loans forgiven automatically.

Consolidation affected how the adjustment applied. A Direct Consolidation Loan was credited with the longest repayment history from the underlying loans; where repayment periods overlapped, the consolidation loan received credit for the longest single timeline, and where they did not overlap, total credited time could be larger because eligible periods from each underlying loan were counted.⁵

One deadline has already closed. Borrowers with FFEL Program loans had to apply to consolidate into Direct Loans by June 30, 2024, to benefit from the adjustment; the consolidation had to be disbursed before October 1, 2024.⁵ If you held FFEL loans and missed that window, the IDR adjustment path is closed, but the buyback below may still work.

PSLF Buyback for Months That Still Don’t Count

For forbearance or deferment months that don’t automatically count through any path above, the PSLF Buyback program lets you pay for those months retroactively so they convert into qualifying payments.⁶

Buyback is not open to everyone. You must already have 120 months of qualifying employment certified, and buying back the forbearance or deferment months must be what gets you to forgiveness. It’s designed for borrowers at the finish line, not those still years away from 120 payments.⁷

How Much Buyback Costs

The per-month cost depends on your repayment situation around the forbearance:

If you were on an IDR plan right before or after the forbearance, and the forbearance lasted less than a year, the Department uses the lower of your two IDR payment amounts from the months surrounding it.
If you were not on an IDR plan, the Department requests your tax information for the relevant years and calculates what you would have owed under the lowest available IDR plan. If the 10-year standard payment would have been lower, that amount is used instead.
If the calculated amount is $0, no payment is required and forgiveness proceeds.

You submit a buyback request through the PSLF Reconsideration portal, selecting “PSLF Buyback” as the type. The Department then sends a buyback agreement with the total amount owed, and you have 90 days from the date of that agreement to pay in full.⁶

The Employment Requirement Runs Through All of It

Every path above shares one condition: you must have been working full-time for a qualifying employer during the forbearance months you want to count. The forbearance type doesn’t matter if you weren’t employed at an eligible organization at the same time.

Full-time for PSLF means meeting your employer’s own definition of full-time or working at least 30 hours per week, whichever is greater. If you hold multiple part-time jobs at qualifying employers, you can combine them to reach the 30-hour threshold.⁸

How to Claim Credit for Forbearance Months

Getting the credit requires certified proof of your employment during the months in question. Use the PSLF Help Tool on StudentAid.gov to generate the Employment Certification Form, enter your employment dates precisely (the servicer cross-references them against the specific forbearance months), and either send a digital signature request to your employer through the tool or submit a signed paper copy to your servicer. Your loans are serviced by MOHELA for PSLF purposes, while the program is managed by the Department of Education.⁷ Processing takes several weeks to a few months. Keep copies of everything you submit.

If the Payment Count Looks Wrong

When your count comes back and forbearance months you believe should count are missing, request PSLF Reconsideration through StudentAid.gov. Supporting documents are not required with the request, and the form takes about five minutes. Include all disputed periods in a single request; filing multiple separate requests slows things down.⁹

If your loan status history itself is wrong — showing incorrect dates for forbearance or repayment — contact your current servicer. For consolidated loans, you may need to request the status history from the holder of the underlying loan and pass it to your current servicer. If the servicer can’t fix it, you can escalate by filing a complaint with the Department of Education.⁵

1
Federal Student Aid. If I Pay More Than My Scheduled Monthly Student Loan Payment Amount, Can I Get Public Service Loan Forgiveness (PSLF) Sooner Than 10 Years?
2
Senator Bernie Sanders’ Office. Student Debt Relief During COVID-19: What You Need to Know
3
Federal Student Aid. Natural Disasters: Info for Affected Individuals
4
VA News. Veterans, Active Duty Can Take Advantage of Public Service Loan Forgiveness Program
5
Federal Student Aid. Payment Count Adjustments Toward Income-Driven Repayment and Public Service Loan Forgiveness Programs
6
Federal Student Aid. Public Service Loan Forgiveness (PSLF) Buyback
7
MOHELA – Federal Student Aid. PSLF Information
8
Federal Student Aid. Requirement: Full-Time Employment
9
Federal Student Aid. PSLF Reconsideration