Democrats Demand Answers from ED on the End of SAVE 

What Borrowers Actually Need to Know

On January 22, fifteen Democratic senators sent a letter to the Department of Education demanding answers to fourteen questions related to the termination of the SAVE repayment plan. Some of these questions already have partial answers, some highlight legitimate operational concerns, and others are more political statements than requests for new information.

Below, we break down each question, separate what matters from what doesn’t, and explain what borrowers should realistically expect as SAVE winds down.

1. How long will borrowers be given to switch into another income-driven repayment plan?

This is one of the most important unanswered questions for borrowers. As of now, ED has not announced a formal transition window. That guidance will likely come once the Department finalizes the rollout timeline for the new Repayment Assistance Plan (RAP).

2. What information will ED provide about higher costs under alternative plans, and what options exist for borrowers who can’t afford higher payments?

This reads more like a statement than a question. ED’s online IDR application already includes a calculator that shows estimated payments across available plans. While some borrowers will see higher payments, others may see lower ones. RAP — like all IDR plans — is designed to preserve affordability, with monthly payments potentially as low as $10.

3. By what date will ED and servicers contact SAVE borrowers with concrete next steps?

A fair and necessary question. Realistically, this communication will occur once ED announces a go-live date for RAP and finalizes transition rules. Until then, specific guidance is unlikely.

4. Will borrowers be allowed to switch plans using current income data, or will recertification be required?

This is the biggest question our team wants answers to. ED has not yet clarified whether borrowers exiting SAVE will be able to rely on existing income documentation or must recertify. If you chose to exit SAVE proactively, and many have, an income certification will be required. If you ride out SAVE until the bitter end, you may get by with old income data which could lead to lower payments.

5. What were the factual, legal, and financial rationales for ending SAVE?

This question has largely already been addressed through litigation. The legal justification for terminating SAVE has been debated extensively in the courts, and ED’s position is now largely constrained by those rulings.

6. Why propose a settlement now if SAVE is statutorily terminated in July 2028?

From a practical standpoint, the courts have already effectively ended SAVE. The July 1, 2028 date in the OBBBA appears to function as a hard stop for several repayment plans (ICR, PAYE, and SAVE), not a guarantee they would survive until then. The actual end date for SAVE will ultimately be determined by the courts in coordination with ED. We never expected SAVE to last through 2026, let alone 2028.

7. When will the new Repayment Assistance Plan take effect?

No later than July 1, 2026 — though it could be implemented sooner if ED finalizes infrastructure and guidance ahead of schedule.

8. Why did ED rescind other borrower-friendly provisions tied to SAVE?

Several positive changes — such as expanded access to IDR for borrowers in default and protections for pre-consolidation payment credit — were bundled into the same “New Rule” that created SAVE. The 8th Circuit Court of Appeals struck down the rule in its entirety, requiring all associated provisions to be reversed… for now. Some helpful changes were lost due to how the rule was structured, not because they lacked merit.

9. Will ED release internal analyses showing how much borrowers’ payments will increase?

This question highlights the core ideological divide in student loan policy. Republicans emphasize government and taxpayer savings; Democrats emphasize increased borrower burden. Both perspectives frame the issue differently, and ED is unlikely to release internal projections that fully satisfy either side.

10. How will ED ensure borrowers aren’t blindsided by higher payments?

While borrowers know major changes are coming by July 1, ED has shown a willingness to move quickly once decisions are finalized. If the transition window is short, some borrowers may feel caught off guard. Staying engaged with servicer communications will matter. Of course we’ll do our best to keep everyone informed as well.

11. What is the timeline for negotiated rulemaking?

As part of the December 9 settlement, ED committed to negotiated rulemaking to finalize SAVE transition details and gather stakeholder input. No dates have been announced yet.

12. How long will servicers take to process applications? And will they lose forgiveness credit due ot processing delays?

a. With over 800,000 unprocessed IDR applications reported in December 2025, ED must address backlog risks to avoid delinquency reporting or lost IDR/PSLF credit. This concern is valid.

b. Officially, up to 60 days of processing time can count toward forgiveness credit. Historically, ED has provided relief when servicer delays harm borrowers, though no guarantees have been issued yet.

13. What happens if borrowers don’t choose a new plan in time?

Key sub-questions include whether borrowers will be automatically placed into another plan, which plan that would be, whether they’ll have time to switch before billing, and whether ED will honor language in prior IDR applications requesting placement into the lowest-payment option.

We assume all of these details will be answered when ED rolls out the formal transition plan.

Final Thoughts

Historically, once ED releases final guidance, it has been clear about what borrowers need to do and what happens if they do nothing. While timelines may feel compressed, borrowers are unlikely to be left without instructions. The most important information will arrive with ED’s official transition guidance — and that’s when borrowers should pay the closest attention.