Income Driven Repayment Certification Rules and Dates 

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Jan 18, 2024

Since the dawn of time (or so it seems), borrowers have struggled to sift through confusing servicer letters and account details to determine when exactly they must recertify their income for their Income Driven Repayment (IDR) plans. Add the recent payment and interest pause from the CARES Act and its “6-to-12-month rule”, and you’ll probably have an easier time learning another language than figuring this stuff out on your own! Fear not because we’re here to translate servicer letters into plain English. Below is everything you need to know about the IDR renewal process.

Why Recertify?

IDR plans adjust annually on your enrollment date. Your payment amount continually reflects your income and is usually based on the adjusted gross income (AGI) from your most recent tax returns. Otherwise, if there has been a significant change in income since those returns were filed, the payment amount will be based off that more recent economic data. And effective July 1st, 2023, borrowers can now elect to have their payment amount automatically recertified each year.

When is my recertification due?

Your loan servicer will start sending notices up to 90 days prior to your anniversary date. It is important to note that your anniversary date and the deadline to submit recertification are two different things. Depending on what verbiage is used by the servicers, it can be difficult to decipher their communications. And different servicers use different wording on their sites!

To break it down, your anniversary date is the date your payment changes to the new amount. Your IDR recertification date is the last date you will make your current payment amount. You need to do your recertification paperwork after your 10th payment on your current cycle of payments and before your 11th payment. For example, if your anniversary date is April 1, your 12th payment is due in March, your 11th is in February, and your 10th payment is in January. Therefore, you would want to complete and submit your recertification paperwork between January and February.

How do I find my recertification date?

Your anniversary date is on your National Student Loan Data System (NSLDS) file. To find it:

  • Log into studentaid.gov.
  • Click the arrow in the top right corner next to your name.
  • Click My Aid, and on the following page click on download my aid data.

The anniversary date shown is the date your payment will change, so 30 days prior is the last date of your current repayment amount (or 12th payment on that cycle).

If your servicer is MOHELA:

  1. Log into mohela.com.
  2. Click on Repayment Options in the blue bar at top.
  3. Click Income Driven Details.

The date shown is your 12th payment.

If your servicer is not MOHELA, you can log into your servicer’s website and click on loan details. This will show the details of your IDR plan and will state when it’s set to expire. The expiration date shown is the date your payment will change, so 30 days prior to that date is the last date of your current payment amount.

What is the 6-to-12-month rule?

The unprecedented payment pause due to the CARES Act threw a major wrench in the recertification process and timeline, especially after the extensions started happening. A temporary rule was put into place in 2020 to provide guidance when the pause ended on IDR recertifications. That time finally came on August 30th, 2023, and the rule went into effect. Simply put, the rule states that anyone with an IDR anniversary date (DD/MM) falling within six months of the end of the payment pause would have their recertification pushed out 12 months. If your anniversary date is more than six months after the end of the pause, the existing date (from before the pause) remains unchanged.

Why the confusion?

As we stated above, borrowers have often confused their anniversary dates and recertification dates, and just about everyone in the industry uses the terms interchangeably. And for borrowers with anniversary dates right around that six-month threshold (February, March, or April of 2024), 90-day recertification notices started going out in December 2023. Therefore, some who thought they had another year to recertify are just now learning they do not. And some who thought they had to recertify soon are learning they have another year. Refer to the rules above to see which group you’re in.

Keep in mind servicers are showing incorrect dates, amounts, and payment plans on some borrowers’ accounts. Therefore, if your renewal notices don’t seem correct based on everything we explained above, you may want to contact them.

We hope this helps you interpret your notices from your servicers! As always, if you need assistance breaking down your recertification timeline, or have any other questions regarding your student loans, our team of expert advisors are standing by to assist with a comprehensive student loan consultation.

Brandon Barfield

Brandon Barfield

Brandon Barfield is the President and Co-Founder of Student Loan Professor, and is nationally known as student loan expert for graduate health professions. Since 2011, Brandon has given hundreds of loan repayment presentations for schools, hospitals, and medical conferences across the country. With his diverse background in financial aid, financial planning and student loan advisory, Brandon has a broad understanding of the intricacies surrounding student loans, loan repayment strategies, and how they should be considered when graduates make other financial decisions.

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