Temporary Expanded Public Service Loan Forgiveness (TEPSLF) is a big deal for a lot of borrowers, especially as they approach 120 eligible PSLF payments.

Here’s the problem we keep hearing about: borrowers log into StudentAid.gov, see their payment count hit 120, and assume forgiveness is coming. Then they get denied. What they didn’t realize is that some of their payments only count under TEPSLF, not regular PSLF, and TEPSLF has an extra requirement most people have never heard of: the final 12 payment rule.

If you spent years on a Graduated or Extended repayment plan before switching to an income-driven plan, this article is for you. Here’s how TEPSLF works, why your StudentAid.gov payment count can be misleading, and how to make sure the last 12 months of your payments don’t disqualify you.

What Is Temporary Expanded Public Service Loan Forgiveness (TEPSLF)?

Temporary Expanded Public Service Loan Forgiveness is a companion program to Public Service Loan Forgiveness (PSLF) that Congress created in 2018 for borrowers who did everything right for PSLF (right loans, right employer, 120 payments) except they were on the wrong repayment plan.

Regular PSLF only counts payments made under income-driven repayment plans (or the 10-Year Standard plan). TEPSLF expands that to include payments made under:

• The Graduated Repayment Plan
• The Extended Repayment Plan
• The Consolidation Standard Repayment Plan
• The Consolidation Graduated Repayment Plan

Everything else about PSLF still applies: you need Direct Loans, full-time employment with a qualifying employer (government or eligible nonprofit), and 120 payments made after October 1, 2007.

Here’s a quick infographic to help you understand the differences between PSLF, TEPSLF, and the special Biden PSLF Waiver:

Where Did Temporary Expanded PSLF Come From?

When the first PSLF borrowers became eligible for forgiveness in 2017, the results were ugly — only about 2% of applicants were approved. One of the biggest reasons for denial was being on the wrong repayment plan, often because a loan servicer steered the borrower into it.

Under pressure from Congress, lawmakers included $350 million for an expanded version of PSLF in the 2018 budget deal (the Consolidated Appropriations Act, 2018). Congress added another $350 million in the fiscal year 2019 appropriations, plus $50 million each in 2020 and 2021 — roughly $800 million total, available until expended.

That’s why it’s called “temporary”: the money is a fixed pot, awarded first-come, first-served. The Department of Education hasn’t announced that funds are exhausted, but there’s no public tracker of what’s left. If you think you qualify, don’t sit on it.

Why TEPSLF Is Suddenly Relevant Again

For a few years, TEPSLF faded into the background. The limited PSLF waiver (2021–2022) and the one-time IDR account adjustment retroactively fixed most “wrong plan” payment histories, so fewer borrowers needed it.

But in 2026, we’re seeing a new wave of borrowers crossing 120 total payments — many with stretches of Graduated or Extended plan payments in their history that only count through TEPSLF. At the same time, PSLF tracking moved from MOHELA to StudentAid.gov, where the payment tracker shows one combined count for PSLF and TEPSLF.

The result: borrowers see 120 payments in their dashboard, expect automatic forgiveness, and instead get a denial — usually because of the final 12 payment rule below.

The Final 12 Payment Rule (Read This Twice)

This is the requirement that’s catching people. To qualify for TEPSLF, the Department of Education checks the amount of two specific payments:

1. The payment you made 12 months before applying for TEPSLF, and
2. The last payment you made before applying

Both of these payments must be at least as much as you would have paid under an income-driven repayment plan at the time.

In practice, treat this as: your final 12 months of payments need to be at IDR levels. The Department checks those two bookend payments, but you generally can’t know in advance exactly which billing cycle will be evaluated as “12 months prior” — so the safe play is making sure every payment in your final year clears the IDR bar.

Why People Fail This Test

Graduated and Extended plans exist to lower your monthly payment. Early Graduated plan payments in particular can be far below what an IDR plan would charge. So the exact plans that make you TEPSLF-eligible are also the plans most likely to fail the 12-month test if you’re still on one when you apply.

How To Pass It

• Switch to an income-driven repayment plan for your final year. This is the cleanest solution. If you’re on IBR (or the new RAP plan, which launched July 1, 2026) for the last 12 months before you apply, you satisfy the rule automatically.
• Or verify your payment amounts. Ask your servicer what your calculated IDR payment would be, estimate it with Loan Simulator on StudentAid.gov, or use our student loan calculator. If your current payments are at or above that number, you’re fine. If they’re close, round up — a payment that’s even a dollar short can trigger a denial.
• Don’t apply the month you hit 120 if your recent payments were too low. A denial here isn’t permanent. You can keep working, make 12 months of IDR-level payments, and reapply — those extra payments count.

Why Your StudentAid.gov Count Is Confusing

Since PSLF servicing moved from MOHELA to StudentAid.gov, your payment progress lives in the PSLF tracker in your StudentAid.gov dashboard. Two things about it confuse borrowers:

1. The count combines PSLF and TEPSLF. Because the PSLF form and TEPSLF request were merged into a single application years ago, the tracker doesn’t clearly separate “these months qualify for regular PSLF” from “these months only qualify if you meet TEPSLF’s extra requirements.” Months you spent on a Graduated or Extended plan can show up in your count — but they only actually pay off if you clear the final 12 payment rule and TEPSLF funding is still available.

2. “Eligible” is not “qualifying.” The tracker also distinguishes months where your loan and plan were eligible but your employment isn’t certified yet. Until you submit a PSLF form covering those months, they don’t count toward 120.

The practical takeaway: if any part of your repayment history was spent on a Graduated, Extended, or Consolidation Standard/Graduated plan, don’t treat “120” in the tracker as a finish line. Check what your last 12 months of payments look like first.

Who Is Eligible For TEPSLF?

To recap, you must meet all of these:

• Direct Loans only.
  FFEL loans, Perkins loans, and Parent PLUS loans don’t qualify. (Consolidating into a Direct Consolidation Loan can help going forward, but check how consolidation affects your payment count before you do it.)
• 120 qualifying payments made after October 1, 2007, each made no more than 15 days late, while employed full-time by a qualifying employer.
• Qualifying employment, certified via the PSLF form, including at the time you apply and when forgiveness is granted.
• The final 12 payment rule, covered above.

How To Apply For TEPSLF

There is no separate TEPSLF application anymore. You use the same form as PSLF — the Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application — ideally through the PSLF Help Tool at StudentAid.gov. If you’re working through the broader process, see our PSLF strategy guide.

When you’re denied PSLF solely because of your repayment plan, you’re automatically considered for TEPSLF. The servicer may follow up asking for income information to verify the 12-month payment test. (The old process of emailing a reconsideration request to FedLoan Servicing is long gone — if you see that advice anywhere, it’s outdated.)

Processing times vary, and the PSLF system has worked through repeated backlogs since the MOHELA transition. Expect months, not weeks, and keep certified copies of everything.

What About Taxes?

Forgiveness under PSLF and TEPSLF is not taxable income at the federal level. A small number of states treat forgiven debt differently, so check which states tax student loan forgiveness — but for most borrowers, the forgiven balance is tax-free.

What Else Is Going on with PSLF?

TEPSLF isn’t the only ting happening with student loans. A few 2026 developments matter for anyone in this situation:

• RAP launched July 1, 2026. The Repayment Assistance Plan, created by the One Big Beautiful Bill Act, is a new income-driven plan that qualifies for PSLF — and satisfies the TEPSLF 12-month test if you’re enrolled for your final year. Borrowers can now apply for RAP online at StudentAid.gov. Going forward, IBR and RAP are the qualifying IDR plans, with PAYE and ICR phasing out by 2028.
• The SAVE plan is gone. After the courts struck down SAVE, remaining enrollees are being moved to other plans in 2026. Time spent in the SAVE litigation forbearance didn’t count toward PSLF — which is pushing more borrowers to look at PSLF buyback and TEPSLF to fill gaps.
• The new employer eligibility rule was blocked in court. The Department finalized a rule in October 2025 allowing it to exclude employers found to have a “substantial illegal purpose,” but a federal judge vacated it on June 30, 2026 — hours before its effective date. The existing qualifying-employer definition remains in effect, though the Department could appeal.
• PSLF buyback is an alternative for some. If your issue is non-qualifying months (forbearance, deferment) rather than a non-qualifying plan, PSLF buyback — not TEPSLF — is likely your path.

TEPSLF FAQ

Is TEPSLF still available in 2026?

Yes. Congress appropriated roughly $800 million total, available until expended on a first-come, first-served basis. The Department of Education hasn’t announced that funding has run out, but it doesn’t publish a running balance either — so apply as soon as you’re eligible.

Do I need to file a separate TEPSLF application?

No. The PSLF and TEPSLF applications were combined into one form. If you’re denied PSLF because of your repayment plan, you’re automatically considered for TEPSLF.

StudentAid.gov shows I have 120 qualifying payments. Why haven’t my loans been forgiven?

A few possibilities. If some of your 120 months were on a Graduated, Extended, or Consolidation Standard/Graduated plan, those months only count through TEPSLF — which means you also have to pass the final 12 payment rule. Processing backlogs are another common reason. And if any months show as “eligible” rather than “qualifying,” you still need to certify employment for those periods.

What exactly is the final 12 payment rule?

The amount you paid 12 months before applying for TEPSLF, and the last payment you made before applying, must each be at least as much as you would have paid under an income-driven repayment plan. The simplest way to guarantee you pass: spend your final 12 months on an IDR plan.

How do I find out what my IDR payment amount would have been?

Ask your loan servicer directly, use Loan Simulator at StudentAid.gov, or estimate it with our student loan calculator. If you’re paying an amount close to the IDR figure, round up to be safe.

I was denied TEPSLF because my recent payments were too low. Am I out of options?

No. The denial isn’t permanent. Keep working for a qualifying employer, make the next 12 months of payments at or above your IDR amount (switching to an IDR plan is the easiest way), then reapply.

Do FFEL, Perkins, or Parent PLUS loans qualify for TEPSLF?

No. Only Direct Loans qualify. FFEL and Perkins borrowers can consolidate into a Direct Consolidation Loan to become eligible going forward, but talk through the payment-count implications first. Parent PLUS loans don’t qualify for TEPSLF even after consolidation.

Is TEPSLF forgiveness taxable?

Not federally. A few states may tax forgiven debt, so check your state’s treatment.

Should I use TEPSLF or PSLF buyback?

They solve different problems. TEPSLF fixes months where you paid on the wrong repayment plan. PSLF buyback fixes months where you made no qualifying payment at all — like time in forbearance or deferment. Some borrowers with SAVE forbearance gaps plus old Graduated/Extended plan history may need to think through both — here’s which payments and periods count toward PSLF and buyback.

How long does TEPSLF processing take?

Longer than it should. Since PSLF processing moved from MOHELA to the Department of Education, backlogs have been common — plan on several months and keep records of your form submissions.