Partial Financial Hardship: What to Know About Recent Changes

Student loan borrowers no longer have to show partial financial hardship to enroll in the Income-Based Repayment plan.

Shannon Bradley
Julie Myhre-Nunes
Updated
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Partial financial hardship (PFH) is a measurement the Education Department (ED) has used in the past to determine whether a student loan borrower could enroll in certain income-driven repayment (IDR) plans — specifically the Income-Based Repayment (IBR) and Pay As You Earn (PAYE) plans.
If your monthly student loan bill under the standard repayment plan would be more than under IBR or PAYE, then you would have PFH and qualify for IBR or PAYE, providing you meet other eligibility requirements.
But the passage of the One Big Beautiful Bill Act (OBBBA) in July 2025 officially eliminated the PFH requirement for IBR. It also prompted the ED to propose eliminating PFH across all IDR plans.

PFH removal from IBR applications faced roadblocks

While the OBBBA’s passage meant the PFH restriction should be removed from the IBR application immediately, that didn’t happen. An inability of the ED and loan servicers to update their systems quickly resulted in delays, as well as legal action by the American Federation of Teachers (AFT).
The PFH requirement was finally removed from the IBR application on December 22, 2025. During this delay, loan servicers were instructed to hold IBR applications that would otherwise be denied due to lack of PFH, and to process them after systems were updated. But during this time, some IBR applications were denied for not meeting the PFH requirement. Here’s what this means for borrowers:
  • Borrowers who could not previously enroll in the IBR plan, because they earn too much to meet the PFH test, can now enroll. They can also see IBR as an option when using the ED’s loan simulator.
  • Loan servicers have begun processing IBR applications that were on hold, but the backlog created is causing some delays.
  • Borrowers who applied for IBR on or after July 4, 2025, and were denied due to lack of PFH, should reapply according to the ED.

Other PFH changes are in progress

The ED has proposed removing the PFH requirement from all income-driven repayment plans. A Notice of Proposed Rulemaking (NPRM) is currently posted and open for public comment through March 2, 2026 .
If the proposal is finalized, borrowers would no longer need to demonstrate PFH to qualify for any IDR plan. Instead, monthly payments would be set using an income-based calculation called the applicable amount.

Status of IDR Plans

Federal income-driven repayment (IDR) plans are in a major transition period. Here are key details to know:
  • Income-Based Repayment (IBR). Will remain an option for loans disbursed before July 1, but not if new loans are taken out after that time. No longer requires partial financial hardship.
  • Pay As You Earn (PAYE) and Income-Contingent Repayment (ICR). Available only for loans made before July 1, 2026, although enrollment is open until July 1, 2027. To be eliminated by July 1, 2028.
  • Saving on a Valuable Education (SAVE). Based on a proposed settlement agreement, SAVE is expected to end in early 2026, requiring borrowers to switch to a new IDR plan.
  • Repayment Assistance Plan (RAP). A new income-based plan set to roll out by July 1, 2026. RAP and the standard repayment plan will be the only options for loans taken out after July 1, 2026.

What will replace the PFH requirement?

Instead of using PFH as a gatekeeping test for enrollment into income-driven repayment, the ED proposes basing repayment on something called the applicable amount.
The applicable amount would be an actual payment calculation. In general, it would be based on how much a borrower’s adjusted gross income is above a certain percentage of the federal poverty guideline. A set percentage of income above that threshold would determine the borrower’s payment. Instead of asking whether a borrower qualifies due to hardship, loan servicers would simply calculate the borrower’s payment using the applicable amount formula, based on income and family size.

Partial financial hardship calculator

It’s likely that PFH will be eliminated for all IDR plans, but PFH changes are still in progress. In the interim, we are continuing to provide our partial financial hardship calculator for those who may need it.
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