PSLF Buyback Does Not Cover RAP Months. Here Is What Your Client Loses.
PSLF buyback lets a borrower pay for months that did not count and turn them into qualifying payments. It does not work for months spent in the Repayment Assistance Plan. If a client sits in a deferment or forbearance while enrolled in RAP, those months do not count toward PSLF, and they cannot be purchased back later at any price. The carve-out appears twice in the regulation, and it is easy to miss at exactly the moment it matters, which is when you are moving a public-service client onto RAP.
What is PSLF buyback?
PSLF buyback is the Department of Education process for converting months you spent in an ineligible deferment or forbearance into qualifying PSLF payments, by paying roughly what you would have paid under an income-driven plan at the time. It is a recovery mechanism, not a planning tool, and it opens only after a borrower already has 120 months of certified qualifying employment.
Federal Student Aid is explicit that the option is available only to borrowers who already have 120 months of qualifying employment under PSLF or Temporary Expanded PSLF. The Department’s stated reason is to stop borrowers from buying months they would never have needed. Requests go through the PSLF Reconsideration flow, and an approved borrower receives a buyback agreement with a fixed amount that must reach the servicer within 90 days or the agreement is void.
Why can a client on RAP not buy back a forbearance month?
Because the regulation excludes RAP from both routes to credit, the automatic one and the paid one. A month of deferment or forbearance on RAP is not credited by default, and it is not purchasable afterward. Nothing recovers it.
The first route is 34 CFR 685.219(c)(2)(v), which credits a specific list of deferments and forbearances as qualifying months, including cancer treatment, economic hardship, military service, post-active-duty student, AmeriCorps, National Guard duty, the Department of Defense Student Loan Repayment Program, and administrative forbearance. That list opens with an exception for periods when the borrower is enrolled in the Repayment Assistance Plan.
The second route is 34 CFR 685.219(e)(6), the buyback provision, which lets a borrower obtain credit for other deferment and forbearance months by making an additional payment equal to or greater than what they would have paid on a qualifying repayment plan. That paragraph opens with its own exception for repayment periods when the borrower is repaying under the Repayment Assistance Plan.
Federal Student Aid states the same rule in plain language on its buyback page, listing enrollment in RAP among the conditions that make a borrower ineligible, and separately listing months in repayment under RAP among the months that cannot be bought back. The Tiered Standard Plan carries an identical exclusion. To be clear about what is not affected, RAP itself remains a qualifying repayment plan for PSLF under 34 CFR 685.219(b)(28)(v), so ordinary on-time RAP payments still count. The loss is confined to months when payments are postponed.
What does a bought-back month actually cost?
The price is set by what the borrower would have paid under an income-driven plan during the months being bought, using the income and family size from that period rather than today’s. If the borrower was on an IDR plan immediately before or after a gap shorter than a year, the Department uses the lower of the two monthly amounts. If there is no adjacent IDR enrollment, it requests tax information for those years. Where the 10-year Standard payment is lower than the calculated IDR figure, the Standard amount is used instead, and if the requested tax and family size information does not arrive within 30 days, the Standard amount is used by default.
So the practical question for an advisor is what the client’s IDR payment looked like back then. Here is that figure across a range of public-service incomes.
| Annual AGI | Standard (10-year) | RAP | IBR |
|---|---|---|---|
| $55,000 | $1,079 | $229 | $259 |
| $70,000 | $1,079 | $350 | $384 |
| $85,000 | $1,079 | $567 | $509 |
Scenario: $95,000 Direct Unsubsidized at 6.5%, single filer, no dependents, pursuing PSLF. Computed on August 10, 2026 with the Finology Software parity-verified engine. Every plan row returned parityVerified: true. PAYE and ICR were returned as excluded, both closed to new enrollment for this loan type as of that date.
Read it as a price list. A client who was on IBR at $70,000 of AGI and spent twelve months in an ineligible forbearance is looking at roughly $4,608 to recover those months, which is twelve times the $384 monthly figure above. Expensive, but recoverable, and it buys twelve months off the end of a PSLF timeline.
The same twelve months on RAP cost nothing to buy back, because there is no purchase available. The client simply works twelve more months. Notice also that the ranking flips: RAP is the cheaper monthly payment at $55,000 and $70,000, but at $85,000 IBR comes in lower. Advisors who default clients to RAP on the strength of the monthly number alone can end up with the higher payment and the weaker forbearance protection at the same time.
Which clients should you check before enrolling them in RAP?
Any PSLF-track client whose income is volatile enough that a hardship deferment or forbearance is plausible in the next few years. For those clients the forbearance treatment is a real cost of the plan, and it belongs in the comparison next to the monthly payment.
Four groups worth a second look:
- Clients approaching 120 certified months who still have gaps in their payment count, since buyback is their cleanest fix and RAP would close that door for any new gaps.
- Residents, fellows, and early-career public servants with predictable low-income stretches ahead.
- Military and National Guard clients, whose service-related deferments are credited automatically on other plans and are not credited on RAP.
- Anyone you moved off SAVE in the past year who landed on RAP by default rather than by choice.
For the eligibility mechanics of RAP alongside PSLF more generally, see our guide to RAP and PSLF. To run a client’s numbers across the open plans, use the RAP payment calculator.
What are the full buyback eligibility rules?
A borrower must have a Direct Loan with a positive principal or interest balance, at least 120 months of certified qualifying employment with no further employment left to certify, and certified employment covering the specific months being bought. Months in school, in origination, in grace, in default, in bankruptcy, or under total and permanent disability monitoring cannot be bought. Neither can months on loans that are paid in full, forgiven, discharged, or folded into a consolidation loan.
Two details that catch people. After consolidating, a borrower can only buy back months on the current consolidation loan, and nothing before its first disbursement date. And the earliest month available to anyone is October 2007, when PSLF was created.
Frequently asked questions
Can a borrower on RAP buy back months of forbearance for PSLF?
No. Federal Student Aid lists enrollment in the Repayment Assistance Plan as a disqualifying condition for PSLF buyback, and 34 CFR 685.219(e)(6) excludes repayment periods under RAP from the buyback provision. The same exclusion applies to the Tiered Standard Plan.
Do regular RAP payments still count toward PSLF?
Yes. RAP is a qualifying repayment plan for PSLF under 34 CFR 685.219(b)(28)(v). Ordinary monthly payments made on time under RAP count as qualifying payments. Only postponed months, meaning deferment and forbearance, are affected by the exclusion.
How much does PSLF buyback cost?
The amount equals what the borrower would have paid under an income-driven plan during the months being bought, based on the income and family size from that period. If the 10-year Standard payment is lower than the calculated IDR amount, the Standard amount is used. If a calculated buyback amount comes to $0, Federal Student Aid proceeds with forgiveness and no payment is required.
Is a balance forgiven through PSLF buyback taxable?
Federal Student Aid states that amounts forgiven under PSLF or TEPSLF are not treated as income for federal tax purposes, citing the IRS. State treatment is a separate question and should be checked against the client’s state of residence.
Sources
- 34 CFR 685.219, Public Service Loan Forgiveness Program, paragraphs (b)(28)(v), (c)(2)(v), and (e)(6), read on the eCFR current text.
- Federal Student Aid, Public Service Loan Forgiveness (PSLF) Buyback, studentaid.gov.
- Payment figures computed August 10, 2026 with the Finology Software parity-verified engine.
- Does Changing Jobs Reset PSLF Progress?
- Did the New PSLF Employer Rule Take Effect? What Advisors Need to Know
- The Numbers an Advisor Can Stand Behind: RAP, the New Standard, and PSLF, Done Right
- Do Student Loans Affect Buying a House? How Lenders Count Your Payment in 2026
- PSLF Guide: Public Service Loan Forgiveness in 2026
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