PAYE and ICR end in 2028
Two income-driven plans terminate on 30 June 2028. IBR survives. What happens to your forgiveness clock in between is the part worth planning around.
What is closing and what is not
| Plan | Status now | After 30 June 2028 |
|---|---|---|
| RAP | Open to any Direct Loan borrower with eligible loans | Continues |
| IBR | Open, subject to the SAVE lockout below | Continues. The only surviving legacy plan. |
| PAYE | Closed to new enrolment. Continues only for borrowers already on it as of 1 July 2024. | Terminates |
| ICR | Closed to new enrolment, on the same condition | Terminates |
| SAVE / REPAYE | Vacated by court order. Not available. | Gone |
Under 34 CFR 685.209(c)(7), borrowers repaying under PAYE or ICR must elect RAP, IBR, or a fixed plan before 1 July 2028. Those who make no election are force-placed: into RAP for loans RAP can take, and into IBR for loans it cannot.
What happens to your forgiveness clock
This is the part that catches people. RAP does credit prior qualifying months, including PAYE and ICR payments made before 1 July 2028. But RAP requires 360 payments where PAYE required 240.
So a borrower fifteen years into a twenty-year PAYE clock, expecting forgiveness in five years, can find themselves credited with those months against a thirty-year requirement instead. Fifteen years of credit against 360 payments is not five years from the end. It is fifteen years from it.
Under 34 CFR 685.209(k)(4)(i)(A), PAYE, ICR and IBR credit a payment made under any income-driven plan except RAP. Under 34 CFR 685.209(k)(8)(i)(C)(4), IBR payments do count toward RAP's 360.
The credit runs one way. Time in IBR carries into RAP. Time in RAP does not carry into IBR. A borrower who spends six years in RAP and then moves to IBR starts IBR's clock at zero.
Months in RAP do still count toward PSLF's 120 either way, so this matters most to borrowers relying on income-driven forgiveness rather than public service forgiveness.
The SAVE to IBR lockout
Under 34 CFR 685.209(c)(3)(ii), a borrower who made 60 or more qualifying payments under REPAYE on or after 1 July 2024 may not enrol in IBR.
The effect is uncomfortable. Borrowers who paid most diligently under SAVE are the ones locked out of the only surviving legacy plan, leaving RAP and its thirty-year clock as their sole income-driven option. If this might apply to you, confirm your payment count with your servicer before assuming IBR is available.
What this has to do with refinancing
Uncertainty is uncomfortable, and refinancing offers the appearance of resolving it: a fixed rate, a fixed payment, a fixed end date, no more rule changes to track.
It is worth being clear about what that trade actually is. The federal system is changing and some of the changes are unwelcome. But it still contains an interest waiver, income-linked payments, statutory deferments, discharge on death and disability, and forgiveness at the end. Leaving it to escape the paperwork is trading a set of real protections for the feeling of certainty.
If the rule changes have genuinely made your federal position worse, the calculator will show that. Run the numbers rather than deciding on the mood.
Related: how RAP works,what happened to SAVE.
Common questions
Which income-driven plans are ending in 2028?
PAYE and ICR terminate on 30 June 2028 under 34 CFR 685.209(c)(7). Borrowers on them must elect another plan before 1 July 2028. Those who do not choose are placed into RAP for RAP-eligible loans and IBR for loans RAP cannot take.
Is IBR going away?
No. IBR survives past 2028 and is the only legacy income-driven plan that does. It remains open to new enrolment, with one exception: a borrower who made 60 or more qualifying REPAYE payments on or after 1 July 2024 may not enrol in IBR under 34 CFR 685.209(c)(3)(ii).
Will my payment count carry over when PAYE ends?
Partly. RAP credits prior qualifying months, including PAYE and ICR payments made before 1 July 2028, toward its 360. But RAP requires 360 payments where PAYE required 240, so a borrower moved from PAYE to RAP typically sees their forgiveness horizon extend substantially rather than continue unchanged.
Should I switch plans now or wait?
That depends on your numbers and this page cannot answer it for you. What is worth knowing before you decide is the asymmetry: months paid under RAP do not count toward IBR, PAYE or ICR forgiveness, while IBR months do count toward RAP. Moving into RAP is easier to do than to undo.