Student Loan Hardship Forgiveness Plan
Student loan hardship forgiveness was a plan that could have offered relief to federal student loan borrowers who faced “persistent financial burdens” like medical bills, natural disasters, and child care. Former President Biden sought to help relieve this financial burden through a hardship-based student loan forgiveness plan that he proposed while still in office.
The plan was ultimately pulled from consideration shortly before the Biden administration transitioned out of the White House. Here’s what to know about the proposed hardship forgiveness for student loans, plus other options for student loan borrowers dealing with financial hardship.
Key Points
• The Biden administration’s proposed student loan hardship forgiveness plan aimed to provide relief to federal student loan borrowers who were facing significant financial burdens.
• Automatic one-time forgiveness would have been offered to those with an 80% chance of default, based on financial indicators.
• An application-based forgiveness option would have allowed others to apply if not eligible for automatic relief.
• The plan was withdrawn in December 2024 due to operational challenges and limited time left in the administration’s term.
• Other student loan forgiveness options include income-driven repayment plans, although applications for these plans are on hold as of March 2025.
Understanding the Hardship Forgiveness Plan
In 2022, President Biden proposed a sweeping student loan cancellation plan that promised qualifying borrowers up to $20,000 in loan cancellation. The plan was blocked by the Supreme Court in 2023. Following the court’s decision, the student loan relief initiative was reworked by the administration into a student loan forgiveness plan, known as Plan B. The student loan hardship proposal was part of Plan B.
Overview of the Initiative
The student loan hardship forgiveness proposal was designed to offer relief to borrowers who were struggling with ongoing financial challenges. It enabled access to hardship forgiveness for student loans through two pathways:
• Automatic one-time forgiveness: In this pathway, if the Department of Education, using a “predictive assessment,” determined that a borrower had at least an 80% chance of defaulting on their student loan debt within two years, it may have automatically forgiven the loans on a one-time basis.
• Application-based forgiveness If borrowers did not qualify for the automatic student loan hardship forgiveness, they could submit an application that would “holistically assess” how likely they were to default or experience severe and persistent financial hardship.
Eligibility Criteria
For a borrower to qualify for automatic forgiveness, an assessment of varying indicators would be done by the Secretary of Education. If the assessment determined that a borrower’s loans had at least an 80% likelihood of going into default in the following two years, they would qualify for hardship forgiveness under the proposed rule.
Some of the indicators used to assess automatic forgiveness included:
• Income
• Total debts owed
• High costs associated with medical bills
• Child care and other essential expenses
• Whether the borrower had qualified for a Pell Grant
Under the application-based forgiveness, borrowers would need to demonstrate that they faced a high probability of loan default or other severe negative outcome if the hardship forgiveness wasn’t granted. The assessment also had to find that no other student loan payment options would adequately resolve the borrower’s hardship circumstances.
Application Process
Only borrowers experiencing an exceptional financial hardship who did not qualify for the automatic one-time forgiveness would need to complete a student loan hardship application for a holistic assessment.
However, since the hardship-based student loan forgiveness plan was withdrawn before its launch, no formal application was publicly available.
Recommended: Understanding Your Student Loan Statement
Implementation Timeline
The proposal for a student loan hardship forgiveness plan had been in the works for some time under the Biden administration. Here’s what to know about the proposal’s timeline.
Proposed Schedule
If the hardship forgiveness proposal had moved forward, the U.S. Secretary of Education in the Biden administration anticipated finalizing the new forgiveness plan and having it go into effect in 2025.
Legal and Political Considerations
The student loan hardship proposal would have given borrowers facing financial hardship tremendous relief. However, the proposed hardship-based student loan forgiveness plan, like many of the Biden administration’s forgiveness plans, had legal and political opposition.
Legal Challenges
Biden’s student loan hardship forgiveness initiatives were stymied by numerous legal challenges. First, the administration’s initial forgiveness plan that offered up to $20,000 in loan forgiveness was struck down by the Supreme Court in 2023. After that, different iterations of the proposal also faced legal hurdles.
For example, in 2024, seven states — Alabama, Arkansas, Florida, Georgia, Missouri, North Dakota, and Ohio — filed a lawsuit against the Biden administration, alleging that the proposed student loan hardship plan was an overstep of executive power.
Political Climate
In February 2025, the U.S. Court of Appeals for the 8th Circuit ruled that former President Biden’s student loan forgiveness plans were unconstitutional. With the Republican party currently holding the majority in Congress, and President Trump’s executive order in March 2025 to dismantle the Department of Education, a broad student loan hardship forgiveness plan appears unlikely to happen under the Trump administration.
Impact on Borrowers
Had Biden’s proposed hardship forgiveness for student loans been successful, an estimated eight million borrowers would have had their student loan balances erased.
Instead, these borrowers will need to repay their student loans through other alternatives, such as using another repayment plan or consolidating student loans.
Another option some borrowers might consider is student loan refinancing. When student loans are refinanced, the borrower’s current loans are replaced with a new loan from a private lender. Ideally, a borrower may be able to get better loan terms or a lower interest rate, if they qualify.
If you decide to explore how to refinance student loans, just be aware that refinancing federal loans makes them ineligible for federal programs, such as IDR plans and federal deferment.
Recommended: Student Loan Refinancing Calculator
Financial Relief
When borrowers default on their student loans, the remaining balance becomes due upfront, which further compounds their financial challenges. The hardship forgiveness plan would have provided relief to federal student loan borrowers who are at the highest risk of defaulting on their debt.
Credit Implications
With the proposed hardship forgiveness plan, some borrowers in a dire financial situation might have been able to avoid the negative mark of student loan default on their credit record.
Here’s why: A student loan balance that’s forgiven shows up on a credit report as a closed account. This lowers borrowers’ debt-to-income (DTI) ratio, which can impact their access to new credit. A DTI ratio is a formula used by creditors to determine whether an applicant can reasonably make payments toward a new credit account — the lower this percentage is, typically the more favorable it is for borrowers.
Alternatives and Additional Support
For borrowers who are experiencing financial hardship, student loan forgiveness is usually accessible through other federal programs, such as income-driven repayment (IDR) plans. However, as of March 2025, a federal court injunction has prevented the implementation of parts of the IDR plans, and applications for the plans are on hold. You can find out more about this situation and get any updates on the Federal Student Aid (FSA) website.
In the meantime, here is more about these plans and how they typically work.
Income-Driven Repayment Plans
IDR plans offer student loan relief — and ultimately, forgiveness — to borrowers who need lower student loan payments. These plans calculate your monthly payment based on your discretionary income and family size, which must be recertified annually. Depending on the plan, repayment terms are extended to 20 or 25 years, with payments set at 10% to 20% of your discretionary income. After successfully making all payments under your IDR plan, any remaining Direct Loan balance is forgiven.
There are technically four IDR plans, though one of them is no longer available:
• Saving on a Valuable Education (SAVE) Plan: This plan is no longer available after being blocked by a federal court.
• Pay As You Earn (PAYE) Repayment Plan
• Income-Based Repayment (IBR) Plan
• Income-Contingent Repayment (ICR) Plan
However, as discussed, applications for the PAYE, IBR, and ICR plans are on hold as of March 2025, and the application to change student loan repayment plans to an IDR option is unavailable.
The Takeaway
The Biden administration’s hardship-based student loan forgiveness plan would have forgiven student loan debt for an anticipated eight million federal student loan borrowers. However, the proposal was met with legal challenges and ultimately withdrawn by the administration in December 2024.
Although other federal loan forgiveness options, like forgiveness through income-driven repayment, currently still exist, new applications for these plans are not currently available. Borrowers looking for help managing their student loan debt may want to consider other options.
Looking to lower your monthly student loan payment? Refinancing may be one way to do it — by extending your loan term, getting a lower interest rate than what you currently have, or both. (Please note that refinancing federal loans makes them ineligible for federal forgiveness and protections. Also, lengthening your loan term may mean paying more in interest over the life of the loan.) SoFi student loan refinancing offers flexible terms that fit your budget.
FAQ
Will the forgiven loan amount be considered taxable income?
Whether a forgiven student loan amount is considered taxable income depends on the forgiveness program that granted the loan cancellation. However, the American Rescue Plan Act of 2021 provides federal loan borrowers a temporary federal tax exemption on forgiven student debt through 2025. Just be aware that some states impose a tax liability on forgiven student loans, regardless.
How does the hardship plan differ from previous forgiveness initiatives?
The proposed student loan hardship forgiveness program was unique in that it offered two different pathways for student debt relief. The first was automatic forgiveness qualification for borrowers who demonstrated an 80% likelihood of defaulting on their student loans. The second was a “‘holistic assessment’ of the borrower’s circumstances” in which forgiveness was to be assessed on a case-by-case basis after the borrower submitted an application.
What legal challenges could affect the plan’s implementation?
The Biden administration withdrew the student loan hardship plan in December 2024, citing operational challenges, and the plan is no longer moving forward. In February 2025, the 8th Circuit Court ruled that former President Biden’s overall student loan forgiveness efforts were unconstitutional.
photo credit:iStock/Damir Khabirov
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