Final RISE Regulations: RAP Payments Will Not Count Toward IBR Forgiveness

Sources: Final RISE regulations, Federal Register public inspection PDF

The Department of Education has finalized the RISE regulations implementing the student loan repayment changes enacted under the law commonly referred to as the One Big Beautiful Bill Act. The final rule is scheduled to be effective July 1, 2026, and it makes broad changes to federal student loan repayment, including the creation of the new Repayment Assistance Plan, or RAP, and the new Tiered Standard Repayment Plan.

For most borrowers, the final regulations are largely consistent with the proposed rules. But there is one major change that deserves immediate attention:

The Major Change: RAP Does Not Build IBR Forgiveness Credit

In the proposed regulations, many observers understood RAP payments to potentially count toward forgiveness under other income-driven repayment plans. In the final rule, the Department changed course.

The Department agreed with a commenter who argued that the statute did not authorize RAP payments to count toward IBR forgiveness. The Department then amended the regulatory language to clarify that, for PAYE, ICR, and IBR forgiveness, a borrower receives forgiveness credit by making a payment under an IDR plan except RAP, or by having a $0 monthly payment obligation.

That means a borrower could make payments in RAP for several years, later switch to IBR, and discover that the RAP months do not count toward the borrower’s IBR forgiveness timeline.

This is not a small technical change. It changes the analysis for borrowers who may be deciding between RAP and IBR, especially borrowers who expect their income, family size, employment, or forgiveness strategy to change over time.

RAP Still Has Its Own Forgiveness Path

RAP is not a dead-end plan. RAP has its own forgiveness structure. Under the final regulations, a borrower repaying under RAP receives forgiveness after satisfying 360 qualifying monthly payments, or the equivalent, over a period of at least 30 years.

RAP also includes certain borrower protections. Payments are based on AGI using a sliding scale from 1% to 10% of AGI, and borrowers may receive a $50 reduction per dependent. However, unlike older IDR formulas, RAP does not include an income protection allowance based on the poverty guideline.

The final rule also provides that if a borrower’s on-time RAP payment is not enough to cover monthly interest, the Department will not charge the borrower for the unpaid accrued interest for that month.

RAP Can Count for PSLF — But Only If the PSLF Rules Are Met

The final rule confirms that RAP is a qualifying repayment plan for Public Service Loan Forgiveness. The Department stated that on-time RAP payments are PSLF-qualifying payments if the borrower otherwise meets the PSLF employment and loan requirements.

That distinction matters. RAP may be workable for PSLF borrowers if they remain in qualifying employment and make on-time payments. But RAP creates risk for borrowers who are not clearly on a PSLF path and may later need IBR forgiveness.

Why This Matters for Borrowers

The practical concern is that borrowers may choose RAP because the monthly payment appears manageable or because it becomes the default income-driven option for many borrowers. But if that borrower later wants or needs to switch into IBR, the RAP months may not help them get closer to IBR forgiveness.

This creates a hidden timeline risk.

For example, a borrower could spend five years in RAP and then determine that IBR is a better fit due to income changes, marital status, family size, or a shift away from PSLF employment. Under the final rule, those five years may count toward RAP’s 30-year forgiveness path, but not toward IBR forgiveness.

Borrowers should not evaluate RAP only by the monthly payment. They need to evaluate the long-term forgiveness path attached to that payment.

Planning Takeaways

Borrowers should be careful before entering RAP if they may later need IBR forgiveness. RAP may be appropriate in some cases, especially where the borrower is pursuing PSLF or where RAP’s 30-year forgiveness structure is the intended path. But RAP should not be treated as interchangeable with IBR.

The key planning questions are:

1. Is the borrower pursuing PSLF?
2. Is the borrower already making progress toward IBR, PAYE, or ICR forgiveness?
3. Would RAP lower the monthly payment but reset or strand progress toward another forgiveness path?
4. Is the borrower likely to remain in RAP long enough for RAP forgiveness to matter?
5. Could the borrower’s income, tax filing status, employment, or family size make IBR more favorable later?
6. The strategy of using RAP to reduce negative amortization then changing to IBR for the shorter forgiveness periods is now not a viable option.

Bottom Line

The final RISE regulations confirm that RAP is now a central part of the new federal student loan repayment system. But the most important change in the final rule is that RAP payments do not count toward IBR forgiveness.

Borrowers should be cautious about entering RAP without understanding the long-term consequences. A lower or more manageable payment today may come with a hidden cost if those months do not count toward the forgiveness program the borrower ultimately needs.