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Effect of Defaulted Student Loans on Return to Work Efforts

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                                 EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                     Policy and Practice Brief:

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                     Prepared by

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          r          Ronald M. Hager, an attorneyorgg Neighborhood Legal
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                                                aa New
                     Services (NLS) of Buffalo, t o York, and Ray Cebula, a
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                     Training and Organizational Development Specialist with
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                     Cornell University’s Program on Employment and Disability
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                     and ge-attorney with the Disability Law Center (DLC) in llege- -lo
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                                                                                            7
       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                                     l
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              This is one of a series of-looa     n c
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                              Advocacy for Beneficiaries of Social Security programs. wwww.c contained
                                                                                        Materials
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              within this policy brief have been reviewed for accuracy by the Social Security Administration
              (SSA), Office of Employment Support Programs. However, the thoughts and opinions
              expressed in these materials are those of the authors and do not necessarily reflect the
              viewpoints or official policy positions of the SSA. The information, materials and technical
              assistance are intended solely as information guidance and are neither a determination of
              legal rights or responsibilities, nor binding on any agency with implementation and/or
              administrative responsibilities.




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                        Introduction ...............................................................................................3 ans- -c
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                        Typescoll lleg                                                                              .col le
                             . of Student Loans ............................................................................... 3
                         w ww.co                                                                              w  ww.col
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                        Effects of a Defaulted Student Loan ............................................................4
                                    Introduction ......................................................................................4
                                    Steps to take prior to going into default ........................................... 4
                                       Repayment Plans ........................................................................4
                                       Deferments .................................................................................4
                                       Forbearances .............................................................................. 5
                                    Effect of Defaulted Student Loans on VR Agency
                                     Funding for College ........................................................................5

                           Increased Federal Efforts to Collect Defaulted Student Loans ................... 6
                                 Elimination of Statute of Limitations ............................................... 6
                                 Tax Intercept Program .................................................................... 6
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                                 Social Security Offset Program ......................................................... 6
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                           Remedies to Take a Loanns s of Default .................................................... 7                         sololid
                                 Bankruptcyns- -co
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                                               ....................................................................................... 7 ans- -co
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                                 Disability lDischarge ..........................................................................8loa
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                              ww.Debt Cancellation Through Discharge Procedures ..........................8
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                                     Closed School Discharge ..............................................................9
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                                       False Certification Discharge ...................................................... 9
                                       Unpaid Refund Discharge ...........................................................9
                                    Repayment of Defaulted Student Loans .......................................... 9
                                    Loan Consolidation .........................................................................10

                           Conclusion         .............................................................................................10
                                    l
                                        3   l
                                                EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                                                            sololida Introduction
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              Many individuals with disabilities mayns-c
                                                 anshave attempted college either before or after                     ans s-c
                                                                                                                         n
                                            e-loloa
                                      l lprior -
              they became disabled. lIfeggecollege attempts were unsuccessful, the student may
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              have defaulted www.co loans. When the loans are secured by the federal
                             on student                                                                 w.c ol
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              government, the individual will not be eligible for further financial assistance, including
              all federal grants and loans, for college until the prior loans are no longer in default.
              Many state vocational rehabilitation (VR) agencies may also be reluctant to provide VR
              funding for higher education in this event. Moreover, the Debt Collection Improve-
              ment Act of 1996 (Debt Collection Act),1 and other federal changes, allow for
              expanded collection of delinquent student loans.

              For individuals with disabilities who are attempting to go to work, the dual impact of
              not being eligible for additional federal aid to obtain higher education and the potential
              drain on income to repay the defaulted loans can be devastating. It is, therefore, very
              important for both Benefits Planning, Assistance and Outreach (BPA&O) counselors
              and Protection and Advocacy for Beneficiaries of Social Security (PABSS) advocates to
       orgg                                                                    rg
              be aware of the effects of defaulted student loans, theon.oorg federal efforts to
      n r
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                                                                             n.
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              collect on those loans, and some of the remediesdaa are available to debtors. This
                                                              sololthat There is also an extremely well                        ida
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              article will explore each of these issues cosome detail.                                                    onns
              written and well-documented-resource ns- -co from the National Consumer Law
                                                  a n  s available                                                   ns-c co
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              Center for those who may g
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                                                              II.     Types of Student Loans

              For anyone working with individuals with defaulted student loans, it is important to
              first determine the precise type of loan as well as the effective date of the loan. Over
              the years, the names of the different types of loans, as well as the rules applicable to    1
                                                                                                              Pub.L.No. 104-34, 31
              those loans, have changed a number of times. Currently, there are three basic types of          U.S.C. § 3716.
              federally guaranteed student loans: Federal Family Education Loans (FFEL), which are        2
                                                                                                              Loonin, Deanne, John
                                                                                                              Rao and Alan White,
              between the student and private financial institutions;3 Direct Loans, which are
                                                                                                              Student Loan Law, The
              between the federal government and the student;4 and Perkins Loans, which are                   Consumer Credit and
              between the school itself and the student.5 A good place to start to find the status of         Sales Legal Practice Series,
                                                                                                              National Consumer
              a borrower’s student loans is www.studentclearinghouse.org.
      .orgg                                                                  .orgg
                                                                                                              Law Center, Inc.
          r                                                                      r
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a at o        It can then get very confusing, because within olidda
                                                                each
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                                                                           o
                                                                     aof tthese three basic families of loan
                                                                                                              (Boston, MA 2001).
                                                                                                              Much of the basic   ida
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              programs are specific types of loans. A conn
                                                                    i
                                                              s solthe same name can be from two                               sololid
                                                                                                              information in this
                                                                                                                            onns
                                                        - loan with
                                                        s- o
                                                     nscancbe a Stafford Loan, subsidized or unsubsi-                   ns-c co
                                                                                                              article came from this
                                                                                                                          s-
              different families. For example, oaan
                                               -l there                                                             -loaan
                                                                                                              resource.
              dized, under both the FFEL ore-
                                                   lo
                                           elge Direct Loan programs. This article will not attempt to ollelgee-l
                                                                                                          3            o
                                                                                                              Governing regulations
                                      o lol eg
                                         l                                                                      l eg
                                 w.c                                                                 basic .c o
                                                                                                              are found at 34 C.F.R.
              differentiate between.c
                              www each of the specific types of loans, but will try to give the wwww.c    w   Part 682.
                            ww                                                                        w
              rules, with citations, which are applicable as broadly as possible. The reader interested   4
                                                                                                              Id. Part 685.
                                                                                                          5
                                                                                                              Id. Part 674.
              in more specific information is referred to Student Loan Law by the National                6
                                                                                                              See note 2, above.
              Consumer Law Center.6
       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                                  l
                                                                                                        4   l




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            III.                                             sololi a
                             Effects of a Defaulted StudentdLoan
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                                    A. olIntroduction
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                                  www.c a loan will be “in default” if there have been no paymentsww.c days
                                 wwCurrently,                                                   ww 270
                                                                                              ww for
                                        (about nine months) and there is a reasonable finding that the borrower no longer
                                        intends to repay.7 Defaulting on a federally-guaranteed student loan has serious
                                        consequences. The loan will most likely be given to a collection agency, which will add
                                        collection fees onto the outstanding principle, interest will continue to accrue on the
                                        loan, the borrower’s credit rating will be affected and wages can be garnished. Addi-
                                        tionally, new offset provisions, which will be discussed below, allow the federal govern-
                                        ment to seize tax returns and, for Social Security Disability Insurance (SSDI) beneficia-
                                        ries, a portion of the SSDI check to repay the loan. Therefore, it is extremely impor-
                                        tant to avoid going into default in the first place.

                                         B.       Steps to take prior to going into default
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  ioin. .o                                        1.    Repayment Plans tionn.o
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                                          For low-income s-coon there are repayment options in addition to the                onns
                                                       olaanns-cplans. FFELs have income-sensitive repayment plans (ISRP) ns-c co
                                                            borrowers,
                                          traditional-lrepayment                                                      loaan s-
                                                 geeborrower’s payments are adjusted each year based on theirlege- -lo
                                              le g      -o                                                           e
                                          where the
                                         .col le                                                                leg
                                                                                                            ol expected
                                      w ww.col gross income. However, monthly payment must be large w.col to at
                                          monthly                                                     w w.c
                                                                                                          enough
                                     www least cover accruing interest.8 Direct Loans have Income Contingent Repayment
                                                                                                    www
                                              Plans (ICRP), which allow payments to be reduced for low income borrowers as
                                              well. Payments under an ICRP need not cover accruing interest and can even be
                                              zero for borrowers below the poverty level.9 Under Perkins Loans, schools may
                                              extend the repayment period for low-income borrowers for up to an additional
                                              ten years. But, as with the repayment plans under the other programs, interest
                                              continues to accrue.10

                                                  2.    Deferments

                                              Another option for borrowers finding it difficult to make payments, prior to
                                              default, is to seek a deferment. A deferment allows the borrower to postpone
                                              paying the loan back and, during that period, interest does not continue to accrue.
      .orgg
          r                                   The rules for obtaining a defermentn.orgg for any loan issued after July 1, 1993.
                                                                                   changed
                                                                                      or
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a at o                                                                       atioion
                                                                               at
                                                                                     .
                                                                          idiunder the FFEL and Direct Loan programs for:                  ida
d                                         Deferments are nowonsool d
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                                                                 available                                                              sololid
                                                                      s                                                              onns
                                                               - n
                                                          ns-c co
                                          students in at leastshalf-time study, graduate fellowships, or rehabilitation programs; s-c co
                                                                                                                                 nns-
                                                     -lola with
                                          unemployment,an the loan deferment for no more than three years; economic a
                                                     e- o                                                                   -loa
                                                                                                                               o
       7
          34 C.F.R. §§
                                            o  l elgedetermined one year at a time for no more than three years;lland ee-l
                                              lol eg
                                          hardship,                                                                 o  elgg
                                                                                                                         e Peace
          682.200(b)(FFEL) and          w.c
                                      www.c service.11
                                          Corps                                                              w.c ol
                                                                                                           www.c
          685.102(b) (Direct).       ww                                                                  ww
       8
          Id. § 682.209(a)(7)(iv).
       9
          Id. § 685.208(f).                   For Perkins Loans, the following deferments are now available: student; unable to
       10
          Id. § 674.33(c)(3).                 find full-time employment, for no more than three years; economic hardship, for
       11
          Id. § 682.210(s) (FFEL)
          and 685.204(b)
                                              no more than three years. In addition, in certain specified circumstances, these
          (Direct).                           deferments are also available: full-time teaching, full-time law enforcement, military
       12
          Id. § 674.34.                       service, and volunteer service, such as the Peace Corps.12
                                     l
                                         5   l
                                                 EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                        3. Forbearancesloanns-
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                    A forbearance is .another option for borrowers who cannot make their loan ww.c col
                              www c
                            w Under the FFEL and Direct Loan programs, unlike a deferment, itwww
                    payments. w                                                               is
                                                                                                 w.
                  available both before and after a borrower goes into default. The forbearance will
                  put a halt to collection actions.13 The forbearance allows a borrower to tempo-
                  rarily stop making payments altogether, reduce the amount of the payments, or
                  extend the length of time over which payments will be made.14 However, also
                  unlike a deferment, interest will continue to accrue during the forbearance period,
                  so it is actually likely that the amount owed on the loan will increase during this
                  time.15

                    Forbearances are available for borrowers who cannot make loan payments be-
                    cause they are in poor health or have other personal problems.16 Administrative
                    forbearances are also available while applications are being processed for, among
                    other things, changes in payments, requests for deferments, loan consolidation or
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  ioin. .o          discharge.17                                      t    n r
                                                                        ion. .o
da                                                            ida tio
                                                           sololida are already paying the $30                             ida
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                                                      for nns
                    Under the Perkins Loan program, -costudents who                                                   onns
                    monthly minimum and stillloaan to
                                                          o
                                                  ns s-cmake payments because of hardship, the                   ns-c co
                                                                                                                    s-
                                               unable
                                           ge- -lo                                                          -lolaan
                                                                                                                o
                    school may further lreduce the minimum payments for up to a year.18 Additionally, llegee-
                                             e
                    a borrower’s w.c c
                                      ooeleg
                                        ll
                                                                                            for w.c
                                                                                                      oolleg
                               w income period can be extended for up to ten more years wwww.c
                                  repayment
                                     .
                             wwww up to 150 percent of poverty.19
                    families with                                                             w
               C.      Effect of Defaulted Student Loans on
                       VR Agency Funding for College
              What if the individual now seeks to return to college, with state VR agency support,
              and does not have the financial ability to get the loan out of default? Must the VR
              agency consider, as a comparable benefit, the value of any grants for which the indi-
              vidual would have been eligible, and reduce its support to the individual by that
              amount?

              VR agencies may fund higher education, if needed to meet an employment goal. How-             13
                                                                                                               Student Loan Law, p. 12.
              ever, the VR agency cannot use federal VR funds “unless maximum efforts have been             14
                                                                                                               34 C.F.R. §§
      .orgg
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              made . . . to secure grant assistance, in whole or in part,n.oor
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                                                                                                               682.211(a)(1)(FFEL) &
a at o                                                          il a tioion. other sources to pay for
                                                                          from
                                                                                                                               ida
                                                                                                               685.205(a) (Direct).
d                                                             olodidat
              that training.”20 The Rehabilitative Services Administration (RSA), which oversees the
                                                            sreconcile the requirement to use “maxi-        15
                                                                                                                            sololid
                                                                                                               Student Loan Law, p. 12.
                                                        con
              VR program, has issued a Policy Directive tons                                                             onns
                                                                                                                     ns-c co
                                                                                                               34 C.F.R. §§
                                                       s-co
                                                                                                            16


              mum efforts” to secure outsideoaan   ns-assistance and the problem for individuals with                  s-
                                                                                                                 -loaan
                                                                                                               682.211(a)(2)(i) (FFEL)
                                              -l grant
                                                  o                                                                 o
                                        egee-l                                                               elgee-l
                                                                                                               & 685.205(a)(1)
              defaulted student loans, lwhere that assistance is unavailable.21
                                      l eg                                                                lol eg
                                                                                                           l
                                    o l                                                                 o      (Direct).
                               w.c ol
                            www.c                                                                   w.c
                                                                                                  www.c
                                                                                                            17
                                                                                                               Student Loan Law, p. 13.
              RSA’s Policy ww                                                                   ww
                           Directive provides that if an individual with the financial means to do so       18
                                                                                                               34 C.F.R. § 674.33(b)(5).
                                                                                                            19
                                                                                                               Id. § 674.33(c)(2).
              fails to repay a loan, the VR agency may determine that the grant assistance for which        20
                                                                                                               29 U.S.C. § 723(a)(5);
              the student is ineligible is, in any event, “available” to that person. Accordingly, the VR      34 C.F.R. § 361.48(f)
              agency would deduct from the amount of assistance it will provide the value of the               (6)(emphasis added).
                                                                                                            21
                                                                                                               RSA Policy Directive,
              grants for which the student would have been eligible. On the other hand, when a                 RSA-PD-92-02 (11/21/
              student with limited financial means cannot make repayment arrangements with the                 91).
       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                               l
                                                                                                     6   l




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                                      lender, or otherwise s s-c loan out of default as discussed below, the VR agency oans s-c
                                                         ann the
                                                      -lo a take                                                         may n
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                                      concludeegee-lo                                                          would g lo
                                               l lthat “maximum efforts” have been made and full VR assistance ollelgee-
                                                    g                                                                 be
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                                      appropriate. When confronted with this question, VR counselors mustc col individu-
                                       w.c o
                                     www.c                                                                w. make
                                                                                                        www.
                                    wwalized determinations, based on all of the circumstances involved.w
                                                                                                      w22
              IV.        Increased Federal Efforts to Collect Defaulted
                         Student Loans
                                        A.     Elimination of Statute of Limitations

                                       It is important to note that there is no longer a statute of limitations that applies to the
                                       collection of student loans.23 What this means is that no matter how old a loan is, all
                                       of the collection actions discussed in this article can be used to seek to recover on a
                                       defaulted student loan. For example, the authors have had clients with loans that were
                                       20 years old that were now subject to collection actions. 24
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  ioin. .o                                     Tax Intercept Programt t o
                                                                                n r
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                                      The tax intercept programon
                                                                                                                                 onns
                                                        a ns-c c applies to a legally enforceable debt owed to the federal ans-c co
                                                             s-                                                                s-
                                      government e-looan
                                                    or administered by a third party on behalf of the government.25 ge-looan
                                                  gge-l                                                               This -l
                                             oloele
                                      would, therefore, apply to defaulted student loans. It gives the governmentleeg
                                               ll                                                                       e
                                                                                                                olothe author-
                                       w  .c.c                                                               .c.c  ll
                                     ww to
                                    wwity w26use any tax refunds owed to a borrower toward repayingwwww thew
                                                                                                         w defaulted student
                                       loan. As long as the loan continues to be in default, with an outstanding balance, any
                                       tax refunds owed will simply be used toward paying off the loan. It is called an inter-
                                       cept program because the refund never gets to the borrower. It goes directly from
                                       the Internal Revenue Service (IRS) to the Department of Education (DOE), the federal
                                       agency that is owed the debt.

                                       Prior to commencing a tax refund intercept, the DOE must give the borrower written
      22
         Id.                           notice. The notice must inform them of the right to review the loan records, to obtain
      23
         20 U.S.C. § 1091a.
      24
         In a recent federal
                                       a review of the status of the loan, or to enter a repayment agreement.27 The bor-
         district court decision,      rower may request a hearing from the DOE within 65 days of receipt of the notice (if
         however, the judge ruled      the borrower does not first request to review the file).28 A timely request for a
         that the DOE could not
                                       hearing will stop the intercept until the review is complete.29 Even though the tax
      .orgg                                                                           g
         seek to offset Social
          r                            collection under this intercept programn.or rg
                                                                                 is administered by the IRS, any attempts at
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a at o
         Security benefits for
                                       resolution must be pursued withdaat   tioion.o                                               ida
d        loans where their right
         to pursue a claim is
                                                                        li the DOE.
                                                                    sooli   d                                                    sololid
         more than 10 years old.                             -conns
                                       C. Socialloans s-c Offset Program
                                                       Security
                                                                  o                                                           onns
                                                                                                                          ns-c co
                                                                                                                            s-
         This is a very important
                                                     - oan                                                            -loaan
                                                                                                                         o
         first step in limiting
                                            o    elgee-l
                                              lol eg
                                               l                                                             o  l elgee-l
                                                                                                               lol eg
                                       w.c                                                               w.c
         governmental actions on
         very old loans.
                                      Federal
                                                                                                       www from taking
                                     www.c law generally prohibits anyone, including the federal government,.c (SSI)
                                    wwSocial Security Disability Income (SSDI) or Supplemental Securityw
                                                                                                    w Income
      25
         31 U.S.C. § 3720A.
      26
         Id. § 3720A(c).               benefits by legal means.30 This is referred to as the anti-assignment clause. However,
      27
          34 C.F.R. § 30.33(b).
      28
         Id. § 30.33(d).
                                       because this right was created by Congress, it can be modified by Congress. In certain
      29
          31 U.S.C. § 3720A(b).        instances Congress has specifically allowed this protection to be pierced. The Debt
      30
         42 U.S.C. §§ 407 (SSDI)       Collection Act31 is one such instance in which Congress specifically indicated its
         & 1383(d)(a)(SSI).
      31
         31 U.S.C. § 3716.
                                       intent to override the anti-assignment clause protection. The law specifically overrides
                                     l
                                         7   l
                                                 EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                                                                                                                        s
                                                    -coo
              the anti-assignment clauses for oans s-c and SSI.32 However, the federal regulations
                                                                                                                  -coon
                                              both n
                                            -l oa  SSDI                                                       ans s-c
                                                                                                          -loloa n
                                       elgee-l
              implementing the Debt lCollection Act provide an exemption for SSI payments,33 and
                                     l e  g                                                          lelgee-
                                                                                                   ol e  g
              the Social Security .cool
                               w Administration’s (SSA) Program Operations Manual System (POMS)c ol
                                                                                                w.
                           wwwww.c from the offset program.34 Therefore, this program willwww.c
              also exempts SSI benefits                                                    ww  not
              apply to SSI recipients, but it will apply to SSDI recipients. Although the law was
              passed in 1996, it was not until 2001 that the government began to implement the
              program.35

              The DOE initiates collection by providing notice of intent to collect past due student
              loans to the SSDI recipient.36 This notice of offset will provide hearing rights and
              limited remedy information. The recipient has the right to request a hearing37 to
              challenge the offset or to set up a repayment plan to avoid offset.38 Requests for
              hearings and arrangements for repayment plans must be made with the DOE.

              The SSA has no authority to modify or terminate DOE offsets.39 DOE must certify
              the debt to the Department of Treasury (Treasury). Once allg   notice time periods have
       orgg                                                             n.or rg
      n r
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at t o
              run and hearings have occurred, Treasury will order SSA to.assign a portion of the
                                                                      io n o
da                                                          o  i l dt
                                                              lodiaatio
              recipient’s monthly SSDI benefits to DOE. Notices from Treasury will come from the                     ida
                                                                                                                  sololid
              Financial Management Service (FMS). cons s
                                                       on                                                       onns
                                                 ns- -c
                                                    s                                                      ns-c co
                                                                                                              s-
                                           -loaan
                                        does -lo
              The Debt Collection Actegeeprovide some protections, however. The first $750 of
                                                                                                        loaan
                                                                                                    ge- -lo
                                                                                                       e
                                      l g
                                 .col le                                                         lleeg
              SSDI paid to a recipient cannot be taken. The total amount recouped from each w.cooll
                            w  ww.col                                                          .c
                                                                                          ww
                          ww payment must be the lesser of the amount the monthly benefit www
              monthly benefit w
              exceeds $750, if at all, or 15 percent of the total monthly benefit.40 The implementing   32
                                                                                                           Id. § 3716(c)(3)(A)(i).
              regulations give the following examples to clarify how this would work:                   33
                                                                                                           31 C.F.R. § 285.4(a)(1).
                                                                                                        34
                                                                                                           POMS GN 02410.300
                    (i) A debtor receives monthly Social Security benefits of $850. The                    B.1.a.
                                                                                                        35
                                                                                                           Tarantino, Louise, “Social
                        amount offset is the lesser of $127.50 (15% of $850) or $100 (the                  Security Benefits Subject
                        amount by which $850 exceeds $750). In this example, the amount                    to Increased Debt
                        offset is $100 (assuming the debt is $100 or more).                                Collection,” p. 16, Legal
                                                                                                           Services Journal (Greater
                                                                                                           Upstate Law Project,
                    (ii) A debtor receives monthly Social Security benefits of $1250. The                  December 2001).
                         amount offset is the lesser of $187.50 (15% of $1250) or $500 (the             36
                                                                                                           31 C.F.R § 285.4(f).
                                                                                                        37
                                                                                                           31 U.S.C. § 3716(a).
                         amount by which $1250 exceeds $750). In this example, the amount               38
                                                                                                           34 C.F.R. § 30.22(b)(3)
                         offset is $187.50 (assuming the debt is $187.50 or more).
      .orgg                                                                  g                             (iii).
          r                                                                .or rg
 tioinn.o                                                             tioinn.oof $650. No
                                                                                                        39
                                                                                                           See POMS GN
a at o              (iii) A debtor receives monthly Social Securityiaat o
                                                                lod payments
                                                                 il                                                     ida
                                                                                                           02410.300 A.5.
d                                                            solessd $750.41
                                                          on is
                          amount will be offset because $650 ns      than
                                                                                                        40
                                                                                                                     sololid
                                                                                                           31 C.F.R. § 285.4(e).
                                                                                                                  onns
                                                     ns-c co                                                  ns-c co
                                                                                                        41
                                                                                                           Id. § 285.4(e)(3).
                                                        s-                                                      s-
                                                -lolaan
                                                  -o                                                      -loaan
                                                                                                             o
                                       o    elgeeV. Remedies to Take a Loan out of Defaultee-l
                                         lol eg
                                          l                                                      o  l elgg
                                                                                                   lol e
                                  w.c
                                www.c                                                        w.c
                                                                                           www.c
                              ww                                                          ww
               A.      Bankruptcy

              While severe limitations have been placed on the discharge of student loans through
              bankruptcy, it is still possible to discharge a student loan based on “undue hardship.”
       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                                  l
                                                                                                        8   l




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                                                                                                                                             s
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                                                               been a c
                                            There must have ans s-“good faith” effort to pay the debt in the past together withans s-c
                                                                                                                                       -coon
                                                            lo a  n                                                              lo a n
                                            no prospecte- -future income for a significant period of time.42 Although this e-a -lo
                                                    lelggefor lo                                                              is
                                                                                                                          lelgge
                                                 ol e                                                                  ol
                                            verychighl hardship standard, it may warrant exploration in appropriate .cases. e
                                             w. o
                                           www.c even if the hardship standard cannot be met, some bankruptcy.c  w c ol For
                                                                                                              www courts have
                                          wwexample,                                                        ww
                                             discharged collection fees and interest for the student loan debt. In addition, a
                                             Chapter 13 bankruptcy plan will determine how much the borrower pays each
                                             month. In many instances, this could mean a significantly lower monthly payment on
                                             the outstanding loan.

                                              B.     Disability Discharge

                                             Under the federal guaranteed student loan programs, there are provisions for dis-
                                             charging a student loan, if a person becomes “totally and permanently disabled.”43 To
                                             be considered “totally and permanently disabled,” the individual must be “unable to
                                             work and earn money or attend school because of an injury or illness that is expected
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                                                                                    ioin. .
                                             to continue indefinitely or result in death.”44o
                                                                                   t o
da                                                                          ida t
                                                                        sololida                                                             ida
                                                                                                                                          sololid
                                                                    c cn s
                                            Beginning in July 2002,-a-oonprocess for disability discharges exists.45 The DOE will s-coon
                                                                ns s new                                                            nns-c
                                                                                                                                         n s
                                                            loa
                                            issue a “conditionalan                                                              -loaa
                                                                                        of three years.46 During this
                                                        ge- -lo discharge” for a periodwork (most likely by reviewingperiodethe lo
                                                           e the borrower’s ability to                                            -
                                                                                                                            gincome
                                            DOE ollereview
                                                  willlleg                                                             oSSAege
                                                                                                                        loel
                                                                                                                         ll
                                             w.c o
                                           www.c                                                               ww .c
                                                                                                                    .c
                                                                                                            ww remains appropri-
                                          wwreports) in order to determine whether the “conditional discharge”ww
                                            ate. The borrower also has an affirmative duty to report to the DOE earnings that are
                                             more than the federal poverty level.47 During the three year period the borrower will
                                             be allowed earnings up to the poverty level. If earnings exceed the poverty level, the
                                             loan will again become due and owing. If earnings remain below poverty during the
       42
          Brunner v. New York State          three year period, the loan will be permanently discharged. During the period of the
          Higher Ed. Services Corp.,         conditional discharge, the borrower is not required to make any loan payments, nor
          831 F.2d 395 (2d Cir.
          1987).
                                             does interest accrue.48
       43
          20 U.S.C. § 1087(a).
       44
          34 C.F.R. §§ 682.200(b)             C.     Debt Cancellation Through Discharge Procedures
          (FFEL) & 685.102(a)(3)
          (Direct).
       45
          65 Fed. Reg. 65, 687-79.          First, there is a discharge of the loan based on the death of the borrower. 49 Addition-
       46
          34 C.F.R. §§ 674.61(b)            ally, based upon “hardship,” debt cancellation, through a number of discharge options,
      .orgg
          Perkins, 682.402(c)(1)
          r                                                                                  g
                                            which will be discussed below, is one ofn.ormost effective ways for a borrower to
                                                                                        the org
 tioinn.o
a at o    (FFEL) and 685.213(a)(i)                                                       n.
                                                                                   tioiefforts. While there is no time limit associated
                                            obtain relief from the DOE’s collection o
d         Direct) 411.530.                                                    loda t
                                                                           sotheida
                                                                               il                                                               ida
                                                                                                                                             sololid
       47
          Id. §§ 674.61(b)(7)(iv)                                      onn
                                            with filing a discharge request,s student loan in question must have been made in
                                                                                                                                         -conns
          (Perkins), 682.402(c)                                   ns-c will
                                                              olaan  s- o
                                            1986, or later. Discharge c result in the complete elimination of the student loanoans s-c  n
                                                                                                                                            o
          (14)(iv) (FFEL) and                               -l o
                                            debt andegereimbursement of all monies paid out by the borrower, including tax -lo    -l a
          685.213(d)(4) (Direct).
                                                   o  l leg -                                                               l l eee
                                                     lolthe eby the IRS and payments made by the borrower. The DOE loelgalso be  g
                                             w.c
                                            refunds seized                                                            .co will
                                           www.c to assist in “cleaning up” the credit report of the borrowerww.cdischarge.
       48
          Id. §§ 674.61(b)(7)(i)
          (Perkins),                      wwrequired                                                              ww
                                                                                                                ww after
          682.402(c)(14)(i) (FFEL)
          and 685.213(d)(1)
                                            Upon the denial of a discharge there exists an informal DOE review process, a second
          (Direct).                         discharge request can be submitted, or the borrower can seek review in federal court.
       49
          Id. § 374.61(a).
       50
          Id. See Student Loan Law,
          p. 113, n. 179, for a list of
                                             Many states have their own tuition recovery funds for students who have been
          available state programs.          defrauded but do not qualify for one of the federal discharge options.50
                                    l
                                        9   l
                                                EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                                                         n ns                                                           nsoolid
                                                                                                                           s
                     1. Closed Schooloans s-c
                                                    -coo                                                             -coon
                                              Discharge
                                           -l loa n                                                              ans s-c
                                                                                                             -loloa n
                                    l lelgee- available for FFELs, Direct Loans and Perkins Loans collelgee-
                 A closed schoolcool e is
                                          g                                                               e g
                              w. discharge
                                  c                                                                 w. ol
                            www.in part, after January 1, 1986.51 The discharge is available if wwww.c
                 received,wwleast
                           at                                                                   the
                                                                                                  w
                 borrower was unable to complete the program because the school closed. The    52

                 student must have either been enrolled at the time of the school’s closure, or if
                 the student withdrew, the withdrawal must have occurred within 90 days of the
                 school’s closure.53 The DOE maintains a list of official school closing dates at
                 www.ed.gov/offices/OSFAP/Students/closedschool/search.html.

                     2.    False Certification Discharge

                 A false certification discharge also applies to student loans received, at least in part,
                 after January 1, 1986.54 Perkins Loans are not eligible for this type of discharge.
                 The student must prove that the school falsely certified to the DOE his or her
                 ability to benefit from the program. In most cases, students with high school
       orgg                                                                orgg
      n r
                 diplomas or General Equivalency Diplomas at the time .of radmission will not be
  ioin. .o
at t o                                                               ioin.minimum state employment
                 eligible.55 However, if the student is unable itoat t o  no
da                                                              l d meet
                                                                     a                                                       ida
                                                                                                                          sololid
                                                          nns id
                 requirements for the job for which the sool was being trained,56 or if the
                                                        coo student                                                     onns
                 school forged or altered the ans- -c or check endorsements,57 a false certifica-
                                               o loan note
                                                    ns                                                             ns-c co
                                                                                                                loaan s-
                 tion discharge still mayge-l-loa
                                        e be e
                                             available.                                                     ge- -lo
                                                                                                               e
                                l g                                                                       le g
                            .col le
                           ww.col                                                                     .col le
                                                                                                     ww.col
                         w
                     3. www
                         Unpaid Refund Discharge                                                   w
                                                                                                  www
                 An unpaid refund discharge also applies to loans obtained, at least in part, after It
                 will allow a borrower to discharge any part of loan liability that is directly due to
                 the school’s failure to pay tuition refunds to the student. They will be able to
                 reduce their debt by the amount of the refund that was owed, as well as interest
                 and related charges.58
                                                                                                             51
                                                                                                                34 C.F.R. §§ 682.402(d)
               D.    Repayment of Defaulted Student Loans                                                       (1)(i) (FFEL),
                                                                                                                685.214(c)(1)(ii)
                                                                                                                (Direct) & 674.22(g)
                                                                                                                (Perkins).
              If an individual with a disability is not eligible to have a student loan discharged, the law  52
                                                                                                                20 U.S.C. § 1087(c)(1).
              makes it relatively easy to develop a repayment plan, which will take the loan out of          53
                                                                                                                34 C.F.R. § 682.402(d)
      .orgg
          r   default. Each guaranty agency under the federal student loan rg .orgprogram must establish a      (1)(i) (FFEL) & 685.214
 tioinn.o
a at o        program, which allows a borrower with defaulted loans o
                                                                                .o
                                                                        tioinnrenew eligibility for all
                                                                    idiaat to
                                                                                                                (c)(1)(ii) (Direct).
                                                                                                                                  ida
d
              federal financial assistance. The borrower nns    solomake six consecutive monthly pay-
                                                            o must
                                                                     ld                                      54
                                                                                                                34 C.F.R. § 682.402(e)
                                                                                                                (1)(i)(A).
                                                                                                                               sololid
                                                                                                                            onns
                                                     ns-c co
                                                 loaan
                                                           -
              ments to bring the loan out of default.sThe guaranty agency cannot demand from a               55
                                                                                                                        ns-c co
                                                                                                                          s-
                                                                                                                Id. § 682.402(e)(1)(i)(A).
              borrower a monthly payment -amount that is “more than is reasonable and affordable
                                                    o                                                               -loaan
                                                                                                                       o
                                           elgee-l                                                              elgee-l
                                                                                                             56
                                                                                                                Id. § 682.402(e)(13)(iii)
                                      o lol eg financial circumstances.”59 A borrower may only .colol eg
                                         l                                                                    l (B).
                                 w.c c
              based upon the borrower’s total
                               www.this provision once.60                                               ww .c
                                                                                                             57
                                                                                                                Id. § 682.402(e)(1)(i)(B),
                            ww
              obtain the benefit of                                                                  wwww       (e)(1)(ii).
                                                                                                             58
                                                                                                                Student Loan Law, p. 58.
                                                                                                             59
                                                                                                                20 U.S.C. § 107-6(b)
              The payments must be voluntary and on-time. “On-time” means payments are made                     (emphasis added).
              within 15 days of the scheduled due date. “Voluntary payments” “do not include                 60
                                                                                                                Id.
              payments obtained by income tax offset, garnishment, or income or asset execution.”61          61
                                                                                                                34 C.F.R. § 685.102(b).
       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                                l
                                                                                                      10   l




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                                                                                                                                      s
                                                               -coo                                                             -coon
                                                     -lo aans s-c
                                                              n                                                              ans s-c
                                                                                                                         -lo a n
                                        A borrower ee-lo cure a default by “rehabilitation.” To get rehabilitation,lthe ee-lo
                                               lelgg also
                                                    can                                                             elggbor-
                                             ol e
                                        rower ol                                                                ol e
                                         w.c
                                       www.cmust make twelve timely monthly payments. Once a loan is ww.c w.c ol
                                                                                                        wrehabilitated, the
                                      wwborrower is eligible for new federal financial assistance.    ww

                                          E.     Loan Consolidation

                                         Loan consolidation may also be available and can be a great alternative. It is available
                                         both before and after a loan goes into default. One disadvantage of consolidating a loan
                                         after it has gone into default is that an 18.5 per cent collection fee is added to the
                                         amount due.

                                         Consolidation plans should be treated as a refinancing agreement and payment plans
                                         are set by the DOE. There is both a Direct Consolidation Loan and a FFEL Consolida-
                                         tion Loan. As long as a borrower has at least one outstanding Direct Loan or FFEL, the
       orgg                                                                        org Loan and consolidate all outstanding
                                         borrower can apply for a Direct Consolidationg
at t on r
  ioin. .o                                                                        n r
                                                                             ioin. .o
                                         loans, including Perkins Loans. dat t o
                                                                        62

da                                                                  sololida
                                                                         i                                                             ida
                                                                                                                                    sololid
                                                                  onns                                                            onns
                                        Generally speaking,ns-c co
                                                            fors- income borrowers, the Direct Consolidation Loan will be ns-c co
                                                                low                                                             s-
                                                          a n                                                             loa n
                                        preferable gealooa Consolidation Loan, because under the FFEL program, payments a
                                                   to - -l
                                                      eFFEL                                                           ge- -lo
                                                                                                                         e
                                                 e g                                                               le g
                                        must ollleast cover accruing interest.63 However, for a Direct ConsolidationllLoan, the
                                           .c c le                                                            .col e
                                         ww.atollevel of a borrower with income at, or below, poverty is www.co 64 The
                                       ww
                                      wwpayment                                                          $0
                                                                                                        wwwper month.
                                         consolidation plan will remove any default that was outstanding prior to the adoption
                                         of the plan and a re-evaluation of the borrower’s financial situation will occur each
                                         year to adjust the payment level accordingly. After 25 years of compliance with the
                                         consolidation plan the entire loan is considered paid in full, even if the payments were
                                         zero each year, 65 and the borrower’s credit report must be corrected.

                                         Consolidation applications can be found on-line at www.ed.gov/directloan. An on-line
                                         calculator will allow the student to determine monthly repayment levels before
                                         completing the consolidation application. The calculator can be found at www.ed.gov/
                                         DirectLoan/Repay/Calc/dlentry2.html.

          g VI.            Conclusion
                                                                                   .orgg
     n.or rg
        .o                                                                    tioinn.o
                                                                                       r
atioion
dat                                                                       id aat o                                                  ida
                                                                     n sololid                                                  nsololid
                                        While defaulted student-oons be a huge barrier to financial independence, there s-coons
                                                            ns-cloans canto the borrower. The borrower can either seek ltoanns-c
                                                       of a n
                                        are a number -looptions
                                                                   c
                                                               s available
                                                     ee-loa                                                              - ooa
                                                                                                                     eleg l
                                                  elgdischarged completely or develop an affortable repayment planlltogee-the
                                        have a loan g
                                                l
                                           .col e
                                         ww.col                                                               .co take
                                                                                                            ww. ol
                                        loan out of default. This is an emerging area of law which the BPA&O andcPABSS
                                       w
                                      www                                                                 w
                                                                                                         www
                                        projects need to be aware.
       62
          Student Loan Law,
          p. 84.
       63
          34 C.F.R. § 682.209(a)
          (7)(iv).
       64
          Id. § 685.209(a)(2).
       65
          Id. § 685.209(c)(4) (iv).
                             l
                                 11   l
                                          EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS

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                                                                                                           s
                                     ns-c co                                                         -coon
              MY NOTES ON TRANSLATING
                                  loaans
                                         - THIS TO PRACTICE:                                     ans s-c
                                                                                             -loloa n
                              ge- -lo
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                      www                                                        w
                                                                                www

              MY STATE CONTACTS:




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       EFFECT OF DEFAULTED STUDENT LOANS ON RETURN TO WORK EFFORTS                         l
                                                                                               12   l




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              Program on Employment and Disability
              School of Industrial and Labor Relations
              Cornell University
              331 Ives Suite
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              This publication is available in alternative formats. To request an alternative format, please contact us using
              the information provided above.This series of briefs are also available on-line in both text and pdf formats.
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