The rule
FFEL (Federal Family Education Loan), Perkins and HEAL loans can’t be repaid under RAP or Tiered Standard. If you also have Direct Loans, those can use the new plans while the older loans stay on a plan they qualify for, such as IBR for most FFEL loans.
To bring FFEL Stafford, FFEL Grad PLUS, FFEL consolidation (without parent PLUS) or Perkins loans into RAP, you consolidate them into a Direct Consolidation Loan.
A new consolidation loan is a new loan
A Direct Consolidation Loan made on or after July 1, 2026 can only be repaid under RAP or Tiered Standard, and receiving one puts all your Direct Loans under the two-plan rule. Consolidating after that date closes off IBR for your Direct Loans.
Payment counts
Qualifying payments on Direct Loans that go into a consolidation loan carry over as a weighted average (see consolidation under the 2026 rules). StudentAid.gov’s example: 60 payments on $30,000 plus 0 payments on another $30,000 becomes 30 payments on the new loan.
Parent PLUS in the mix
FFEL parent PLUS loans, and consolidation loans that include a parent PLUS loan, remain ineligible for RAP.
Not financial or legal advice. This page explains the published rules. It does not tell you which plan to choose. Your loan servicer and StudentAid.gov have the final word on your account.
Official sources
- StudentAid.gov: One Big Beautiful Bill Act – Important Definitions (updated Aug. 24, 2026)
- StudentAid.gov: SAVE Plan Borrowers – FAQs About Choosing a Different Repayment Plan (October 2026)
- 34 CFR 685.209, income-driven repayment plans (current eCFR, as amended May 1, 2026)
Last verified Oct 17, 2026. Corrections are logged on What changed.
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