Adjusted Gross Income (AGI) when consolidating loans for IBR?

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tyman123

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I graduated medical school in the summer and am now a first year resident. I'm in the process of consolidating my loans and want to take advantage of IBR and PSLF. I did not file taxes last year.

In the AGI section, I put down 0 since I assumed it's asking for last year's income (it was 0 because I was a medical student). However, a section a little later asks for current income. I have no idea what to put for this. If I enter 0 for AGI originally and put my current income in this section, the form says the 2 are incompatible. Should I put a half year income? Let's say I make 50k/year. Do I put down 25k since I will only have worked from July - December of this year?

I'm trying to basically pay $0 for my first year in loans and rely on PSLF in the future. Is this even possible? Someone please help!

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Since you did not file taxes last year, most likely you won't pay 0 this first year. You'll have to submit an income document which will show your half year income.
 
Would this just be my hospital's contract or some kid of sheet listing my income?
 
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Almost everyone I've talked to in real life recommends putting $0 down. Then a half years salary for the next year.
 
You can put down 0. But they usually ask for verification through tax returns. If you can't provide that, you have to submit alternative documentation which will likely require you to submit intern pay stub info.
 
Unfortunately, I don't think there's a way to pay $0 for the first year of IBR/PAYE anymore--you can't (or at least shouldn't) lie on a government form and say your current salary is $0, especially since, aside from the possible legal ramifications, in the unlikely event PSLF still is around, I'm sure the government will carefully scrutinize your application and history of payments/tax returns. If I recall (I tried consolidating/applying for IBR a few months ago, then decided to wait until closer to the end of my grace period and cancelled my application) the IBR forms asks if the AGI you listed accurately reflects your current situation, which it doesn't. In which case you then have to list your current income. In addition, everyone I've heard from (admittedly a small number at this point, as most are utilizing their full grace period and thus haven't consolidation/applied for IBR yet) that applied had to submit documentation of their income since it was their first year applying for the program.

It definitely used to be that you could use $0 for the first year of payments and half a year's salary for the 2nd (the program was new and loan servicers didn't think to ask new grads their current salary), but I don't think there's a way to do that anymore. I actually don't think PSLF will still be around for us to benefit, but if it is, the odds are it'll be such a large amount forgiven that Uncle Sam is going to look really carefully at our payment/tax return history, and I think it'd be worth it to play by all the rules. Depending on if you qualify for PAYE vs IBR, your payments should be on the order of $250-$550 or so a month, which isn't too bad. (Obviously $0 sounds better...). If you have a spouse/kids then that number will differ.

What you can try to do is when you submit your pay stub, also submit documentation (possibly signed by HR) that says you'll only be working there for half of this fiscal year. Some federal loan servicers might then halve your calculated AGI. That could possibly get you a $0 monthly payment, depending on your salary and family size, and if so, would then be kosher. I think that's worth asking your loan servicer about (ideally ask them via e-mail, so you have it in writing). Loan servicers are often very willing to help you out, so I'd ask them all the questions you listed here.
 
Is the IBR form the real one where AGI/all that matters? And does it magically appear once you consolidate? Or do you have to seek it somewhere?
 
Has anyone been able to successfully get $0 as their repayement if you had filed your taxes?
 
Has anyone been able to successfully get $0 as their repayement if you had filed your taxes?

I was just looking at the online IBR application, and unfortunately it specifically asks "Is your current income or your spouse's current income (if you and your spouse file a joint federal income tax return) significantly different than the income reflected above?" Assuming you filed taxes as a 4th year, the answer would be "yes." If you didn't file taxes, then you'd have to submit documentation of your residency salary anyway.

Unfortunately I believe this means the days of $0 as your repayment are over, unless you consolidate and apply prior to beginning internship. But I'm sure if anyone has success, and is able to do it legally/ethically, we'll hear about it.
 
In the past, people have definitely recorded a $0 income and been granted $0 payments that counted as IBR. This was before the shift to the new servicers, though, so I am unsure if this has stopped or if it did.

I have a resident friend who graduated from medical school in 2010, immediately waived the grace period to start future PSLF eligibility ASAP while his income was still low, wrote down on the forms that his new income would in fact be different than the previous year's just like it asked, and then submitted his residency contract as evidence of his new salary to stay honest. Nonetheless, they used his prior year tax forms to compute the IBR payment anyway. Like I said, this was before the shift to the new servicers, but it sounds like the current IBR form is not exactly different from the one they were using in 2010.

FWIW, said resident has to re-enroll for IBR every May, and despite getting a pay raise each July, they still compute the IBR payment based on the last calendar year which is a mix of a wage that represents 2 prior salaries rather than status quo at the time that the new IBR payment goes into effect.

I think the best thing to do is tell them last year's income was $0, which it was, and then tell them what your income is now and just see what happens. If you can't afford the IBR payment, consider forbearance.
 
I'm in the process of figuring it out too. I talked to a Great Lakes financial advisor (they talked to us at the end of 4th year) and she said that even if you didn't have a tax return from last year, you can go ahead and put 0 for income. I also talked to a Sallie Mae lady (my loan servicer), and she said its up to us to submit whatever info we want. I couldn't get a straight answer out of her though if it was ok or not, she just kept saying its up to us what we want to submit. It makes me nervous to lie about it but I'll see if I can figure a way around it
 
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I'm in the process of figuring it out too. I talked to a Great Lakes financial advisor (they talked to us at the end of 4th year) and she said that even if you didn't have a tax return from last year, you can go ahead and put 0 for income. I also talked to a Sallie Mae lady (my loan servicer), and she said its up to us to submit whatever info we want. I couldn't get a straight answer out of her though if it was ok or not, she just kept saying its up to us what we want to submit. It makes me nervous to lie about it but I'll see if I can figure a way around it

I would recommend getting that in writing (via e-mail I guess) if you're counting on loan forgiveness. If those programs are still around in 10 (PSLF), 20 (PAYE), or 25 (IBR) years, it's very possible that the government will heavily scrutinize the application, tax returns, etc.

The first time I called my servicer (FedLoan) they also said I could chose what I wanted. I called back because it sounded rather odd (it seemed like knowingly lying to the government to me, which is fraud...) and the servicer didn't sound that knowledgeable. The lady I spoke with the second time, who was extremely knowledgeable, said I would definitely need to mark my income as having changed (side note-she said in the future I don't if it's only a few thousand dollars difference), but that I could include a note with my salary documentation stating I'm only getting half a year's worth of income (since I'm only employed July-Dec of 2013), and that my IBR payments will be based on half my salary (which is what my 2013 tax return will reflect), which is nice.

The IBR application really is very specific with it's question regarding whether your tax return reflects your current income. If your loan servicer says it's ok to say it does when it doesn't or (in the case of not filing taxes the prior year) put your current income as $0 when it isn't, then I guess it's up to them (they're the ones calculating your IBR payments), but I'd definitely get something concrete in case it ever comes back to bite you. Personally I prefer to be on the safe side and not be charged with fraud someday, and the payments aren't that high, even when based on a full year's salary, but then, I'm not in NYC or anything.
 
I filed taxes in 4th year of medical school with a minimal AGI, then applied to consolidate loans in May of 4th year while checking the box for "delayed consolidation" which was processed in the middle of November. I supplied the ADOI form in May with the rest of the application and wrote truthfully at the time that I had $0 income, and that "I was optimistic that I would find employment after graduation." All those forms were accepted, my IBR application was processed in November and I was approved by my lender for $0 monthly payments. I called my lender and apparently government pays off accumulated subsidized interest quarterly. So far so good. Worst case I am finding a loophole in the system but I don't think I'm flirting with perjury or anything.
 
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I know I'm replying to an old thread, but in case anyone's still interested in newer information. I took the following from the IBR FAQs found at (http://studentaid.ed.gov/sites/default/files/income-based-repayment-common-questions.pdf)

Q19: What happens if my income as reported on my federal tax return changes after I begin repaying under IBR?
A19: As long as you remain on the IBR Plan, your loan holder will annually review your current income to determine whether you continue to have a “partial financial hardship” and, if applicable, to adjust your monthly IBR payment amount. If your income increases or decreases there will generally be a corresponding increase or decrease in your required monthly payment amount. [January 5, 2010]

So it looks like as long as you filed an income-tax return for $0 in your fourth year of medical school, you should be okay for 1 year thereafter. If you didn't file a tax return, only then will they ask for alternative documentation of income.
 
So it looks like as long as you filed an income-tax return for $0 in your fourth year of medical school, you should be okay for 1 year thereafter. If you didn't file a tax return, only then will they ask for alternative documentation of income.

Unfortunately that's not quite accurate. You still have to answer the question "Does this (the prior years tax return) accurately reflect your current income." Seeing as most of us apply for IBR when the grace period ends, around the fall of intern year, the answer is no. Most lenders require you to fill out the alternative documentation of income when you start IBR anyway.

At least that's what I can tell you from both me and fellow interns just going through the process. I wanted things to be kosher, and the customer service representatives, (except one-- see my above post) as well as a common-sense interpretation of the above question, all told me I had to say my prior tax return didn't accurately reflect my current income.

The only loophole I've heard of (unless you want to lie on the government forms), is applying for consolidation prior to starting residency, like Mbekweni did. This allows you to accurately (and ethically) say "yes" (your income is $0) and potentially start repayment in July (if the application gets processed right away). I know a few people who did this. You'd loose all the savings from Uncle Sam paying the interest on your subsidized stafford loans (only the interest you don't pay off), and you end up with a slightly higher interest rate (I think it rounds up to the nearest 8th of a percentage, or something like that.) You also lose the ability to pay down the higher interest loans first (GradPlus), though if you don't owe that much it might not be an issue.

On the flip side, you get that $0 payment and up to six additional months that counts towards PSLF.

From above posts, it sounds like some (such as crhine) were told by their loan servicer that they can use their prior year's tax return even if it doesn't reflect their current salary (I was told that at first). Personally that seems risky to me since you're not getting it in writing and the question on the IBR form is pretty specific, but if your lender says you can do it then I suppose you can do what your lender says. (Just try to call back and ask other representatives, because a lot unfortunately don't know what they're talking about when it comes to anything about your loans, especially how IBR works).

I'm hoping for PSLF (even though I don't think it'll still be around...), so I'm trying to play by the rules so that in the event PSLF is still around, the IRS or Dept of Ed employee, or whoever will review my application and discharge my debt, will look at my paperwork (and probably prior year's tax returns) and grant the forgiveness without too much hassle.
 
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The only loophole I've heard of (unless you want to lie on the government forms), is applying for consolidation prior to starting residency, like Mbekweni did. This allows you to accurately (and ethically) say "yes" (your income is $0) and potentially start repayment in July (if the application gets processed right away). I know a few people who did this. You'd loose all the savings from Uncle Sam paying the interest on your subsidized stafford loans (only the interest you don't pay off), and you end up with a slightly higher interest rate (I think it rounds up to the nearest 8th of a percentage, or something like that.) You also lose the ability to pay down the higher interest loans first (GradPlus), though if you don't owe that much it might not be an issue.

On the flip side, you get that $0 payment and up to six additional months that counts towards PSLF.

Remember that if you do the application while in Med school you can click a button for delayed processing so you don't lose any of your grace period benefits and you end up consolidating via your paperwork that has been held for months and enter IBR right at the time all your other peers are deciding what to do with their loans about 6 months after graduation.
 
Remember that if you do the application while in Med school you can click a button for delayed processing so you don't lose any of your grace period benefits and you end up consolidating via your paperwork that has been held for months and enter IBR right at the time all your other peers are deciding what to do with their loans about 6 months after graduation.

This is true, though I had some trouble with it because my loans were still in "in-school" status (and not eligible for consolidation) until a few days before residency orientation began, so I just wasn't able to apply in that middle-ground area where my loans were eligible to consolidate but prior to having an income. I'll bet if I deferred the processing my loans (I selected to process immediately) would have been eligible, but it's all water-under the bridge.

On the other hand, if you can do this, you might as well only delay the processing a month or two--that way you get the $0 payments, but you also start repayment earlier, which gets you closer to the 10-year's worth of PSLF (should it still be around and/or you're interested in it)
 
Unfortunately that's not quite accurate. You still have to answer the question "Does this (the prior years tax return) accurately reflect your current income." Seeing as most of us apply for IBR when the grace period ends, around the fall of intern year, the answer is no. Most lenders require you to fill out the alternative documentation of income when you start IBR anyway.

I'm hoping for PSLF (even though I don't think it'll still be around...), so I'm trying to play by the rules so that in the event PSLF is still around, the IRS or Dept of Ed employee, or whoever will review my application and discharge my debt, will look at my paperwork (and probably prior year's tax returns) and grant the forgiveness without too much hassle.

What if you waive your grace period and fill out that form in May/June before starting residency? So you can honestly say your current income is $0.
 
What if you waive your grace period and fill out that form in May/June before starting residency? So you can honestly say your current income is $0.

I think I've heard of some people trying that, with mixed success (waiving the grace period). I think the issue sometimes is you can't waive the grace period until it begins, so there may be just a short timeframe between graduation (technically the date that your school lists as your end-date, which is often a week or two after graduation) and start of residency. But if you can do that, and apply for IBR at that time, then your income would in fact be $0.
 
What if you waive your grace period and fill out that form in May/June before starting residency? So you can honestly say your current income is $0.

Yes you can do this. By clicking the button for delayed processing you can fill out the required paperwork in May and then have it all processed in November or December, allowing you to take advantage of your grace period. Just make sure that you have filed taxes for the year prior so lenders can access your adjusted gross income (AGI) from the IRS database.
 
What if you waive your grace period and fill out that form in May/June before starting residency? So you can honestly say your current income is $0.
Yes you can do this.
I think it's really important to point out that you cannot waive the grace period for Direct Loans. Not knowing this almost caused me to make an expensive mistake, so I hope this information helps others. For verification of this, (I talked with my loan servicer, FedLoan, but also see) the answer to question #18, here (https://studentaid.ed.gov/sites/default/files/public-service-loan-forgiveness-common-questions.pdf):

"Under the law that governs the Direct Loan Program, you may not waive the six-month grace period on a Direct Subsidized Loans or Direct Unsubsidized Loan that begins after you are no longer enrolled in school at least half-time. Direct Subsidized Loans and Direct Unsubsidized Loans only enter repayment at the end of the six-month grace period..."

Also, it goes on to specify this, relevant to those of us pursuing PSLF: "...Any payments made on a loan during the grace period, when you have no legal requirement to make payments, will be applied to reduce outstanding interest or loan principal and will not count as PSLF-qualifying payments."

My current understanding is that the only way around this mandatory grace period on Direct Loans is if you consolidate them; then the grace period is actually forfeited, and you can enter repayment (and IBR) on the consolidated loan as soon as it is processed (which takes a few months, it sounds like?).

Additionally, since you select the repayment method as part of the loan consolidation request, my current understanding is that if you submit the consolidation (and thus repayment method) request before you start residency, and select IBR, you can get $0 payments under IBR for the first year (assuming that you aren't making a significant amount of taxable income when you fill out the consolidation request).
 
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Also correct. Another interesting thing is that your IBR payments won't be adjusted until your tax returns come back the following year in April. So you should be able to get grace period until about December after med school graduation, then consolidate into $0 IBR for Decber through April of the following year for a total of roughly 16-19 months of no payments following med school graduation (my girlfriend is having her updates payments start July 1 based on her April tax return though the speed of the adjustment likely depends on individual loan service providers). Also important to note that each person should do an analysis on whether $0 per month works best for their own situation as interest is still accumulating and many people will just be deferring for a larger bill down the road.
 
Also, it goes on to specify this, relevant to those of us pursuing PSLF: "...Any payments made on a loan during the grace period, when you have no legal requirement to make payments, will be applied to reduce outstanding interest or loan principal and will not count as PSLF-qualifying payments."

My current understanding is that the only way around this mandatory grace period on Direct Loans is if you consolidate them; then the grace period is actually forfeited, and you can enter repayment (and IBR) on the consolidated loan as soon as it is processed (which takes a few months, it sounds like?).

So, if you consolidate the loans, then the 6 mo grace period is forfeited: you start repayment and in this case, those repayments DO count toward PSLF-qualifying payments?
 
Could you guys offer me some advice? I currently have about 180k in loans and I start residency in 2 weeks. I read this whole thread and was wondering which situation would be better:
1. To apply now for "delayed consolidation" so it processes after my grace is over (november 2014). My understanding is that if I apply now for "delayed consolidation," I can still get the $0 payments (my tax return was filed this year so I can use that) under an income repayment plan (either IBR or PAYE). If this works, how long will I have $0 payments? From November 2014-November 2015, or earlier?
OR
2. To apply for consolidation NOW and forfeit grace period. If I do this, I can get $0 payments but it'll start once the consolidation has been processed (my loan provider told me it'll take about 2 months). If this is the real time period, then will my $0 payments be for August 2014 - August 2015, or earlier?

Basically, my question deals with the benefits of the grace period. What are the full benefits of the grace period and is it worth forfeiting it? Also, is my understanding of both situations correct that I will get the $0 payments as long as I apply before I start residency?

Any and all advice will be greatly appreciated!

Thank you!
 
So, if you consolidate the loans, then the 6 mo grace period is forfeited: you start repayment and in this case, those repayments DO count toward PSLF-qualifying payments?
Yup, that's what I believe. If you learn anything more either way, please post and let us know, though!
Could you guys offer me some advice? I currently have about 180k in loans and I start residency in 2 weeks. I read this whole thread and was wondering which situation would be better:
1. To apply now for "delayed consolidation" so it processes after my grace is over (november 2014). My understanding is that if I apply now for "delayed consolidation," I can still get the $0 payments (my tax return was filed this year so I can use that) under an income repayment plan (either IBR or PAYE). If this works, how long will I have $0 payments? From November 2014-November 2015, or earlier?
OR
2. To apply for consolidation NOW and forfeit grace period. If I do this, I can get $0 payments but it'll start once the consolidation has been processed (my loan provider told me it'll take about 2 months). If this is the real time period, then will my $0 payments be for August 2014 - August 2015, or earlier?

Basically, my question deals with the benefits of the grace period. What are the full benefits of the grace period and is it worth forfeiting it? Also, is my understanding of both situations correct that I will get the $0 payments as long as I apply before I start residency?
These are all really good questions, which I would also like to know the answers to! That said, are you going to be utilizing PSLF? If you are, it would probably save you money, overall, if you start your qualified IBR/PAYE payments for PSLF as quickly as possible. This is because the more qualified payments you make for PSLF as a resident, when you have a lower salary, means the less IBR/PAYE payments you need to make for PSLF after residency (when you'll have a higher salary and have to make higher IBR/PAYE payments).
 
Also, here's a question I have: back in May, I applied for a Direct Consolidation Loan electronically through StudentLoans.gov. Part of the loan consolidation application was also applying for the repayment plan for the consolidated loan, and I had my AGI from my previous tax return electronically retrieved from the IRS (as it was accurate), for calculation for the IBR payment amount.

I've started residency now, and my Direct Consolidation Loan application process should be completed in about a week (my servicer is FedLoan). Does anyone know if FedLoan will request that I submit additional verification (or re-verification) of income for IBR after the consolidation process is completed next week? It would be a bummer to have applied for a consolidated loan and IBR early, when my income was $0, only to have FedLoan request my current income just a week after I've started residency, resulting in the higher IBR payment amount that I was hoping to avoid for this first year.

I called FedLoan and asked a customer service representative there, but the rep wouldn't give me a straight answer. :meh:
 
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I called FedLoan and asked a customer service representative there, but the rep wouldn't give me a straight answer. :meh:

They wouldn't even give me a straight or consistent answer about whether or not I had to mark the box about whether my tax returned reasonably reflected my current income, which would have meant $0 payments vs ~$350 monthly payments. In the end I played it safe and submitted my new income stubs and paid the $350/month.

In your case things are a little different--you already submitted your IBR/PAYE application. They will most likely calculate yours payments based on that--I doubt they will ask for current income (but if they do, you should provide it). However, I'd be willing to bet they'll catch on to the "consolidation loophole" at some point--just as most servicers now ask for current income when you re-enter repayment after your grace period ends, rather than accepting the prior year's tax return (which was presumably $0 for most borrowers).

I think the bigger question is, are you supposed to update your servicer whenever your income bumps up, or can you wait until the next yearly application. I doubt anyone would hesitate to provide new info if they lost a job or their salary fell, but I doubt many would notify their servicer if their income went up. I doubt it'd matter except perhaps for PSLF eligibility. I'd look at your MPN and the Dept of Ed's website on IBR/PAYE rather than ask your loan servicer--as mentioned above, they don't always give a consistent answer (ie., they don't actually know the real answer)

One thing I've learned--write down the days you call your servicer and the name of the representative you spoke with. That way in case anything ever comes back/doesn't get resolved at least you have a record you can refer to.
 
They wouldn't even give me a straight or consistent answer about whether or not I had to mark the box about whether my tax returned reasonably reflected my current income, which would have meant $0 payments vs ~$350 monthly payments. In the end I played it safe and submitted my new income stubs and paid the $350/month.
Yeah, that was probably smart--though it's so frustrating not to be able to get straight/consistent answers, in this case, I think it's because what "reasonably reflects" means hasn't been defined by the U.S. Department of Education (or through court cases, yet). At least, I can't find any definition of what "reasonably reflects" means, which is a fairly vague phrase!

In your case things are a little different--you already submitted your IBR/PAYE application. They will most likely calculate yours payments based on that--I doubt they will ask for current income (but if they do, you should provide it).
Yeah, I hope so--of course if they do ask, I'll provide it.

I think the bigger question is, are you supposed to update your servicer whenever your income bumps up, or can you wait until the next yearly application. I doubt anyone would hesitate to provide new info if they lost a job or their salary fell, but I doubt many would notify their servicer if their income went up. I doubt it'd matter except perhaps for PSLF eligibility. I'd look at your MPN and the Dept of Ed's website on IBR/PAYE rather than ask your loan servicer--as mentioned above, they don't always give a consistent answer (ie., they don't actually know the real answer).
Yeah, I definitely think that's good advice. While I don't know for certain, I'm pretty sure you are not required to update your servicer whenever your income increases. The only thing I've found in the federal IBR/PAYE/ICR application that relates to this, are these statements:

From page 6: "After entry into the IBR or Pay As You Earn plan, you must annually certify your family size and provide income documentation for determination of whether you continue to have a partial financial hardship. Your loan holder(s) will notify you of the deadline by which you are required to provide this documentation. Your monthly payment amount may be adjusted annually. The new payment amount may be higher or lower, depending on the income documentation and family size information you provide each year."
Note that the only reporting requirement it mentions is the annual re-certification of your family size and income documentation.

From page 7: "IMPORTANT INFORMATION ABOUT ALTERNATIVE DOCUMENTATION OF INCOME

YOU ARE REQUIRED to provide alternative documentation of your income if:
- You did not file a federal tax return for the either of the two most recently completed tax years; or
- You have been notified by your loan holder(s) that alternative documentation of your income is required.

YOU MAY provide alternative documentation of your income if your Adjusted Gross Income (AGI), as reported on your most recently filed federal tax return, does not reasonably reflect your current income, because, for example, of a loss of or change in employment by you or your spouse.

YOU ARE NOT REQUIRED to provide alternative documentation of your income if you can provide a copy of your most recently filed federal tax return or an IRS tax return transcript from either of the two most recently completed tax years; and that documentation reasonably reflects your current income."

Here, note that it specifically says you may provide documentation of your income if your AGI as reported on your most recently filed federal tax return is different from your current income, but it does not say that it is required (unless requested by your loan holder, it sounds like).

...I could be wrong, of course, but I feel like these statements make it pretty clear (right?) that the only reporting that is required is for the annual re-certification.
 
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Just an update and a question...
  • Update: my loans were approved for IBR with the $0 dollar monthly payment for the first year (so, for until July next year), as I'd hoped (yay!).
  • Question: so, when I have to recertify in 2015 for IBR, and the form asks me if my current income is significantly different than the income reported on my most recent (i.e. 2014) federal income tax return, do I have to say "no," since I was employed for only half the year in 2014, and the income on my 2014 tax return will thus be only half what my income in 2015 will be?
...It's weird having your monthly IBR payment amount being based on your previous year's income, when you recerify in the middle of the year...

EDIT: here's another way to put my question:
  • How do I compare my "current income" to the income reported on my "most recent federal income tax return" and decide whether the two are "significantly different"?

  • Should I multiply my current monthly income by 12 and compare that number to my gross income on my last federal income tax return?

  • Or, should I calculate what my total income has been from the past 12 months to the present and compare that number with my gross income on my last federal income tax return?
 
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EDIT: here's another way to put my question:
  • How do I compare my "current income" to the income reported on my "most recent federal income tax return" and decide whether the two are "significantly different"?

  • Should I multiply my current monthly income by 12 and compare that number to my gross income on my last federal income tax return?

  • Or, should I calculate what my total income has been from the past 12 months to the present and compare that number with my gross income on my last federal income tax return?

No one knows for sure, since there are no issued guidelines (that I'm aware of) as far as what "reasonably represents" means. I personally advocate a better safe than sorry approach, since it is a federal form. The way I would gauge it is this way:

Next June, take your current monthly income and multiple by 12 (for your yearly salary). If that is close to what your total pre-tax earnings on your tax return for 2014 was, then put on the form that your tax return accurately reflects your current income. (I've had customer service reps tell me a couple thousand dollars difference is fine). The issue here is your tax return will only reflect half a year's salary, so the safe way to go is to say it doesn't accurately reflect your current income, and then submit proof of your current income, which will obviously come with a higher repayment.

Typically what this means is that most residents will need to submit proof of income when they start repayment (since most will start in December, after the grace period ends, unless they consolidate in June/July), and then again the following year. After that, subsequent tax returns will reflect an entire year's worth of earnings and should be within $1000-$2000 of their current income. Obviously if someone's spouse gets a raise (or stops working) that changes the equation, in which case you just submit proof of current income (and/or a signed statement that your spouse is unemployed).

You could of course risk it and just say your salary next June is accurately reflected on your 2014 tax return--I honestly don't think anything would come of it. And it would give you a very small payment. But since it's a federal form, when I applied I personally didn't want to be guilty of fraud, plus if forgiveness sticks around I figured it's best to always err on the side of caution.
 
Maybe it's just me, but I think that you get 1 full year before having to re certify. So by consolidating in December after graduation you get until at least December of the following year. I filed for delayed consolidation in May of my 4th year in med school, application processed/consolidation in November and $0 monthly payments decided and starting December 6 months later. It's now July and the loan servicer hasn't said a word about my April 2014 tax returns or adjusting my $0 payments for the coming year. I am hopeful that I will get even more time and not have income re-evaluated until next years 2014 tax return.

If that's the case (based on my girlfriends experience of April Tax return, adjusted payment starting August 1 afterwards) I might have $0 monthly payments until August of 2015- 2 years after graduating from med school!
 
Maybe it's just me, but I think that you get 1 full year before having to re certify. So by consolidating in December after graduation you get until at least December of the following year. I filed for delayed consolidation in May of my 4th year in med school, application processed/consolidation in November and $0 monthly payments decided and starting December 6 months later. It's now July and the loan servicer hasn't said a word about my April 2014 tax returns or adjusting my $0 payments for the coming year. I am hopeful that I will get even more time and not have income re-evaluated until next years 2014 tax return.

If that's the case (based on my girlfriends experience of April Tax return, adjusted payment starting August 1 afterwards) I might have $0 monthly payments until August of 2015- 2 years after graduating from med school!
 
Maybe it's just me, but I think that you get 1 full year before having to re certify. So by consolidating in December after graduation you get until at least December of the following year. I filed for delayed consolidation in May of my 4th year in med school, application processed/consolidation in November and $0 monthly payments decided and starting December 6 months later. It's now July and the loan servicer hasn't said a word about my April 2014 tax returns or adjusting my $0 payments for the coming year. I am hopeful that I will get even more time and not have income re-evaluated until next years 2014 tax return.

If that's the case (based on my girlfriends experience of April Tax return, adjusted payment starting August 1 afterwards) I might have $0 monthly payments until August of 2015- 2 years after graduating from med school!

Yes--you do get one full year before having to reapply for IBR. I think Hastible consolidated and opted for immediate payments. If he/she did that, the main advantage is they get another 6 months worth of low payments that qualify for PSLF (since everyone else will be using their grace period for the first six months of residency).

If your lender isn't asking for an updated tax return or updated proof of income, then as far as I know you don't need to provide it. Usually people will provide that info if their income falls since it would save them money, but I'm not sure if anyone actually submits that data if their income jumps.

I would however, make sure you reapply on-time each year--your lender won't tell you when you need to reapply for IBR, and if your IBR "anniversary date" is in Dec then you usually want to reapply around October/November to make sure your new application is processed on time--otherwise you will be switched to the standard repayment plan when IBR ends, and all your interest will capitalize. I've seen a few threads where people said this happened to them and they couldn't correct things retroactively. That can cost a fair amount of money in the end, and defeats two of the mean reasons to pursue IBR while in residency (maxing out on those low payments that qualify for PSLF, and preventing your interest from capitalizing until at least the end of residency).

My wife didn't have to reapply for IBR for almost a year and a half, because one more of her loans entered repayment during the middle of her IBR payment cycle, so her lender just extended her IBR anniversary date to a year after that loan entered repayment. She found out about this when she called to ask when she needed to reapply. I'd encourage anyone to do the same--$0 payments for two years would be really great, and maybe your lender has extended your IBR payment cycle, but I would check-in with them to make sure.
 
No one knows for sure, since there are no issued guidelines (that I'm aware of) as far as what "reasonably represents" means. I personally advocate a better safe than sorry approach, since it is a federal form. The way I would gauge it is this way:

Next June, take your current monthly income and multiple by 12 (for your yearly salary). If that is close to what your total pre-tax earnings on your tax return for 2014 was, then put on the form that your tax return accurately reflects your current income. (I've had customer service reps tell me a couple thousand dollars difference is fine). The issue here is your tax return will only reflect half a year's salary, so the safe way to go is to say it doesn't accurately reflect your current income, and then submit proof of your current income, which will obviously come with a higher repayment.
Thanks for your response, Bob--I find it unbelievable that no guidelines have been issued for what "significantly different" means, but I agree that your approach makes sense. My income is probably going to differ by a smaller amount in future years (like from ~$40,000 to ~$44,000), and I just wish I wasn't stuck with having to guess about whether this constitutes a "significant difference" or not. Of course, I could just submit Alternative Documentation of Income every time my income is different, but having IBR based off of gross income, instead of AGI is a really big difference sometimes (and can thus make a huge difference in the monthly loan payments, of course).

You could of course risk it and just say your salary next June is accurately reflected on your 2014 tax return--I honestly don't think anything would come of it. And it would give you a very small payment. But since it's a federal form, when I applied I personally didn't want to be guilty of fraud, plus if forgiveness sticks around I figured it's best to always err on the side of caution.
Yeah, I also asked my loan servicer (FedLoan) about this, and the representative literally told me that they would process the application regardless of what I chose about my income being significantly different or not, and that I should do whatever I feel most comfortable about. NOT HELPFUL! I took it to mean that they don't have any more of a clue than we do, though, about what "significantly different" means, since it just wasn't defined by Congress when IBR was created, apparently.

...Also, just to throw out another option, here's what someone else did, who was in a similar situation as us (still risky, but at least there is some protection?): http://askheatherjarvis.com/forums/viewthread/9175/
 
Thanks for your response, Bob--I find it unbelievable that no guidelines have been issued for what "significantly different" means, but I agree that your approach makes sense. My income is probably going to differ by a smaller amount in future years (like from ~$40,000 to ~$44,000), and I just wish I wasn't stuck with having to guess about whether this constitutes a "significant difference" or not. Of course, I could just submit Alternative Documentation of Income every time my income is different, but having IBR based off of gross income, instead of AGI is a really big difference sometimes (and can thus make a huge difference in the monthly loan payments, of course).


Yeah, I also asked my loan servicer (FedLoan) about this, and the representative literally told me that they would process the application regardless of what I chose about my income being significantly different or not, and that I should do whatever I feel most comfortable about. NOT HELPFUL! I took it to mean that they don't have any more of a clue than we do, though, about what "significantly different" means, since it just wasn't defined by Congress when IBR was created, apparently.

...Also, just to throw out another option, here's what someone else did, who was in a similar situation as us (still risky, but at least there is some protection?): http://askheatherjarvis.com/forums/viewthread/9175/

I had the same exact situation when I asked FedLoan! While an e-mail like the link you listed is always best ("get it in writing," right?), what I've gotten into the habit of doing each time I call my servicer is write down the date, the name of the person I spoke with, and what we talked about. It's not as good as actually having something in writing, but this way I've documented what we talked about.

In my case my income was jumping closer to $10-12K. I personally thought it was significant but different FedLoan representatives told me it was, it wasn't, and I could choose. I literally kept getting different answers from different people--I kept calling back because I really wanted them to all agree "it wasn't" so I could benefit from lower payments. So I decided to played it safe. But when my income jumps ~$2-3,000/year as a resident, I won't consider that significant, and I'll use the prior year's tax return.
 
Oh--for those that do submit documentation of your current income, make sure to send in a copy of your tax return and a letter explaining the deductions you took that lower your AGI--if you don't they'll just assume your salary is your AGI. The student loan interest deduction lowers your AGI by up to $2500--it's not huge, but that'll still decrease your monthly payments by a bit. Most people won't qualify for much because loans don't enter repayment until December (so maybe you pay off $200-500 in interest), but I made a voluntary $2500 payment to pay off interest before it capitalized (I think I got $400 back from Uncle Sam because of the deduction, I'm preventing 2500 in principle from accumulating interest, and also lowering my AGI slightly, so I thought it was a smart move since I could afford it). I know I got a tax benefit for moving expenses, but I can't remember if that actually lowered my AGI.

FedLoan actually took this into account when I submitted my alternative documentation of income, so it saves me a little bit each month. But I spelled it out for them and circled the relevant parts of my tax return.
 
Oh--for those that do submit documentation of your current income, make sure to send in a copy of your tax return and a letter explaining the deductions you took that lower your AGI--if you don't they'll just assume your salary is your AGI... FedLoan actually took this into account when I submitted my alternative documentation of income, so it saves me a little bit each month. But I spelled it out for them and circled the relevant parts of my tax return.
Oh, interesting! But if your annual recertification requires submitting alternative documentation of income, the application says to submit "one piece of supporting documentation for each source of income (your and your spouse’s). For example, documentation includes pay stubs, a letter(s) from your employer(s) listing income, interest or bank statements, or dividend statements..." You submitted a copy of your tax return as documentation, instead, though? If your tax return reflected your current income accurately, wouldn't it be unnecessary to submit alternative documentation of income, in the first place?

I would be really interested in hearing more specifics of how you did what did! :)
 
Oh, interesting! But if your annual recertification requires submitting alternative documentation of income, the application says to submit "one piece of supporting documentation for each source of income (your and your spouse’s). For example, documentation includes pay stubs, a letter(s) from your employer(s) listing income, interest or bank statements, or dividend statements..." You submitted a copy of your tax return as documentation, instead, though? If your tax return reflected your current income accurately, wouldn't it be unnecessary to submit alternative documentation of income, in the first place?

I would be really interested in hearing more specifics of how you did what did! :)

Sorry--I don't think I explained myself well. I submitted proof of my and my wife's income (paystubs). The reason I submitted a copy of my tax return with those documents as well (plus proof of my wife's student loan burden) was to show proof of the deductions I took that lowered my AGI--I figured that while my salary on my tax return might not represent my current income anymore, the deductions I was taking were still relevant. And part of me was hoping they'd take the easy route and just use the tax return instead of calculating our yearly income :)

Maybe all you need to do is write a letter saying your AGI is $2500 lower than your calculated salary because of the student loan interest deduction, for example, but I thought it'd help to send in proof.
 
So, I e-mailed the office of Federal Student Aid at the U.S. Department of Education this question:

I will be filling out the IBR Repayment Plan Request for annual recertification, and I have a question about question #9 (asked in Section 4 of the request), which asks:

"9. Is your current income or your spouse's current income (if you completed Section 3 or file a joint federal income tax return) significantly different than the income used to determine the Adjusted Gross Income (AGI) reported to the IRS on your most recently filed federal income tax return?”

To make sure I answer question #9 correctly, I need to know the answer to this question: how do I determine whether my "current income" is "significantly different" from the AGI on my "most recently filed federal income tax return"?

...And this is the response I received:

From: StudentAid <[email protected]>
Date: Tue, Jul 15, 2014 at 10:51 AM
Subject: 77 RE: Form submission from: Contact Us

Thank you for your inquiry about federal student aid.

You must reapply for the Income-Based Repayment (IBR) Plan each year by submitting documentation of your adjusted gross income (AGI) and family size. Each loan servicer will have its own documentation process.

If you did not file a federal income tax return, or if you believe that your reported AGI does not reasonably reflect your current income, the loan servicer may use other documentation to verify your income. For example, if you are now unemployed or are earning significantly less than your reported AGI, the loan servicer may consider your current income in determining your IBR payment amount.

You should contact your loan servicer directly to obtain additional information and the appropriate forms.

We hope this information is helpful.

E-Mail Unit
StudentAid.gov
Federal Student Aid

...So, I must submit documentation of my AGI, but if I can't or if I believe that my reported AGI does not reasonably reflect my current income, the loan servicer may use other documentation to verify my income. I'm not sure how to utilize this information, though... Maybe like how this person did? Select that my current income is not "significantly different" from the AGI on my most recent tax return on the application for annual re-certification, and then e-mail my loan servicer to inform them of any actual differences in my current income and my reported AGI, and leave the ball in their court to determine whether that difference is "significant"?

Hmm... Well, I could reply and ask a follow-up question (or even the original question again)--if any of you e-mail [email protected] about this, I'd be curious to know what responses you receive.

Alternatively, they did advise me "contact your loan servicer directly to obtain additional information and the appropriate forms," so, maybe I should e-mail FedLoan a question related to this, and see what they respond...
 
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I also had asked the same question on Answers.Ed.Gov, as I wasn't sure where I should direct my question, and it was forwarded to the office of Federal Student Aid at the U.S. Department of Education. So, I just got another response to them about the question I asked (see post above), which looks like it actually provides a clear answer (see sentence in italics and bold--my emphasis--below)!

From: "StudentAid" <[email protected]>
Date: Jul 16, 2014 7:45 AM
Subject: 77 RE: Incident #28022-32999 Forwarded Internally​

Thank you for your inquiry about federal student aid.

Your loan servicer may use alternate documentation of income if it believes that your adjusted gross income (AGI) does not accurately reflect your current ability to make monthly payments. If you believe your income is significantly different and you want your servicer to consider your current income, you may answer yes. If the servicer agrees, it may choose to use alternate documentation of your income. The decision is made by the servicer, not the U.S. Department of Education.

This office answers general federal student aid questions. We do not provide loan account information or perform loan servicing requests. You should contact your loan servicer directly for additional assistance.​

...

We hope this information is helpful.

E-Mail Unit
StudentAid.gov
Federal Student Aid​
 
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That's really interesting... I think a lot of what I've said about playing it safe and submitting proof of your current income might not be the best way to go. I think as long as you document what your lender tells you (and the service reps will usually give different answers since they don't really seem to know what they're talking about) then you could use a $0 tax return from 4th year, and a half-year's salary from intern year to get two years of low payments (assuming your lender doesn't ask for current proof of income).
 
That's really interesting... I think a lot of what I've said about playing it safe and submitting proof of your current income might not be the best way to go.
Yeah, I thought this was really interesting, too. Who knows, though, maybe this is just like our correspondence with FedLoan, and I'll get a different response, if I e-mail the U.S. Department of Education this question again. +pity+
 
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That's really interesting... I think a lot of what I've said about playing it safe and submitting proof of your current income might not be the best way to go. I think as long as you document what your lender tells you (and the service reps will usually give different answers since they don't really seem to know what they're talking about) then you could use a $0 tax return from 4th year, and a half-year's salary from intern year to get two years of low payments (assuming your lender doesn't ask for current proof of income).
This is the "magic" that paid financial advisor firms like GL Advisor have been using for years to help justify their fees. Or you can just file the paperwork yourself.
 
Any updates on this issue? 4th yr student and I am about to file my 2014 tax return with an AGI of $0 hoping that I will be able to use this when I apply for PAYE/ibr to get $0 repayments the first year. I feel like I would be too scared to put down that my current income has not significantly changed once I start residency. Anyone have any new info on this topic?
 
Any updates on this issue? 4th yr student and I am about to file my 2014 tax return with an AGI of $0 hoping that I will be able to use this when I apply for PAYE/ibr to get $0 repayments the first year. I feel like I would be too scared to put down that my current income has not significantly changed once I start residency. Anyone have any new info on this topic?

About two months ago I asked the Department of Education (the owner of our federal loans) and they said it's 100% up to your loan servicer to decide if you can check the box on whether your prior year's tax return is accurate or not, and it's up to them to decide what constitutes "significantly different." I then asked my loan servicer (FedLoan) the same question. I requested someone in administration answer my question since I got so many different answers over the phone, but honestly I can't be sure I didn't get another normal customer service rep. Either way, they said if your income has changed significantly (no particular definition given on that--but certainly going from $0/year to ~45K a year qualifies) that you do need to mark the box and provide your current income.

Here's my take: if you have any intent/hope of benefiting from any of the loan forgiveness plans, it's not worth risking all that just to save $300-$500 per month. Your monthly payment is eventually going to be that regardless because you reapply each year, so either you will be able to budget for that couple hundred dollars a month or you won't.

But, if you really want $0 payments AND want loan forgiveness, then e-mail your loan servicer (so that you get things in writing) and ask them what you should do. Then at least if they say "you're ok to use your $0 tax return" you have that documented in case anyone goes over those applications when/if your loans get forgiven. Not that it'll definitely help if that happened--but it might.
 
For that first year, your income goes from $0 a year to half of $45K a year. Is a change in income from one end of the poverty line for a family of four to the other end of the poverty line really "significant"? You're still considered poor either way.
 
About two months ago I asked the Department of Education (the owner of our federal loans) and they said it's 100% up to your loan servicer to decide if you can check the box on whether your prior year's tax return is accurate or not, and it's up to them to decide what constitutes "significantly different." I then asked my loan servicer (FedLoan) the same question. I requested someone in administration answer my question since I got so many different answers over the phone, but honestly I can't be sure I didn't get another normal customer service rep. Either way, they said if your income has changed significantly (no particular definition given on that--but certainly going from $0/year to ~45K a year qualifies) that you do need to mark the box and provide your current income.

Here's my take: if you have any intent/hope of benefiting from any of the loan forgiveness plans, it's not worth risking all that just to save $300-$500 per month. Your monthly payment is eventually going to be that regardless because you reapply each year, so either you will be able to budget for that couple hundred dollars a month or you won't.

But, if you really want $0 payments AND want loan forgiveness, then e-mail your loan servicer (so that you get things in writing) and ask them what you should do. Then at least if they say "you're ok to use your $0 tax return" you have that documented in case anyone goes over those applications when/if your loans get forgiven. Not that it'll definitely help if that happened--but it might.
Thanks for all your helpful advice on this topic. I really ignored my loans the first 3.5 years and am now just trying to figure everything out.
I also have fedloan as my loan servicer so i assume they will give me same advice but ill call and see what they say.
Also when you apply for paye/ibr and consolidation do you do it through the studentloan.gov website or through your loan servicer.
 
Thanks for all your helpful advice on this topic. I really ignored my loans the first 3.5 years and am now just trying to figure everything out.
I also have fedloan as my loan servicer so i assume they will give me same advice but ill call and see what they say.
Also when you apply for paye/ibr and consolidation do you do it through the studentloan.gov website or through your loan servicer.

It never hurts to call, and honestly your odds are 50/50 for them telling you exactly what I did vs them saying it's ok to say your $0 tax return accurately reflects your current income. If they say the latter, just make sure to document who you spoke with and when you spoke with them. Just in case you ever qualify for forgiveness and it becomes an issue. (Though, I make a habit of documenting any conversation with my lenders).

I believe you apply for PAYE/IBR through studentloan.gov. There should be a link through the FedLoan website that directs you to the website to apply, but I believe it's studentloan.gov. You may have to print that and fax it to your lender, depending on whether you need to supply supporting documents (ie, your spouses loans if you're married, current paystubs, etc.)
 
Any updates on this issue? 4th yr student and I am about to file my 2014 tax return with an AGI of $0 hoping that I will be able to use this when I apply for PAYE/ibr to get $0 repayments the first year. I feel like I would be too scared to put down that my current income has not significantly changed once I start residency. Anyone have any new info on this topic?

Many (most?) servicers are now asking for the alternative documentation of income (ADI) for new residents filing for IBR/PAYE, thus circumventing the question/possibility of using your $0 income to get a $0 payment. The old days of making $0 payments for one year and then half payments for the second year are gone/going away (still worked in 2012 when I graduated; I've written about it here). Most people I've talked to recently have had to make the full calculated IBR/PAYE payment once their grace period ended. If others have had a different experience I'd be interested to hear.
 
So i emailed my loan servicer fedloan with this question and this was there exact response:"Income-Driven Repayment plans are always based off of your current income and family size. If your income has changed since you filed your last tax return, you will be required to send copies of your two most recent pay stubs."
I hope to maybe get some loan forgiveness at the end so I definitely dont want to screw around.
At this point I dont even see the point in filling my 2014 income taxes with zero income( i have held on to it). I might as well let my parents claim me as a dependent and get their $500 or so rebate for me.
 
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