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This blog contains our recommendations for improving and protecting the Total and Permanent Disability Discharge program for federal student loan borrowers. To learn about the structure and history of the program, read our program brief here.
Congress and the U.S. Department of Education (Department) have made sweeping changes to the federal student loan system this year, putting substantial new limitations on safety net programs for borrowers, including the income-driven repayment (IDR) system and loan discharge options for students who attended schools that closed and schools that engaged in misconduct. Lawmakers also imposed new borrowing limits for professional programs that could thwart the plans of prospective doctors, dentists, and lawyers from underrepresented communities, and Department officials are working to limit employer eligibility for the Public Service Loan Forgiveness (PSLF) program. These efforts threaten to reverse the progress policymakers have made over the past several decades to improve access to higher education and to protect borrowers from the devastation of student loan default.
Notably, however, policymakers have not proposed similar cuts to another safety net program for federal student loan borrowers: the Total and Permanent Disability (TPD) discharge program, which discharges loans for borrowers with severe disabilities who are unable to work.
In fact, recent operational changes to how the Department’s office of Federal Student Aid (FSA) processes TPD applications could yield positive outcomes for borrowers, following a history of other reforms that have expanded program eligibility and made it easier for borrowers to apply.
To maintain and build on this progress—as outlined in this piece—Department officials should do more to improve application processing, support a borrower’s designated representative in the TPD discharge process, increase outreach to eligible borrowers, regularly publish discharge data, and increase staffing to properly manage the TPD program.
Improve Processing
In the spring of 2025, as part of the Department’s Unified Servicing and Data Solution (USDS) initiative to improve federal student loan servicing, the Department completed its transition of TPD processing from loan-servicing company Nelnet to other contractors. For several months in early 2025, TPD application processing was paused and reportedly restarted in March. But according to recent media reports and complaints from borrower advocates, the transition has been riddled with problems.
Chiefly, the new contractors have been slow to process a growing backlog of TPD applications, resulting in some borrowers getting erroneous denials because their applications were signed by their medical provider more than 90 days ago. Other borrowers have waited months with no updates. During the processing periods, borrowers are entitled to a forbearance to stop their bills, but the contractors’ failures to apply the forbearance and misinformation from call center staff about forbearances have put borrowers at risk of delinquency and default.
The Department should clear the backlog of TPD applications and send timely communications to borrowers who have been waiting. It should also publish an update on its website when it is caught up from the transition and back to regular operations.
As the Department implements USDS, it should also be transparent with customers about which entities are involved with each aspect of program delivery. Although part of the purpose of USDS was to make things less confusing for customers, obscuring who is doing what is not good government. The Department should publish on its website an explanation of how TPD applications get processed and by whom, so customers can identify the companies or units within FSA that are responsible for errors or delays.
The Department and its contractors are supposed to track the reasons why a TPD application is rejected at any stage of the process and provide notification to the borrower. The Department should continuously study these rejections to identify issues that it can correct operationally or through improved outreach to customers. It should also hold listening sessions with borrowers, advocates, and attorneys to hear feedback on its TPD application processing.
Expand Outreach
Many borrowers receive TPD discharge without taking any action; the Education Department partners with the Social Security Administration and the Department of Veterans Affairs to identify qualified borrowers through data matching and automatically discharges loans. When TPD discharge is not automatic, borrowers must know about the program before they can apply. Although Federal Student Aid has improved the information available on StudentAid.gov, this may not be enough to reach people who have serious disabilities. The Department should invest in proactive outreach strategies to reach more eligible borrowers. For example, understanding the link between age, disability, and a growing population of older Americans with student loan debt, the Department should hold information sessions and debt clinics at senior living facilities, community centers, and other places where they can reach older and disabled populations.
Similarly, the Department should leverage its own data to conduct individual outreach. Recent research shows an alarming trend of default and forced collections—including offsetting Social Security benefits—among older student loan borrowers. The Department should send information about all available repayment and debt relief options, including TPD, to borrowers 65 years of age and older to prevent default. And, as the Department attempts to collect on defaulted borrowers, it should include information about TPD in its outreach.
It is not just borrowers who need to know about TPD. The medical professionals who complete TPD applications must also understand the program and their role in certifying a borrower’s disability. In 2024, the Department launched a FAQ-style website on StudentAid.gov with tips about TPD for medical professionals. The Department should do more to get this information to networks of medical professionals who commonly care for disabled and elderly populations.
Support Designated Representatives
People with significant physical or cognitive disabilities commonly rely on others to help them through administrative processes. The Department allows student loan borrowers to designate an organization or representative—including “a member of the borrower’s family, the borrower’s attorney, or another individual authorized to act on behalf of the borrower”—to assist with all aspects of the TPD discharge process. This includes the ability to give and receive information about the borrower’s TPD application over the phone and sending correspondence directly to the designated representative.
However, as the Department bolsters account security, it may be harder for designated representatives to manage a borrower’s TPD application. The Department must ensure that logistical and training barriers do not interfere with a designated representative’s access to the borrower’s account, which has reportedly been an issue in recent months. The Department must train its contractors to understand the rights of representatives and ensure that signed designated representative forms are consistently attached to the borrower’s account. Designated representatives should be able to communicate with call center agents with the same ease as the borrower.
Similarly, as the Department drives customers to rely on information and forms through StudentAid.gov student accounts, borrowers with disabilities may struggle with using the computer and internet. The Department should ensure that designated representatives are able, with the borrower’s permission, to access the borrower’s login and password.
Although the Department allows attorneys to be designated representatives for TPD, federal law may prohibit certain attorneys from accessing a borrower’s StudentAid.gov account, even with the borrower’s permission. The Stop Student Debt Relief Scams Act of 2019 permits an attorney who works for a government agency or a nonprofit organization and who is representing a borrower to access accounts, but it seems that an attorney hired by the borrower from a for-profit firm would not. The Department should issue guidance to clarify whom a borrower can allow to access their online account.
Publish Program Data
Between 2020 and 2025, the Department regularly published updates on the number of borrowers who received debt relief under its major programs, including TPD, PSLF, Borrower Defense, and Income-Driven Repayment. Nearly 633,000 borrowers received $18.7 billion in debt relief from TPD discharge during that time.
Publishing these numbers has the potential to boost public confidence in the Department’s programs at a time when borrower sentiment is low. The Department should add a data table to its Federal Student Loan Portfolio website with the number of borrowers receiving any type of forgiveness or discharge broken down by program, the number of loans discharged, and the total amount discharged.
Increase Staffing
The Department must retain adequate staff to keep the TPD program running and to implement program reforms, but the ongoing dismantling of the Education Department’s staff threatens the program’s stability. As of October 2025, roughly half the agency’s workers from the start of the year had been terminated or left.
Units within Federal Student Aid that were responsible for oversight of the student loan program and its servicers were heavily impacted by the reduction in force, which may explain the poor performance of the new TPD contractors. Meanwhile, Congress included a funding boost for student loan servicing in the 2025 reconciliation law, which suggests that lawmakers expect the Department to maintain adequate staffing and functions. The Department must ensure that it has enough qualified program experts and certified contract management staff to manage the TPD program.
The Education Department is not the only federal agency with a role in TPD. The Social Security Administration and Veterans Affairs must also maintain adequate staffing levels in their own disability benefits programs that connect with TPD. Significant staffing cuts are happening at these agencies; SSA announced plans to reduce its workforce by 7,000 employees, while the VA is slated to lose 30,000 employees. Recent reporting suggests veterans are already seeing delays and erroneous rejections of their TPD applications that may be the result of staffing issues at federal agencies.
Conclusion
The federal government has long promised debt relief to Americans with disabilities, and bipartisan efforts in Congress and across administrations have greatly improved the Total and Permanent Disability Discharge Program over the past two decades. During the second Trump Administration, hundreds of thousands of borrowers are likely to seek TPD discharge, and the Department must ensure the program works. As a priority, the Department must correct its course following the destructive dismantling of half its staff and the error-ridden rollout of its new TPD processing workflow to ensure borrowers with disabilities can access debt relief.
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