The C.A.R.E.S. Act and its Influence on Student Loans

Published: August 17, 2022 • General

Introduction

In March 2020, the United States Congress passed the Coronavirus Aid, Relief, and Economic Security (C.A.R.E.S.) Act to mitigate the economic repercussions of the COVID-19 pandemic. The sweeping legislation, topping $2 trillion, included various provisions to support individuals, businesses, healthcare entities, and, notably, students with loans. With the pandemic disrupting employment and causing economic uncertainty, the C.A.R.E.S. Act offered much-needed relief to millions of student loan borrowers.

The C.A.R.E.S. Act’s impact on student loans cannot be overstated. Understanding these impacts is paramount for those with student loans, as these changes can significantly alter repayment strategies and financial planning. Furthermore, with the current discussions about student loan reforms, having a comprehensive understanding of the relief provided by the C.A.R.E.S. Act is crucial.

The Suspension of Loan Payments

One of the most prominent provisions of the C.A.R.E.S. Act was the suspension of payments for certain student loans. Specifically, the suspension applied to loans owned by the U.S. Department of Education, which included Direct Loans (both those disbursed directly to students and those made through the now-discontinued FFEL Program) and Federal Perkins Loans. However, commercially-held FFEL Program loans and school-held Perkins Loans did not qualify for the suspension, leaving a subset of borrowers without this relief.

The suspension of loan payments was initially slated to end in September 2020. However, the unprecedented nature of the pandemic led to multiple extensions, with borrowers not required to make payments for a considerable period.

The suspension of payments was not merely a deferment; it was unique in that interest did not accrue during this period. Typically, with deferments or forbearances, interest continues to accumulate, which can increase the total amount to be repaid over time. The C.A.R.E.S. Act eliminated this concern, providing genuine relief to borrowers during a time of economic uncertainty.

The Suspension of Collection on Defaulted Loans

The C.A.R.E.S. Act also addressed defaulted loans, an issue affecting many borrowers struggling to keep up with their payments. Under the Act, involuntary collections on defaulted student loans were suspended. This suspension meant that actions like wage garnishment, the offset of tax refunds, and the reduction of Social Security benefits were halted.

This provision was a lifeline for borrowers whose loans were in default. By suspending collections, the Act provided these borrowers with a temporary reprieve, allowing them to redirect their limited resources towards immediate needs during the crisis.

Moreover, the suspension of collections also had an impact on credit reporting. Ordinarily, defaulted loans can significantly harm a borrower’s credit score, affecting their ability to secure housing, obtain credit, or even find employment. However, under the C.A.R.E.S. Act, suspended payments were reported to credit bureaus as if they were regular payments. This change protected borrowers’ credit scores during the suspension period, providing additional indirect financial relief.

In conclusion, the C.A.R.E.S. Act brought substantial changes to the landscape of student loans. By understanding these changes, borrowers can be better equipped to navigate their loan repayment strategies and make informed decisions about their financial futures. As discussions about student loan reforms continue, the lessons learned from the C.A.R.E.S. Act will likely influence the direction of future policy.

Employer-Paid Student Loan Benefits

A lesser-known but significant provision of the C.A.R.E.S. Act was the introduction of employer-paid student loan benefits. Under this provision, employers can provide up to $5,250 annually towards an employee’s student loans, and these payments would be excluded from the employee’s income. In other words, employees would not have to pay income tax on these benefits. This provision was an extension of the existing educational assistance programs under section 127 of the Internal Revenue Code, which previously covered tuition, fees, books, and other supplies, but not student loan repayments.

Both private and public sector employers can offer these benefits, providing a new avenue for businesses to support their employees during the challenging economic climate. The inclusion of student loan repayments in employer education assistance programs represented a notable shift in the landscape of employee benefits, potentially influencing recruitment, retention, and overall employee satisfaction in industries where education costs and student debt levels are high.

From a tax perspective, the benefits are also excluded from the employer’s payroll taxes, providing tax savings for businesses. However, employers cannot claim a business deduction for these payments. Despite this, the provision can still be a valuable tool for employers looking to support their employees and enhance their benefits packages.

Impact on Public Service Loan Forgiveness (PSLF)

The C.A.R.E.S. Act also had implications for the Public Service Loan Forgiveness (PSLF) program. Under the PSLF program, borrowers who have made 120 qualifying payments while working full-time for a qualifying employer can have the remaining balance of their Direct Loans forgiven.

A significant concern for many borrowers in this program was how the suspension of payments would affect their progress towards the required 120 payments. The C.A.R.E.S. Act addressed this concern by stipulating that each month of suspended payments would count as a qualifying payment for PSLF purposes. This means that borrowers in the PSLF program effectively moved closer to loan forgiveness during the suspension period, despite making no payments.

The Current State of Student Loan Relief

Since the enactment of the C.A.R.E.S. Act, there have been several extensions to the suspension of payments and interest accrual. The most recent extension, at the time of writing, has set the end of the suspension period for August 31, 2022. These extensions have provided continued relief for borrowers during the ongoing economic uncertainty caused by the pandemic.

The employer-paid student loan benefits provision, originally set to expire at the end of 2020, has also been extended through 2025. This extension allows employers more time to implement these programs and provide tax-free student loan repayment benefits to their employees.

Discussions about further student loan relief continue at the federal level. Proposals range from additional extensions of the payment and interest suspension to broad student loan forgiveness. The Biden Administration has already enacted targeted loan forgiveness for borrowers with total and permanent disabilities and those defrauded by their schools, but broader loan forgiveness remains a topic of ongoing debate.

In conclusion, the C.A.R.E.S. Act and subsequent legislation have significantly altered the student loan landscape. Borrowers and employers alike should stay informed about these changes to take full advantage of the relief and benefits available. As the nation continues to grapple with the economic effects of the pandemic, and as discussions about student loan reforms continue, understanding the current state of student loan relief is more important than ever.

Conclusion

The Coronavirus Aid, Relief, and Economic Security (C.A.R.E.S.) Act has had a profound impact on student loans, bringing about significant changes that continue to affect millions of borrowers across the nation. From the suspension of payments and interest accrual to employer-paid student loan benefits and the influence on Public Service Loan Forgiveness, the Act has reshaped the landscape of student loans in ways that will likely be felt for years to come.

The broad scope and long-term effects of these changes underscore the importance of staying informed about student loan relief. As the nation continues to recover from the economic impact of the pandemic, and as discussions about future student loan reforms persist, understanding the current state of student loan relief becomes increasingly crucial.

Both borrowers and employers should familiarize themselves with these changes to fully benefit from the relief measures provided. Borrowers can adapt their repayment strategies and make informed decisions about their financial futures, while employers can leverage these benefits to support their employees and enhance their benefits packages.

The C.A.R.E.S. Act’s provisions, along with subsequent extensions and proposed future reforms, reflect a national recognition of the burdensome student loan debt problem. As we continue to navigate the economic fallout of the pandemic, these measures serve as a testament to the potential for legislative action to bring about significant relief.

In conclusion, the C.A.R.E.S. Act and its influence on student loans represents a significant chapter in the ongoing narrative of student loan policy. As we look towards the future, it’s crucial for all stakeholders – borrowers, employers, policymakers, and advocates – to carry the lessons from this period forward, shaping a fairer and more sustainable system for student loan borrowing and repayment.