ED seeks comments on proposed IDR form changes (RAP option; due Aug. 7, 2026)

The U.S. Department of Education is seeking public comment on a proposed revision to the Income-Driven Repayment (IDR) Plan Request information collection/forms used for William D. Ford Federal Direct Loans and Federal Family Education Loan programs. The Federal Register notice was published July 8, 2026, and comments are due August 7, 2026 (docket ED-2026-SCC-1420).

This is a notice-and-comment process for a forms/information-collection update—not a final change you can assume is already locked in for every borrower’s specific IDR request.

What the IDR Plan Request form is used for

FSA uses the IDR Plan Request process when borrowers want to enroll in an IDR plan, recertify an IDR plan, or change their IDR option. The proposed update targets the borrower-facing questions and selections on that request.

What ED/FSA says it would change

In the July 8 notice, ED describes two main themes:

• Add the Repayment Assistance Plan (RAP) option. ED proposes updating the form so borrowers can select the Repayment Assistance Plan.
• Revise questions tied to “family size” / dependents. ED proposes revising the form’s family-size-related questions to “accurately gather” the borrower’s number of dependents, which ED describes as a component tied to the Repayment Assistance Plan.

How “family size” inputs work on the form (including unborn children)

ED/FSA’s borrower-facing IDR Plan Request form includes a Family Size Information section. It asks, for example:

• How many children, including unborn children, are in the family and receive more than half their support from the borrower.
• How many other people (excluding spouse and children) live with the borrower and receive more than half their support from the borrower.

ED’s proposed form update is grounded in the federal regulatory definition of “family size” used for IDR plans. The regulation defines family size by adding the borrower, and for qualifying households, includes items such as children (including unborn children who will be born during the year the borrower certifies family size) and other individuals who live with the borrower and receive more than half their support from the borrower.

Why ED/FSA links this to Direct Loan timing and a court action

ED says the form revision is meant to support statutory and regulatory changes affecting Direct Loans received on or after July 1, 2026. The notice also references that certain provisions regulated in 34 CFR 685.209 were invalidated due to court actions on March 10, 2026.

The notice also points borrowers to how the IDR framework is expected to shift: ED says the form would provide notice that PAYE and ICR plans will be sunset in 2028, and that the SAVE plan was removed in an earlier version of the form after a court injunction.

What to watch next (and what you can do during the comment window)

• Whether ED finalizes the revised form/information collection after comments. Until ED completes the comment process, treat the changes as proposed.
• When the updated form/instructions roll out. Borrowers and servicers generally move from draft/proposal to implementation only after ED completes the required steps after the comment period.
• If your income or family size changes. FSA says if an IDR plan’s monthly payment doesn’t reflect your current situation, you can submit updated information to request recalculation.

If you’re applying, recertifying, or preparing to update an IDR request around this period, the practical takeaway is simple: ED is actively shaping the borrower inputs and options that feed IDR processing—so the details you see on StudentAid.gov and through your servicer may evolve after the comment period ends.

Sources

• FSA Partners (ED) — Comment request on IDR Plan Request (July 8, 2026)
• Federal Register — ED IDR Plan Request comment request (Docket ED-2026-SCC-1420) (PDF)
• Federal Student Aid (StudentAid.gov) — Income-Driven Repayment (IDR) Plan Request form (PDF)