Student Loan Forgiveness and Forms: The Devil is in the Details

Karen Gross
4 min readAug 25, 2022


The idea of student loan forgiveness, even if it is not the “full package” some in Congress and in the educational world desired is a positive outcome. And, there will be approximately 20 million borrowers positively impacted if the data are accurate.

So far so good.

Here is what is troubling to me and by this piece I hope to influence how this student loan forgiveness is implemented. Stories on the actual details of how the programs will be implemented will be forthcoming according to reports so it is not too late to chime in.

My worry is reflected in this quote from a Washington Post piece this a.m. by Honan and Ross, “Most people will need to fill out a form with the Department of Education.”

Can you hear a wee yeek? A form will be need by most students/graduates.

Forms and Forms

There are several reasons why forms worry me. Here are some of them.

  1. Some students/graduates will not get the needed forms and they will lose out on benefits.
  2. Some students/graduates will complete the forms incorrectly and will need to redo them several times, leading to time delays.
  3. Who will be handling and sorting and deciding on all the submitted forms within the Department of Education (when I worked there, this would have been a huge time suck given staffing)? Will there be huge delays?
  4. What information will be needed on the forms that is not already available through some other federal or state government database (IRS; Social Security; state taxing authorities)? Can these other databases be tapped and coordinated?
  5. What if there is disagreement, is there a form of appeal?

Sunstein and Thaler’s Nudges

Back in the Obama Administration, attention was given to the suggestions of Sunstein and Thaler about opt-ins and opt-outs. Basically, if you make something an opt-in, there are lots of folks who will not take the needed action, to their own detriment. If the offering is so good, why not make it automatic? And, folks know that many will forget or not take action, meaning that not all the monies will be distributed to those who are legally entitled to them. We have seen this in other government relief programs, sadly.

And, these scholars/advocates argued that if a benefit is offered (say on a credit card) and the holder of the card did not want it, they could opt out. And, since most folks would not opt out, the benefit goes to the many. Consider similarly if employers had mandatory allocations of an employee’s salary to a saving account (say 2%). If not desired, an employee could opt out. But, imagine the benefit to those who accrued savings?

To use the word of these scholar/advocates, why not help folks by nudging them in the right direction? Nudges work and they can be part of government policy.


Here’s a thought: The Department of Education needs to consider all federal (and perhaps state) databases that will yield the information needed to give loan forgiveness. Then, they need to have the benefits applied automatically — reducing or eliminating the student debt covered by the new program.

And, if there is some small percentage of students for whom these data are not available, have the government reach out — not the student reach in. And, then, if the government does not get hold of the student, there is a penalty for inaction and a pathway for students to reach in.

Some have estimated that the “automatic” forgiveness will be available to 8 of the 20 million some odd students/graduates affected. Seriously, that means 12 million students would need to apply to the Department of Education using some form. Even if the data points are off, asking 5 million students to apply is too many. The needed data are there — even if not housed in the Department of Education.

Shared databases is a big issue in DC and across the US. But, it is time to bust silos and have agencies work together for the benefit of the citizens. So, here’s a good place to start and as the regulations are crafted, make student loan forgiveness automatic with mandatory form filing in the rare — not the usual — case.

P.S. I dislike forms and their design — I think they often act as deterrents. So, I do have in addition to practical and policy and theoretical based reasons for no forms, a personal one too — although my loans are now all paid off (given my age).

PPSS. A special thank-you to Bill Reeve for discussing this issue with me and sharing his thoughts.



Karen Gross

Author, Educator & Commentator; Former President, Southern Vermont College; Former Senior Policy Advisor, US Dept. of Education; Former Law Professor