RAP vs. Legacy IDR: Side-by-Side Comparison
The new Repayment Assistance Plan (RAP) is worse for borrowers in almost every way. Here's exactly how it compares to IBR, PAYE, and ICR—and why consolidating before July 2026 matters.
The Key Differences
| Feature | Legacy IDR (IBR/PAYE) | RAP (New Plan) |
|---|---|---|
| Forgiveness Timeline | 20-25 years | 30 years |
| Payment Basis | Discretionary income | Gross income (AGI) |
| Income Protection | 150-225% of poverty line exempt | None—starts from $0 |
| Payment Rate | 10-15% of discretionary income | Sliding scale based on AGI |
| Minimum Payment | $0 if income qualifies | $10/month minimum |
| Dependent Deduction | Built into poverty calculation | Flat $50/month per dependent |
| Interest Subsidy | Varies by plan, some protection | No broad subsidy |
| PSLF Eligible | Yes | Yes |
Why RAP Is Worse
1. Ten More Years to Forgiveness
RAP extends the forgiveness timeline to 30 years (360 payments). That's a full decade longer than the 20-year forgiveness on PAYE, and 5 years longer than 25-year forgiveness on IBR.
2. No Income Protection
Legacy IDR plans protect income near the poverty line from being counted toward your payment. PAYE, for example, only counts income above 150% of the federal poverty level as "discretionary income."
RAP eliminates this. Your payment is calculated on your gross adjusted income starting from dollar one. For low-income borrowers, this means significantly higher payments.
3. $10 Minimum Payment
On IBR or PAYE, if your income is low enough, your payment can be $0—and that $0 payment still counts toward forgiveness. RAP imposes a $10 minimum, meaning no truly free months.
Any loans taken out after July 1, 2026 are only eligible for RAP—not legacy IDR plans. If you have existing loans that you want to keep on IBR or PAYE, do not consolidate them with any new loans taken after this date, or your entire balance becomes RAP-only.
Who Should Consider Pre-Cliff Action
Consider consolidating or locking in your plan before July 1, 2026 if:
- You have undergraduate loans and plan to take graduate loans after July 2026
- You have FFEL loans that need consolidation anyway (to become PSLF-eligible)
- You want to ensure all your debt stays on legacy IDR terms
The Strategic Consolidation
If you consolidate all existing federal loans into a Direct Consolidation Loan before July 1, 2026, that consolidated loan remains eligible for legacy IDR plans (IBR). Any new loans you take after July 2026 would be separate and RAP-only—but at least your existing debt is protected.
IBR Is the Survivor
Of the legacy IDR plans, IBR (Income-Based Repayment) is the only one that survives the OBBBA terminations. PAYE and ICR are scheduled for elimination on July 1, 2028. If you're currently on PAYE or ICR, you'll eventually need to switch to IBR or move to RAP.
For long-term planning, IBR is the stable choice among legacy plans.