Biden Administration Student Loan Debt Relief Plan (2022)
On June 30, 2023, the United States Supreme Court struck down the Biden administration's student loan debt relief plan. In a 6-3 decision, the court ruled in Biden v. Nebraska that the 2003 HEROES Act did not provide the U.S. Department of Education with the authority to cancel parts of student loans on a large scale.[1] Click here to read more about the lawsuit, and click here to read more about the 2003 HEROES Act.
After the Supreme Court struck down Biden's 2022 student debt cancellation plan, the Biden administration announced several other student loan debt cancellation plans with more limited scopes. Click here to read more.
President Joe Biden (D) announced the three-part student loan debt relief plan, which aimed to offer "targeted debt relief as part of a comprehensive effort to address the burden of growing college costs and make the student loan system more manageable for working families," on August 25, 2022. The administration intended that the plan take effect before borrowers were required to resume payments on their student loans, which were first paused in response to the coronavirus in March 2020 by the Trump administration.[2] On June 3, 2023, Biden signed into law the Fiscal Responsibility Act of 2023, which raised the debt ceiling and contained a provision ending the repayment pause 60 days after June 30, 2023.[3] On June 12, 2023, a representative for the U.S. Department of Education clarified the timeline for the resumption of student loan repayments, stating, "Student loan interest will resume starting on September 1, 2023, and payments will be due starting in October. ... We will notify borrowers well before payments restart."[4]
Noteworthy elements of the plan included:[2]
- Cancellation of up to $20,000 of student loan debt for Pell Grant recipients and $10,000 for other borrowers making under $125,000
- A final student loan repayment pause through December 31, 2022[5]
- A reduction in monthly payment amounts and the coverage of unpaid monthly interest when a borrower makes monthly payments
- Expansion of employment types that qualify for the Public Service Loan Forgiveness (PSLF) program
- Increased oversight of higher education programs with high debt levels
- Only federal student loans held by the Department of Education would be eligible for debt cancellation.[6]
On June 7, 2023, Biden vetoed a joint resolution of disapproval passed by Congress that sought to void the student loan plan. Click here to read more about the resolution.
On this page you will find:
- Aftermath of the 2023 Supreme Court decision
- The text of Biden's announced plan
- Legal background of the plan
- Lawsuits filed challenging the plan
- Congressional actions related to the plan
- A timeline of federal student debt relief actions during the coronavirus pandemic
Aftermath
Following the Supreme Court's ruling, Biden announced he would seek to enact student debt cancellation under the authority of the Higher Education Act, and that borrowers would not risk default or harmed credit if they missed payments in the 12 months following the ruling.[7]
Biden announced the Saving on a Valuable Education (SAVE) in August 2023, which sought to reduce undergraduate loan payments, adjust loan payments to discretionary income, reduce interest, and provide early debt cancellation for low-balance borrowers.[8] In April 2024, Biden said he would cancel up to $20,000 of unpaid interest on loans, automatically cancel debt for individuals eligible for cancellation under existing policy, cancel debt for individuals who entered repayment 20 years previously, individuals who were enrolled in low-financial-value programs, and for individuals experience financial hardship.[9]
In April 2024, Missouri Attorney General Andrew Bailey (R) filed a lawsuit against Biden's SAVE plan.[10]
Text of the plan
The scroll box and collapsible sections below provide the text of Biden's Student Loan Debt Relief Plan announcement.[2] Further information on the plan can also be found on the Federal Student Aid explainer page.
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President Biden believes that a post-high school education should be a ticket to a middle-class life, but for too many, the cost of borrowing for college is a lifelong burden that deprives them of that opportunity. During the campaign, he promised to provide student debt relief. Today, the Biden Administration is following through on that promise and providing families breathing room as they prepare to start re-paying loans after the economic crisis brought on by the pandemic. Since 1980, the total cost of both four-year public and four-year private college has nearly tripled, even after accounting for inflation. Federal support has not kept up: Pell Grants once covered nearly 80 percent of the cost of a four-year public college degree for students from working families, but now only cover a third. That has left many students from low- and middle-income families with no choice but to borrow if they want to get a degree. According to a Department of Education analysis, the typical undergraduate student with loans now graduates with nearly $25,000 in debt. The skyrocketing cumulative federal student loan debt—$1.6 trillion and rising for more than 45 million borrowers—is a significant burden on America’s middle class. Middle-class borrowers struggle with high monthly payments and ballooning balances that make it harder for them to build wealth, like buying homes, putting away money for retirement, and starting small businesses. For the most vulnerable borrowers, the effects of debt are even more crushing. Nearly one-third of borrowers have debt but no degree, according to an analysis by the Department of Education of a recent cohort of undergraduates. Many of these students could not complete their degree because the cost of attendance was too high. About 16% of borrowers are in default – including nearly a third of senior citizens with student debt – which can result in the government garnishing a borrower’s wages or lowering a borrower’s credit score. The student debt burden also falls disproportionately on Black borrowers. Twenty years after first enrolling in school, the typical Black borrower who started college in the 1995-96 school year still owed 95% of their original student debt. Today, President Biden is announcing a three-part plan to provide more breathing room to America’s working families as they continue to recover from the strains associated with the COVID-19 pandemic. This plan offers targeted debt relief as part of a comprehensive effort to address the burden of growing college costs and make the student loan system more manageable for working families. The President is announcing that the Department of Education will:
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Legal background
In a memorandum released on August 23, 2022, General Counsel Lisa Brown outlined an argument for the Secretary of Education's legal authority to cancel and alter student loan debt requirements, which was overturned by the United States Supreme Court on June 30, 2023. Click here to read more about the case.
Brown said the Higher Education Relief Opportunities for Students (“HEROES”) Act of 2003 provides the authority to "'waive or modify any statutory or regulatory provision applicable to the student financial assistance programs' if the Secretary 'deems' such waivers or modifications 'necessary to ensure' at least one of several enumerated purposes, including that borrowers are 'not placed in a worse position financially' because of a national emergency." Many of the student debt repayment pauses of 2020, 2021, and 2022 also used the statutory authority provided by the HEROES Act.
In the memo, Brown argued that "several provisions of the HEROES Act indicate that Congress intended the Act to confer broad authority" and that "this authority could be used to effectuate a program of categorical debt cancellation directed at addressing the financial harms caused by the COVID-19 pandemic." This memo also requested that a previous memorandum issued during the Trump administration be rescinded.[12]
The January 2021 memorandum addressed the same legal question, whether the HEROES Act could allow the secretary of education to cancel student loan debt for a mass category of borrowers, but said the secretary could not pursue such debt cancellation. The January 2021 memo argued, "Congress never intended the HEROES Act as authority for mass cancellation, compromise, discharge, or forgiveness of student loan principal balances, and/or to materially modify repayment amounts or terms."[13]
Lawsuits
This section was last updated on August 14, 2023. See something we missed? Email us.
Nebraska v. Biden: Supreme Court overturns student loan debt relief plan
On September 29, 2022, six Republican state attorneys general, led by Nebraska Attorney General Doug Peterson (R), filed a lawsuit challenging the plan before the United States District Court for the Eastern District of Missouri. Along with Nebraska, Missouri, Arkansas, Iowa, Kansas, and South Carolina joined in the lawsuit. The plaintiffs said, "The Biden Administration’s Mass Debt Cancellation is yet another example in a long line of unlawful regulatory actions. No statute permits President Biden to unilaterally relieve millions of individuals from their obligation to pay loans they voluntarily assumed."[14]
On October 20, Judge Henry Autrey of the United States District Court for the Eastern District of Missouri dismissed the case.[15] The plaintiffs appealed the decision. On October 21, the United States Court of Appeals for the Eighth Circuit issued a stay temporarily blocking the program while the lawsuit was considered.[16] The court issued a nationwide injunction on November 14.[17] The Biden administration asked the Supreme Court to vacate the injunction on November 18.[18]
The Supreme Court announced on December 1 that it would take up the case.[19] This case was consolidated with Brown v. U.S. Department of Education on January 4, 2023.[20] The court ultimately issued separate rulings in this case and Brown v. U.S. Department of Education.
On June 30, 2023, the court ruled against the Biden administration, overturning the student loan debt relief plan. In a 6-3 majority opinion, Chief Justice John Roberts wrote, "Today, we have concluded that an instrumentality created by Missouri, governed by Missouri, and answerable to Missouri is indeed part of Missouri; that the words 'waive or modify' do not mean 'completely rewrite'; and that our precedent—old and new—requires that Congress speak clearly before a Department Secretary can unilaterally alter large sections of the American economy." Justices Clarence Thomas, Samuel Alito, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett joined in the majority opinion.[21]
In her dissent, Justice Elena Kagan wrote, "The majority’s opinion begins by distorting standing doctrine to create a case fit for judicial resolution. But there is no such case here, by any ordinary measure. [...] The opinion ends by applying the Court’s made-up major-questions doctrine to jettison the Secretary’s loan forgiveness plan." Justices Sonia Sotomayor and Ketanji Brown Jackson joined in Kagan's dissent.[21]
Badeaux v. Biden
On October 27, Tommy Badeaux, a Louisiana lawyer, filed a lawsuit challenging the plan before the United States District Court for the Eastern District of Louisiana. The plaintiff said, "Tommy seeks recourse in this Court to vindicate the Constitution and the Administrative Procedure Act and to stop an arbitrary and capricious wealth transfer that did not follow the rules."[22] The case was stayed on January 20, 2023, pending a Supreme Court ruling in similar cases.[23] On August 11, 2023, the case was voluntarily dismissed by all plaintiffs.
Brown v. U.S. Department of Education
On October 10, 2022, the Job Creators Network Foundation Legal Action Fund filed a lawsuit on behalf of two plaintiffs challenging the plan before the United States District Court for the Northern District of Texas. The plaintiffs said, "Without relief from this Court, Plaintiffs will be forever denied their procedural rights to protect their concrete interests. Because the Debt Forgiveness Program was adopted in violation of the APA [Administrative Procedure Act], the Program must be vacated and set aside and the Department should be enjoined from implementing or enforcing the Program in any manner."[24] On November 8, Judge Mark Pittman ruled that the program should be vacated.[25] The Biden administration filed an appeal.[26]
The Supreme Court took up the case on December 12, and consolidated it with Nebraska v. Biden on January 4, 2023.[27] The court ultimately issued separate rulings in this case and Nebraska v. Biden.
On June 30, 2023, in a unanimous opinion written by Justice Samuel Alito, the Supreme Court found that the plaintiffs did not have standing.[28]
Garrison v. U.S. Department of Education
On September 27, 2022, the Pacific Legal Foundation filed a lawsuit on behalf of Frank Garrison challenging the plan before the United States District Court for the Southern District of Indiana. The plaintiffs said, "Nothing about loan cancellation is lawful or appropriate. In an end-run around Congress, the administration threatens to enact a profound and transformational policy that will have untold economic impacts."[29] On October 21, 2022, Judge Richard Young of the United States District Court for the Southern District of Indiana dismissed the case.[30] The plaintiffs appealed the decision to the United States Court of Appeals for the Seventh Circuit, which rejected their request for an emergency injunction on the program.[31] The plaintiffs then appealed the decision to the United States Supreme Court. On November 4, 2022, Justice Amy Coney Barrett rejected the request for an emergency injunction.[32] The case was dismissed on July 6, 2023, following the Supreme Court's ruling in Nebraska v. Biden.[31]
Legislative action
The section below provides an overview of noteworthy federal legislative action in response to the Biden Administration Student Loan Debt Relief Plan. It was last updated on June 5, 2023.
H.R.3746 - Fiscal Responsibility Act of 2023
H.R.3746 - Fiscal Responsibility Act of 2023 raised the debt ceiling.[33][34] Additionally, this bill also contained a provision ending the pause of student loan repayments 60 days after June 30, 2023, and prohibiting the Department of Education from making any additional extensions. Biden signed this bill into law on June 3, 2023.[34]
The student loan repayment pause began on March 20, 2020, during the Trump Administration amid the coronavirus pandemic. It was extended eight times.[35]
The Fiscal Responsibility Act of 2023 codified a timeline previously established by the Biden Administration. Following the pause's eighth extension on November 22, 2022, the Biden Administration announced payments would resume 60 days after either June 30, 2023, or a Supreme Court decision on the Student Loan Debt Relief Plan, whichever came sooner.[3][36]
The bill was introduced by Rep. Patrick McHenry (R-Tenn.) on May 29, 2023. The House voted 314-117 to approve the bill on May 31, and the Senate voted 63-36 to approve the bill on June 1.[34] Click here to view roll calls of these votes.
H.J.Res.45 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans".
H.J.Res.45 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans". is a joint resolution of disapproval under the terms of the Congressional Review Act (CRA) passed by the 118th Congress seeking to void the Biden Administration Student Loan Debt Relief Plan.[37]
Biden vetoed this resolution on June 7.[37]
The House of Representatives voted 218-203 to approve the resolution on May 24, 2023, with two Democrats, Reps. Jared Golden (D-Maine) and Marie Gluesenkamp Perez (D-Wash.), and 216 Republicans voting in favor. The Senate voted 52-46 to approve the resolution on June 1, with Sens. Joe Manchin (D-W.Va.), Jon Tester (D-Mont.), Kyrsten Sinema (I-Ariz.), and 49 Republicans voting in favor. The resolution was introduced by Rep. Bob Good (R-Va.) on March 27.[37]
Timeline of student debt relief (2020-2023)
The following section provides a timeline of noteworthy student debt relief actions during the coronavirus pandemic. Timeline entries from April 19, 2022, and earlier were excerpted from a Congressional Research Service report.[38]
Biden administration (2021 - 2023)
- June 30, 2023: The United States Supreme Court overturned the student loan debt relief plan in a 6-3 majority opinion.[21]
- June 12, 2023: A representative for the U.S. Department of Education (DoE) clarified the timeline for the resumption of student loan repayments: "Student loan interest will resume starting on September 1, 2023, and payments will be due starting in October. ... We will notify borrowers well before payments restart."[4]
- June 7, 2023: Biden vetoed the Congressional Review Act (CRA) resolution of disapproval seeking to void the Student Loan Debt Relief Plan.[39]
- June 3, 2023: Biden signed the Fiscal Responsibility Act of 2023 into law, which raised the debt ceiling and contained a provision ending the pause of student loan repayments 60 days after June 30, codifying a timeline previously announced by the Biden Administration and prohibiting the Department of Education from making any additional extensions.[3][40] The repayment pause was initially established by the Trump Administration on March 20, 2020, amid the coronavirus pandemic, and extended eight times.[41]
- June 1, 2023: The Senate voted 52-46 to approve a Congressional Review Act (CRA) resolution of disapproval seeking to void the Student Loan Debt Relief Plan.[37]
- May 24, 2023: The House voted 218-203 to approve a Congressional Review Act (CRA) resolution of disapproval seeking to void the Student Loan Debt Relief Plan. Two Democrats, Reps. Jared Golden (D-Maine) and Marie Gluesenkamp Perez (D-Wash.), voted alongside 216 Republicans in favor of the resolution.[37]
- March 27, 2023: Congressional Review Act (CRA) resolutions of disapproval seeking to void the Student Loan Debt Relief Plan were introduced in the House and Senate.[42][43]
- November 22, 2022: The Biden administration announced it would extend the student loan repayment pause while court challenges to the debt relief program were ongoing. Biden said the pause would be extended no further than June 30, 2023.[44]
- November 14, 2022: The United States Court of Appeals for the Eighth Circuit issued a nationwide injunction blocking the Student Loan Debt Relief Plan (Nebraska v. Biden).[17]
- November 8, 2022: United States District Court for the Northern District of Texas Judge Mark Pittman ruled that the student loan debt relief program should be vacated (Brown v. U.S. Department of Education).[25]
- October 21, 2022: The United States Court of Appeals for the Eighth Circuit issued a stay temporarily blocking the student loan debt relief program while a lawsuit against it was considered.[16]
- August 24, 2022: President Joe Biden (D) announced his Student Loan Debt Relief Plan, which, among other policies, would cancel up to $10,000 or $20,000 of student loan debt. Biden also announced the final student loan repayment pause would end on December 31, 2022.
- April 19, 2022: The DoE announced the establishment of IDR plan account adjustments to provide credit toward loan discharge.
- April 6, 2022: The DoE announced an extension of the interest, payment, and collections suspensions through August 31, 2022. ED also announced that “all borrowers with paused loans” will receive a “fresh start on repayment by eliminating the impacts of delinquency and default and allowing them to reenter repayment in good standing.”
- December 22, 2021: The DoE announced an extension of the interest, payment, and collections suspensions through May 1, 2022.
- October 6, 2021: The DoE announced the establishment of the PSLF Limited Waiver, which expanded the types of payments borrowers could receive PSLF payment credit for through October 31, 2022.
- August 19, 2021: The DoE announced an indefinite extension of the suspension of the requirement that certain borrowers who received a Total and Permanent Disability (TPD) discharge provide subsequent earnings documentation during the three-year post-TPD monitoring period.
- August 6, 2021: The DoE announced an extension of the interest, payment, and collections suspensions through January 31, 2022.
- March 30, 2021: The DoE announced the suspension of interest accrual and involuntary collections on GA-held FFEL program loans, retroactive to March 13, 2020. The DoE also announced the transfer of some GA-held FFEL program loans that defaulted on or after March 13, 2020, to the DoE and the placement of such loans in good standing.
- March 29, 2021: The DoE announced a suspension, through the end of the COVID-19 emergency, of the requirement that certain borrowers who received a TPD discharge provide subsequent earnings documentation in accordance with the three-year post-TPD monitoring period. ED also announced that TPD loan discharges would be restored for borrowers whose loans were reinstated because they did not submit earnings documentation in accordance with the three-year monitoring period between March 13, 2020, and the end of the COVID-19 emergency.
- January 21, 2021: The DoE announced an extension of the interest, payment, and collections suspensions through September 30, 2021.
Trump administration (2020)
- December 4, 2020: The DoE announced an extension of the interest, payment, and collections suspensions through January 31, 2021.
- August 21, 2020: The DoE announced, in accordance with a Presidential Memorandum dated August 8, 2020, an extension of the interest, payment, and collections suspensions through December 31, 2020.
- March 27, 2020: President Donald Trump (R) signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law. The CARES Act suspended interest accrual, monthly loan payments, and involuntary collections on student loans through September 30, 2020. It also specified that suspended payments were to count toward the 120 monthly payments required under the PSLF program, toward the 20- or 25-year repayment periods under the income-driven repayment (IDR) plans, and toward the nine voluntary payments required for individuals to rehabilitate their defaulted loans.
- March 20, 2020: The DoE announced that all borrowers would automatically have their interest rate set to 0% for at least 60 days, each borrower would have the option to suspend their payments for at least two months, and borrowers who were more than 31 days delinquent on their loans as of March 13, 2020 would automatically have their payments suspended.
See also
- Joe Biden presidential administration
- Joe Biden's executive orders and actions
- Federal government responses to the coronavirus (COVID-19) pandemic, 2020-2022
Footnotes
- ↑ SCOTUSBlog, "Announcement of opinions for Friday, June 30," June 30, 2023
- ↑ 2.0 2.1 2.2 White House, "FACT SHEET: President Biden Announces Student Loan Relief for Borrowers Who Need It Most," August 24, 2022
- ↑ 3.0 3.1 3.2 Marketplace, "What the debt ceiling deal means for your student loans," June 2, 2023
- ↑ 4.0 4.1 Politico, "Biden admin will resume interest on federal student loans Sept. 1; monthly payments due in October," June 12, 2023
- ↑ The White House extended the repayment pause beyond this date.
- ↑ The Hill, "Lawsuits, shrunk eligibility take the shine off Biden’s student debt relief," October 2, 2022
- ↑ Twitter, "Biden on June 30, 2023," accessed July 3, 2023
- ↑ White House, "FACT SHEET: The Biden-Harris Administration Launches the SAVE Plan, the Most Affordable Student Loan Repayment Plan Ever to Lower Monthly Payments for Millions of Borrowers," August 22, 2023
- ↑ White House, "President Joe Biden Outlines New Plans to Deliver Student Debt Relief to Over 30 Million Americans Under the Biden-Harris Administration," April 8, 2024
- ↑ Fox Business, "Missouri AG files lawsuit over Biden's latest student loan handout attempt: It's 'illegal,'" April 9, 2024
- ↑ 11.0 11.1 11.2 11.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ U.S. Department of Education, "The Secretary’s Legal Authority for Debt Cancellation," August 23, 2022
- ↑ United States Department of Education Office of the General Counsel, "Memorandum to Betsy DeVos," accessed April 20, 2023
- ↑ Nebraska.gov, "Complaint," accessed October 5, 2022
- ↑ Springfield News-Leader, "Judge dismisses attempt by Missouri, other states to block Biden debt forgiveness program," October 21, 2022
- ↑ 16.0 16.1 NBC Chicago, "Appeals Court Temporarily Blocks President Joe Biden's Student Loan Forgiveness Program," October 21, 2022
- ↑ 17.0 17.1 CNBC, "Federal appeals court blocks Biden student debt relief program nationwide," November 14, 2022
- ↑ The Washington Post, "Biden administration asks Supreme Court to reinstate student loan forgiveness program," November 18, 2022
- ↑ ABA Journal, "Supreme Court will consider challenge to Biden's student-debt relief program, puts case on fast track," December 1, 2022
- ↑ SCOTUSblog, "Biden v. Nebraska," accessed January 17, 2023
- ↑ 21.0 21.1 21.2 Supreme Court, "Nebraska v. Biden," June 30, 2023
- ↑ Just the News, "Complaint," October 27, 2022
- ↑ PACER Monitor, "Badeaux v. Biden et al," accessed January 23, 2023
- ↑ Job Creators Network, "Complaint," accessed October 11, 2022
- ↑ 25.0 25.1 CNBC, "Federal judge in Texas declares Biden’s student debt relief plan unlawful," November 10, 2022
- ↑ Court Listener, "Brown v. U.S. Department of Education (4:22-cv-00908)," accessed November 14, 2022
- ↑ SCOTUSblog, "Department of Education v. Brown," accessed January 17, 2023
- ↑ Supreme Court, "Brown v. U.S. Department of Education," June 30, 2023
- ↑ Reason, "Garrison v. U.S. Department of Education," accessed October 5, 2022
- ↑ United States District Court for the Southern District of Indiana, "ENTRY DISMISSING PLAINTIFFS' AMENDED COMPLAINT," October 21, 2022
- ↑ 31.0 31.1 Court Listener, "GARRISON v. U.S. DEPARTMENT OF EDUCATION (1:22-cv-01895)," accessed October 31, 2022
- ↑ The Hill, "Barrett again denies emergency bid to block student loan forgiveness plan," November 4, 2022
- ↑ The New York Times, "Biden Signs Fiscal Responsibility Act in End to Debt Limit Crisis," June 3, 2023
- ↑ 34.0 34.1 34.2 Congress.gov, "H.R.3746 - Fiscal Responsibility Act of 2023," accessed May 30, 2023
- ↑ Forbes, "Biden Administration Extends Student Loan Payment Pause Amid Forgiveness Court Battle," Nov. 22, 2022
- ↑ Money, "Education Department Confirms the Student Loan Payment Pause Won't Be Extended Again," May 12, 2023
- ↑ 37.0 37.1 37.2 37.3 37.4 Congress.gov, "H.J.Res.45 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans".," accessed May 25, 2023
- ↑ Congressional Research Service, "Student Loans: A Timeline of Actions Taken in Light of the COVID-19 Pandemic," June 21, 2022
- ↑ Congress.gov, "H.J.Res.45 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans".," accessed June 8, 2023
- ↑ Money, "Education Department Confirms the Student Loan Payment Pause Won't Be Extended Again," May 12, 2023
- ↑ Forbes, "Biden Administration Extends Student Loan Payment Pause Amid Forgiveness Court Battle," Nov. 22, 2022
- ↑ Congress.gov, "H.J.Res.45 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans".," March 27, 2023
- ↑ Congress.gov, "S.J.Res.22 - A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Education relating to "Waivers and Modifications of Federal Student Loans".," March 27, 2023
- ↑ Cite error: Invalid
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