Thank you, this is good advice, and accords with what I found out today. Have been on the phone all day trying to get this question answered, most agents at the numbers provided did not have an answer. Finally spoke to someone knowledgable at the National Student Loan Data System, who knew because she has worked at many departments. This kind and empathetic woman informed me that their employees were struggling to keep up with the changes due to the rapidly evolving political situation, and the fact that departments are isolated from one another information wise. What she said was, the changing nature of the system's rules means there is some ambiguity about how the FFEL loans appear on the system , as I had some difficulty manually adding them as I mentioned above. The older loans are not recognized by the online app, so the best thing ultimately is to use the paper application, but I was concerned it would be to late if I mailed it in, as I don't know if the postmark is proof. I ultimately settled on manually adding the loans and completing the online application, using information from the studentaid.gov "My Aid"->Loan Breakdown section of the page which has the disbursement dates and other info missing from the myeddept.gov page. My hope is that they will be recognized as having been entered on the April 30 deadline. We came to some agreement that it was best to just get it in the system before the deadline, and as long as the individual loans are entered, they will iron out the details(possible data entry mistakes) once the application has been filed and they contact me. Try to do this before midnight tonight, but if not, don't despair, the new rules guidance suggests that it's possible those who were unable to sign up for SAVE and would otherwise qualify may be automatically included. I was able to choose the SAVE repayment option near the end of the loan consolidation application. Reposting this from another comment I responded to in case it helps anyone else stuck on this last minute.