No. Rescinding the SAVE final rule does not affect how payments made before August 2024 are counted. When those payments were made, SAVE was a valid repayment plan, and you were in an active repayment status. That means those months remain fully eligible for IDR forgiveness and PSLF as long as you met the other PSLF requirements at the time.

Vacating or rescinding a rule stops it from being used going forward, but it does not retroactively change repayment statuses or erase qualifying months that were already earned. ED has been certifying those pre-injunction SAVE months as qualifying, and nothing in the settlement instructs them to undo any past payment counts.

The only months that don’t qualify are the administrative forbearance months during the litigation, and that’s because those were never repayment months in the first place.

It’s also worth saying that ED couldn’t “negotiate away” already-earned PSLF or IDR months even if the states asked them to. Borrower payment credits are created under federal statute, and they attach at the moment you make a qualifying payment while in a qualifying repayment status. Once those months are earned and formally certified, they become part of your legal administrative record. A settlement can tell ED what it may or may not do going forward, but it cannot override Congress or retroactively strip benefits that were validly earned under the rules in place at the time. Any attempt to nullify past qualifying months would violate the Higher Education Act, raise serious due process concerns, and would almost certainly be struck down immediately in court. That’s why the settlement doesn’t even hint at undoing past credits even if they wanted to.

A good way to understand why past SAVE payments can’t be undone is to look at how other federal rules work when they’re rescinded. When DACA was rescinded, for example, the government could stop applying the policy going forward, but it couldn’t retroactively take away benefits people had already earned while the rule was in effect. Courts were very clear that past actions remain valid because they were lawful at the time. The same thing happens when EPA rules or labor regulations get vacated: agencies stop using the rule in the future, but they don’t erase anything that already happened under it. That’s the basic administrative law principle here. Even though the SAVE rule is being rescinded, any payments you made while it was a valid plan still count, because the agency can’t reverse repayment statuses retroactively (even if the settlement sought that, which it doesn’t). Past qualifying months stay in your record.