PILRAP - Frequently Asked Questions
General PILRAP Questions
What is PILRAP?
The Public Interest Loan Repayment Assistance Program (PILRAP) was established to assist graduates pursuing employment in the public interest who, because of their student loan burden, might be dissuaded from working in this traditionally lower-paying sector. Program participants receive PILRAP assistance in the form of a loan to aid in meeting student debt repayments for the year. PILRAP loans are forgiven at the end of each calendar year of qualifying public interest work. Participants must reapply each year for assistance.
How do I apply for PILRAP?
Complete the PILRAP application and return it with all required attachments by the application deadlines. To receive benefits, you must fulfill all eligibility requirements outlined on the program materials/website and be selected by the Financial Aid Office. Awards are made on a year-to-year basis and you must reapply each year for continued assistance and to retain program eligibility. The operation of PILRAP is dependent on the availability of funds, so eligibility itself does not guarantee that benefits, in whole or in part, will be received by the applicant. Although the law school will make every effort to continue making awards to eligible participants, prior receipt of benefits does not create an entitlement to future assistance. Applications are available each fall.
I just graduated this year. Can I apply for the program this year or do I have to wait one year?
All graduates are potentially eligible to apply for the program during the year that they graduate. Therefore, if you graduated in May 2014, you are eligible to apply for PILRAP-II in the fall of 2014, and receive funds in 2015, if you have secured qualifying employment. Applications are generally due in October and made available in August or September.
When do I have to re-pay my award if I leave the program?
If you leave your eligible employment before the end of the calendar year, you must inform the Financial Aid Office within thirty (30) days of the change in employment. You may be asked to repay the portion of the assistance that corresponds to any period of time during the calendar year in which you did not maintain qualifying employment. The repayment must be made within that same calendar year.
Would I owe taxes on PILRAP funds received from my school?
Generally, no, but please talk to your accountant for a definitive answer. You will not receive any tax forms in the mail from the school with regard to PILRAP awards. Please also see http://www.acslaw.org/acsblog/node/12506.
I worked in a judicial clerkship during my first year out of law school. I know that judicial clerkships are not eligible employment for the program, but does the year that I spent as a judicial clerk count against the 3-year window of eligibility?
No. While judicial clerkships are not considered eligible public interest employment for the program, regardless of the salary, the time spent in a judicial clerkship does not count against the 3-year eligibility window for entrance into the program. Your work as a clerk is eligible employment for Public Service Loan Forgiveness.
Will my spouse's income exclude me from the program?
It depends. For married applicants, the applicant's annual salary will be considered to be the greater of the following two values: the applicant's salary, or half of the total family salary.
If I am ineligible to apply for PILRAP this year, does that mean that I may never apply again?
Once you graduate from American University Washington College of Law (AUWCL), you have three years to enter the PILRAP program for the first time. Specifically, you must apply to enter the PILRAP program within three years of the January following your graduation. So, for instance, if you graduated in May of 2011, you would need to become a participant of the PILRAP program by January of 2015. Therefore, if you were a 2011 graduate who was ineligible for PILRAP in October of 2011, you would still be able to apply for the first time to the PILRAP program in October of 2012, October of 2013, or October of 2014.
In addition, if you have received PILRAP assistance in the past, you may take a leave of absence from the program, for any reason, and still return. A leave of absence may be necessary because you are unemployed at the time that the application is due, because you are working part-time at the time that the application is due, because you are working at a private law firm at the time that the application is due, or for any other reason which makes your employment ineligible.
Once you become a PILRAP participant, you may only take a leave of absence for a total of two years. Once you have been on a leave of absence for a cumulative total of two years, you will not be eligible for any more leaves of absence. Your participation in the program will need to be continuous from that point forward, or you will become permanently ineligible for participation. You do not need to submit any paperwork while on a leave of absence.
If you have no loan repayment obligation because your IBR amount is zero dollars every month, but you are in full-time eligible employment, then you can enter inactive status in the PILRAP program rather than taking a leave of absence. If you have never applied for PILRAP before, you must submit a complete application, indicating that you wish to be on inactive status. If you have completed a full application at some point in the past, and now wish to be on inactive status, you must annually turn in an Employment Verification Form and a statement that you wish to be on inactive status. While on inactive status, you will receive no assistance from the PILRAP program. There is no time limit as to how long you may be on inactive status. However, inactive status counts toward the ten year period during which you are eligible for PILRAP assistance.
What counts as full-time work for the purposes of the PILRAP program?
The PILRAP Program shall define full-time employment in the same manner as the federal Public Service Loan Forgiveness Program:
“If you only have one employer, you must meet your employer’s definition of full-time. However, for PSLF purposes, that definition must be at least an annual average of 30 hours per week…
If you have more than one employer during the same period of time, full-time employment is an annual average of at least 30 hours per week, determined by adding together the annual average number of hours per week for each employer. Each employer must qualify as a public service organization for the employment to be included in determining whether you are employed on a full-time basis.”
I received an LLM from AUWCL. May I apply for PILRAP?
Only JD graduates of AUWCL may apply for, and receive, PILRAP funding. If you received both your JD and your LLM from AUWCL, then you may apply for PILRAP if you are otherwise eligible. LLM graduates from AUWCL, who did not receive their JD from AUWCL, should familiarize themselves with the federal income-driven repayment plans and loan forgiveness plans, such as the Income-Based Repayment Plan, the Income-Contingent Repayment Plan, Pay As You Earn, and the Public Service Loan Forgiveness Program. For more information, visit: http://studentaid.ed.gov/repay-loans/understand/plans.
Can I receive PILRAP assistance if I work abroad?
If your work is located abroad but your employer is the US government or another qualifying employer under the Public Service Loan Forgiveness program, then you are eligible for assistance. If you are working for a foreign government or foreign non-profit, then you are not eligible for assistance, but you may take a leave of absence from the program. Please see the answer to “If I am ineligible to apply for PILRAP this year, does that mean that I may never apply again?”
Can I apply for PILRAP as a participant of the JD Distinguished Fellowship Program?
Yes, but you may not need assistance. If you apply for an income-driven repayment plan, you should explain on your application that your funding through the JD Distinguished Fellowship Program is limited and report your income for the 12 month fellowship. Your income-driven repayment obligation may be zero, in which case you do not need to apply for PILRAP assistance. Keep in mind that if you do not apply this year, you must apply within three years of the January after your graduation in order to gain entrance into the program. For those JD Distinguished Fellows who do apply for PILRAP, no signature is needed on the Employment Verification Form. If you have not secured employment when your JD Distinguished Fellowship ends, and you participate in an income-driven repayment plan, then you should alert your servicer/lender that your income is diminishing and ask for your monthly obligation to be recalculated. If you secure employment during the first year of your being in an income-driven repayment plan, you do not necessarily need to report the increase in income until your annual recertification (anniversary date). In other words, you are only required to update your salary with your servicer/lender once a year, unless told otherwise by your servicer/lender. You must update the Financial Aid Office with any information regarding a change in salary or employment status within thirty days.
I am a JD Distinguished Fellow who is applying for an Income-Driven Repayment Plan. Can I get a letter from the school stating that I am employed and verifying my salary?
Yes. You should contact Tino Fletcher in the Finance Office at firstname.lastname@example.org.
I am a JD Distinguished Fellow. Can I apply for the DC Bar Foundation's LRAP Program?
No. Your employer is American University, which is not a qualifying employer for the DC Bar LRAP Program.
Do I need to provide AUWCL with my spouse’s income information even though we file our taxes separately?
You will need to provide AUWCL with your spouse’s income information and tax return. AUWCL needs this information to calculate your annual salary because, for PILRAP purposes, your salary will be considered to be the greater of the following two values: your salary, or half of the total family salary. This is true regardless of whether you and your spouse file your taxes separately. The Financial Aid Office will realize that you filed separately based on the tax returns submitted.
May I redact my social security number from the documents that I submit with my PILRAP application?
Yes, you may. The Financial Aid Office will need your AU ID in order to process your application, but it does not need your social security information.
I am a joint degree student, and I will not finish my MA until the spring. Should I apply for PILRAP in October, before I finish my MA?
No. You should wait until after you have finished your studies to apply for PILRAP. So long as you are a student, your loans should not go into repayment. In addition, you may be entitled to a grace period once your studies are over. You will apply for PILRAP during the October after you finish with your studies. Having said that, if you are graduating in December, and you will be employed in eligible employment in January, you may apply for PILRAP in October.
I pay for a portion of my health insurance as a pre-tax salary deduction. Does that expense get subtracted from my salary for the purposes of determining my PILRAP eligibility?
PILRAP does not subtract your health insurance from your income when determining eligibility. If you make $76,000 annually, and $2,000 is deducted as a pre-tax cost for health insurance, you are not eligible for PILRAP.
Can I apply for PILRAP even though I am currently looking for a job?
In order to apply for PILRAP, you must be working full-time or have secured full-time employment that will begin by January 1.
I am employed as a clerk for the Executive Office for Immigration Review. Is that eligible employment?
No. Clerking for the Executive Office for Immigration Review counts as a time-limited judicial clerkship, meaning that although you are not eligible for PILRAP assistance, your window of eligibility to enter the program is not impacted during your clerkship. Your work as a clerk is eligible employment for Public Service Loan Forgiveness.
Do I have to turn in my whole federal tax return with my application or can I simply submit the first two pages of my 1040?
The whole tax return is required.
I asked for an extension from the IRS to file my taxes late. I will not have filed my tax return by the October 1 deadline for the PILRAP application. May I still apply for PILRAP assistance?
Yes, you may still apply. Please include a short addendum with your PILRAP application, explaining that you asked for an extension to file your taxes late. Once you do file your taxes, please update the Financial Aid Office with a copy and your eligibility will be determined at that time.
How do I submit my PILRAP application?
All application materials must be scanned together and emailed as a single attachment in an email (with the subject heading “PILRAP 2015 Application”) to email@example.com by Wednesday, October 1, 2014. Hard copies, faxes, and incomplete applications will not be accepted. An application is not considered submitted until the applicant receives a confirmation email from the Financial Aid Office. An applicant who does not receive a confirmation email within two business days of submitting the application must contact firstname.lastname@example.org to confirm receipt of the application. Late applications will not be considered.
Can I receive assistance from both PILRAP and another LRAP program, such as the DC Bar Foundation LRAP?
You can. Sometimes, the other LRAP will give you a substantial enough award that you will not be eligible for PILRAP assistance. If this happens, you may ask to go on inactive status with AUWCL’s PILRAP program. Please see the answer to the Frequently Asked Question “If I am ineligible to apply for PILRAP this year, does that mean that I may never apply again?” Other times, you may get assistance from both programs. If you apply for another LRAP, you must note that fact on your PILRAP application. The Financial Aid Office will not calculate your PILRAP award until you notify the Financial Aid Office of the outcome of your other LRAP application.
I have heard that many PILRAP participants are repaying their federal loans with an income-driven repayment plan while getting PILRAP assistance. What is an income-driven repayment plan?
An income-driven repayment plan ties your monthly debt repayment to your income. The U.S. Department of Education offers three types of income-driven repayment plans:
When should I apply for an income-driven repayment plan, if I plan to do so?
You should apply for an income-driven repayment plan in August or September after you graduate. The approval process may take 30-90 days. You should be aware that this may mean that you enter repayment before the end of your grace period. However, your payments should be manageable under the plan that you have chosen because they are based on your income. Furthermore, once you enter repayment, any payments will count toward the Public Service Loan Forgiveness Program if you are in qualifying employment for that program. You may also have the option to request that your servicer/lender wait until your grace period is over to approve your application for the repayment plan, although this may delay your PILRAP award disbursement.
PILRAP-II Questions (For Graduates of the Class of 2008 and After)
How does PILRAP-II work?
The Financial Aid Office assists graduates in making monthly payments under an income-driven repayment plan, or as if they were making payments under an income-driven repayment plan. The amount of assistance provided depends on each graduate’s income and on each graduate’s eligibility for different income-driven repayment plans.
The money lent to a graduate under the PILRAP program is forgiven at the end of the calendar year of service. Graduates must apply to the program annually to receive new awards.
Who is eligible for PILRAP-II?
To be eligible for PILRAP-II, an applicant must be an AUWCL graduate from the Class of 2008 or after and be employed full-time in a law-related capacity for a public interest employer. A public interest employer is considered to be 1) an organization qualifying for tax exemption under IRS Code Sections 501(c)(3), 501(c)(4) or 501(c)(5); or 2) a local, state or federal government agency or office. Judicial staff attorneys and permanent law clerks are eligible, but one- or two-year judicial clerkships are not qualifying employment for PILRAP.
Applicants must earn an annual salary of $75,000 or less and all loans borrowed must be in satisfactory repayment status. Both applicant and spousal assets will be considered during the application review and may preclude you from receiving a PILRAP award even if your salary is below $75,000.
Graduates must apply for the program within three years of the January following their graduation. Once a graduate is a participant of the program, the graduate can continue to reapply annually for up to ten years for continued loan repayment assistance.
Does my loan have to be in a particular repayment plan with the U.S. Department of Education (Standard, Graduated, Income-Contingent, Income-Based Repayment, Pay As You Earn)?
PILRAP-II awards are based on the payments calculated for either the Income-Based Repayment (IBR) plan or the Pay As You Earn (PAYE) repayment plan for all federal student loans. Participants are not required to select any particular repayment plan, but PILRAP-II awards will be based on estimated annual loan repayments that the graduate would make if enrolled in IBR, except if enrolled in PAYE.
I earn $76,000, but I contribute $2,000 to a retirement plan, which lowers my taxable salary to $74,000. Can I still apply?
Yes. Contributions to an employer-sponsored pre-tax retirement plan will be subtracted from the salary before determining eligibility.
Should I include my undergraduate federal student loans in my application?
Yes. The Financial Aid Office considers all federal student loan debt (law school, other graduate school, and undergraduate school) when evaluating the applicant's annual repayment obligation under the Income-Based Repayment (IBR) plan or the Pay As You Earn (PAYE) repayment plan.
If my income increases above $75,000, does that mean that I can never be eligible for PILRAP again in the future?
If your income increases above $75,000, you may preserve your ability to receive PILRAP assistance again in the future by entering inactive status in the program. In order to be on inactive status, you must still be employed full-time in qualifying employment. In other words, you would be eligible for PILRAP if it were not for the fact that you are making more than $75,000. If you have never applied for PILRAP before, you must submit a complete application, indicating that you wish to be on inactive status. If you have completed a full application at some point in the past, and now wish to be on inactive status, you must annually turn in an Employment Verification Form and a statement that you wish to be on inactive status. While on inactive status, you will receive no assistance from the PILRAP program.
There is no time limit as to how long you may be on inactive status. Being on inactive status counts toward the ten year period during which you are eligible for PILRAP assistance. So, for instance, if you receive PILRAP funding in 2012, and then go on inactive status starting in 2013 and lasting for nine years, then you will be terminated from the PILRAP program in 2022, having received only one year of assistance.
What happens if my income changes in the middle of the year?
Income changes must be reported to the Financial Aid Office. Based on your new income and any decrease to your repayment obligation, the Financial Aid Office will recalculate your PILRAP award, which may affect any upcoming disbursements or your annual award for the next calendar year, should you apply for PILRAP again.
If your income increases above $75,000, you will not receive any upcoming disbursements from the PILRAP program, and you may need to pay back any funds that you already received which have not yet been applied to your loans.
PILRAP-I Questions (For Graduates of the Class of 2007 and Before)
Who is eligible for PILRAP-I?
To be eligible for PILRAP-I, applicants must be an AUWCL graduate from the Class of 2007 or before and be employed full-time in a law-related capacity for a public interest employer. A public interest employer is considered to be 1) an organization qualifying for tax exemption under IRS Code Sections 501(c)(3), 501(c)(4) or 501(c)(5); or 2) a local, state or federal government agency or office. Judicial staff attorneys and permanent law clerks are eligible, but one- or two-year judicial clerkships are not qualifying employment for PILRAP. Applicants must earn an annual salary of $50,000 or less and all loans borrowed must be in satisfactory repayment status.
Does my loan have to be in a particular repayment plan with the U.S. Department of Education (Standard, Graduated, Income-Contingent)?
No. The Financial Aid Office uses a different repayment schedule formula than the U.S. Department of Education.
I earn $51,000 but I contribute $2,000 to a retirement plan, which lowers my taxable salary to $49,000. Can I still apply?
Yes. Contributions to an employer-sponsored pre-tax retirement plan will be subtracted from the salary before determining eligibility.
Can I include my undergraduate loans in my application?
Yes. Please see the PILRAP-I information webpage for a more complete list of eligible loans.