TICAS Comments on the Draft “Alternative Documentation of Income” Form
TICAS recently submitted comments on the “Alternative Documentation of Income” form for Direct Loan borrowers in the Income Contingent Repayment (ICR) or Income-Based Repayment (IBR) plans. The form is used by borrowers whose adjusted gross income (AGI) is not available from the IRS or whose most recently reported AGI does not accurately reflect their current income.
To accurately and efficiently capture the income information needed to determine borrowers’ payments in IBR and ICR, this form must be as easy as possible for them to understand and use. Our comments recommend specific improvements to reduce borrower confusion and improve the form’s effectiveness.