TICAS Comments on the Revised “Alternative Documentation of Income” form for IBR and ICR
TICAS recently submitted comments on the revised “Alternative Documentation of Income” form for Direct Loan (DL) 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.
We appreciate that the Department of Education incorporated in the latest draft form some of the recommendations we submitted on April 12, 2012, but some of the changes to the layout and instructions make this revised form less clear and user-friendly than the prior draft. Our comments recommend specific improvements to reduce borrower confusion and improve the form’s effectiveness.