No, it’s not too late to implement your default aversion plan for the 2024 Cohort. The window closes soon.
Many institutions have not had to worry about CDRs over the last five years when payments were paused and delinquent students were placed into administrative forbearance to avoid default.
Fight a Three-Front CDR Battle
Federal Student Aid predicts 4 – 6 million new borrowers could default by September 2026. Institutions currently have to handle three cohorts—FY 2024, 2025, and 2026—all of whom are contributing to an expected record-high CDR year.
A detailed, cost-effective plan with absolute certainty of success is necessary immediately for all three cohorts.
1. The Deadline for the FY 2024 Cohort
This cohort includes the borrowers who entered repayment between October 1, 2023 and Sept 20, 2024, and who default between Oct 1, 2023 and Sept 30, 2026. This is where the defaults are occurring right now. The end of the monitoring period for the 2024 CDR calculation is September 30, 2026.
To mitigate your 2024 CDR, it’s imperative to cure as many borrowers in late-stage delinquency as possible over the next year.
2. The Threat of the FY 2025 Cohort
An additional 2.5 million new borrowers will enter the 2025 cohort. Delinquency here is starting at a catastrophic level.
- Borrower defaults began on October 1, 2025.
- This cohort is building from a base of over 40 percent delinquency already, with 10% or more already in technical default as of October 1, 2025.
- New confusion from the RAP (Repayment Assistance Plan) transition for post-2024 borrowers starts in July 2026, further complicating repayment.
3. The Strategy for the FY 2026 Cohort
Borrower default risk is projected to be high for both the 2025 and 2026 cohorts. A preventative plan must be in place now to stabilize these students as they move through the repayment lifecycle.
The 2026 cohort began for borrowers entering repayment after October 1, 2025 and will continue until Sept 30, 2026. Many of these students are still in school, making proactive default aversion easiest.
Institutions should have contact information for their in-school population and can put them on a sustainable repayment plan during their grace period before repayment begins.
The Sooner You Implement a Default Aversion Plan, the Better
The time for easy fixes is over. If your current delinquency rate exceeds 25%, we strongly recommend that you immediately hire a third-party servicer.
This urgency is driven by a critical servicing gap:
| Challenge | Impact on Default Aversion |
| Servicers Typically Stop Outreach at Technical Default | Institutions are on their own to contact borrowers who are 270+ days delinquent and help them before they reach 360 days. |
| Difficulty of Cure | Successfully curing a borrower who is 181+ days delinquent is extremely difficult, sometimes requiring up to 82 calls per contact. |
IonTuition provides the targeted intervention necessary to cure these difficult, late-stage accounts that the federal system has abandoned. You can also download a guide to federal student loan default aversion here.
Focus on Cures of Your Late-Stage Delinquencies
A successful default aversion plan targets the most at-risk accounts before the September 30, 2026 deadline:
- Immediate Focus: Identify borrowers who are 181+ days delinquent
- Strategic Outreach: Use customized campaigns, including strategic skip tracing to find current contact information, to reach borrowers who have been unreachable.
- Expert Management: Utilize a third-party partner to execute the high-volume, consistent contact efforts (like the 82 calls per cure) needed to move these borrowers into an appropriate repayment plan.
It is not too late, but the CDR measurement period for the 2024 cohort is underway. If you’re unsure how many delinquencies your institution has, request a CDR HealthCheck from IonTuition today!