MOHELA Billing Errors: How to Dispute Charges and Escalate

By Student Relief Solutions Editorial — Reviewed by Marcus Whitfield

MOHELA has been documented by the U.S. Department of Education to have caused billing failures affecting hundreds of thousands of borrowers — and if one of those errors is on your account, you can dispute it, escalate it, and, if necessary, file a formal CFPB complaint that creates a legal paper trail the servicer cannot ignore.

The short version

MOHELA (Missouri Higher Education Loan Authority) became the exclusive servicer for Public Service Loan Forgiveness (PSLF) accounts in 2022. Since taking over that role, federal records and enforcement actions have documented a pattern of billing errors, payment misapplications, and PSLF payment count discrepancies. The U.S. Department of Education withheld $7.2 million in servicer compensation from MOHELA following documented failures, including a 2023 incident in which approximately 800,000 borrowers did not receive timely billing statements, leading to delinquency on accounts that should never have gone past due. If your account shows a billing error, a wrong PSLF payment count, or an incorrect forbearance record, there is a defined escalation path. This guide walks through each step.

Documented MOHELA failure modes (sourced)

Before disputing, it helps to know which errors are documented — both because they're more likely to affect your account and because referencing them explicitly in a complaint can move your case faster.

• 800,000 late billing notices (2023): The Department of Education found that MOHELA failed to send timely billing statements to approximately 800,000 borrowers when student loan repayment resumed after the COVID-19 payment pause. Borrowers who never received a bill were reported as delinquent. ED withheld $7.2 million in servicer fees as a consequence. Source: Federal Student Aid announcement, Sept. 2023.
• PSLF payment count miscounts: The American Federation of Teachers (AFT) filed a federal lawsuit against MOHELA in 2023 alleging systematic errors in PSLF payment counts — including miscounting qualifying payments, failing to process Employment Certification Forms (Form ECF/Form 25) in a timely manner, and providing inaccurate count information to borrowers. Source: AFT v. MOHELA, U.S. District Court, E.D. Mo., filed 2023.
• Incorrect forbearance placements: Some borrowers have been placed in administrative forbearance by MOHELA without their request or consent, which can affect PSLF payment counts. Months in forbearance do not count as qualifying PSLF payments. Source: studentaid.gov PSLF guidance.
• Lost or unprocessed Form 25 (Employment Certification) submissions: CFPB complaint database records show a recurring pattern of borrowers submitting PSLF Employment Certification Forms that were not processed, acknowledged, or reflected in payment counts for 90+ days. Source: CFPB Consumer Complaint Database.
• Misapplied payments: Payments applied to the wrong loan type within an account, or applied as principal reduction instead of interest-first, can alter payoff timelines and PSLF count eligibility.

Step 1: Document what you have before you call

A dispute without documentation goes nowhere. Before picking up the phone, pull together:

• Your complete payment history from your MOHELA account portal (mohela.com) — export or screenshot every payment with date, amount, and application
• Your PSLF payment count history from the "PSLF Payment Tracker" in your MOHELA portal
• Copies of all Form ECF/Form 25 submissions with their submission confirmation numbers and dates
• Your loan servicer history from studentaid.gov — log in and check "My Aid" to see every servicer that has ever held your loans and when transfers occurred
• Any billing statements (or documentation that you did not receive one when expected)
• Proof of employer eligibility: PSLF Help Tool approval letters, employer certification letters

Step 2: Call MOHELA — what to say (literal script)

MOHELA customer service: 1-888-866-4352. Hours: Monday–Friday 7 a.m.–10 p.m. CT, Saturday 8 a.m.–6 p.m. CT.

"Hi, my name is [your name] and my account number is [your 10-digit MOHELA account number]. I'm calling because I believe there is an error on my account: [state the specific error — e.g., 'My PSLF payment count shows X qualifying payments, but my payment history shows Y payments that should qualify under my employer certification.']. I'd like to open a formal dispute case and get a case reference number. Per Federal Student Aid guidelines, I'm entitled to have this reviewed and corrected. Can you open a dispute and give me the case number before we hang up?"

What to do on the call:

• Write down the representative's name, the time of your call, and the call reference or case number they assign
• Ask for the expected resolution timeline in writing (servicers are required to provide this)
• Do not accept vague timelines — ask for a specific date by which you'll receive a written response
• If the rep says the issue is "under review" with no timeframe, ask to speak with a supervisor

Step 3: Follow up in writing within 5 business days

After the call, send a written dispute to MOHELA. Written disputes create a paper trail that matters if you escalate to CFPB. Use secure messaging inside your MOHELA portal or certified mail to:

MOHELA
633 Spirit Dr.
Chesterfield, MO 63005

Your written dispute should include:

• Your name, SSN (last 4), and account number
• A clear statement of the error (specific — "My PSLF qualifying payment count shows 87 payments; based on my payment history attached, the correct count should be 94 qualifying payments")
• Reference to your call: date, representative name, case number
• Attached documentation: payment history, Form 25 submissions, employer certifications
• A specific request: "Please correct my payment count and provide written confirmation of the corrected count within 30 days"

Step 4: If MOHELA doesn't resolve it within 30 days — escalate

The servicer has 30 days to respond to a dispute under the Fair Credit Reporting Act (for credit-reporting disputes) and Federal Student Aid program rules. If 30 days pass with no resolution or with an inadequate response, you have three escalation paths, and you should use all of them simultaneously.

Escalation path 1: Federal Student Aid Ombudsman

The FSA Ombudsman is an independent office within the U.S. Department of Education that handles unresolved loan servicer disputes. This is not a complaint line — it is a formal mediation office with authority to contact servicers directly.

• Online: studentaid.gov/feedback-center/ (select "Submit a complaint or feedback")
• Phone: 1-877-557-2575
• Mail: FSA Ombudsman Group, P.O. Box 1843, Monticello, KY 42633

When you file with the Ombudsman, reference your MOHELA case number, your written dispute letter date, and the documented ED finding (if applicable) — e.g., "MOHELA was found by the Department of Education to have failed timely billing in 2023; I believe my account was affected." This framing anchors your complaint in documented institutional failure, not just your word against the servicer's.

Escalation path 2: CFPB consumer complaint

The Consumer Financial Protection Bureau's consumer complaint database is public-facing and read by servicers' compliance teams. A CFPB complaint triggers a formal response requirement — servicers must respond within 15 days and resolve within 60 days.

• File at: consumerfinance.gov/complaint/
• Select "Student loan" as the product and "Federal student loan servicing" as the issue type
• Upload all documentation you have
• Be specific and factual — CFPB complaint staff review narratives and escalate to their enforcement team if patterns emerge

The CFPB complaint database is searchable by the public. A documented complaint creates a permanent record that supports any future legal action and strengthens FSA Ombudsman review.

Escalation path 3: State Attorney General

Your state AG's consumer protection office can pursue action against servicers that violate state consumer protection law. This path is slower but adds additional legal weight, especially in states with active student loan servicer oversight laws (Illinois, California, New York, Washington, and others).

• Find your state AG: naag.org/find-my-ag/
• File a complaint through your state AG's consumer protection portal

Special case: PSLF payment count disputes

If the error is specifically a PSLF payment count error, there is an additional pathway: the PSLF reconsideration process. As of 2025, Federal Student Aid accepts PSLF reconsideration requests for borrowers who believe their payment count is incorrect. Submit via:

• studentaid.gov PSLF reconsideration form
• Attach documentation showing why additional payments should qualify (employment certification, payment date records)

Note: Processing times for PSLF reconsideration currently run 3–6 months based on MOHELA's reported backlog. File early. File with documentation. Keep copies of everything you submit.

What to do if it goes wrong (realistic failure modes)

• MOHELA "resolves" the dispute in your favor on paper but the count doesn't update: Document the resolution notice date + the portal count date. Return to FSA Ombudsman with this discrepancy as new evidence.
• Complaint is closed without resolution (CFPB "company responded — closed without relief"): Reopen the complaint with additional documentation or escalate to FSA Ombudsman, referencing the CFPB complaint number.
• Forbearance placed on account during dispute: Administrative forbearance during dispute does not count as qualifying PSLF payments. Ask MOHELA in writing whether any months are being counted as forbearance instead of qualifying payments during your dispute period, and request retroactive correction if so.

Realistic timeline

• MOHELA initial dispute response: 7–30 business days (per MOHELA's published SLAs)
• FSA Ombudsman review: 60–90 days, potentially longer for complex PSLF count disputes
• CFPB complaint formal response: 15 days to acknowledge; 60 days to resolve
• PSLF reconsideration decision: 3–6 months based on current processing

Do not assume that filing one complaint will resolve your issue quickly. File all three escalation paths simultaneously once the 30-day servicer response window has passed.

Related resources

If your dispute involves a PSLF payment count error, read our guide to auditing your PSLF payment count in MOHELA. If you're working through a PSLF reconsideration, see our explainer on PSLF eligibility requirements in 2026.

This article was generated by AI under editorial supervision. All program rules and figures are sourced from primary government documents (studentaid.gov, CFPB, ED.gov). This is information, not financial advice — talk to a fiduciary or your servicer about your specific situation.