Systems and methods are disclosed for programming data in a non-volatile memory array are disclosed. Certain embodiments provide a non-volatile solid-state memory array and a controller configured to receive write data from a host device, program the write data to a first block of the memory array in a lower-page-only (LPO) programming mode, and perform a data consolidation operation on the first block, wherein said performing garbage collection comprises programming at least a portion of the write data to a second block not in LPO programming mode.