By Louisa Woodhouse, Senior Associate, Policy and Advocacy
Reading time: Two minutes
On Monday, the National College Attainment Network (NCAN) submitted written comments to the US Department of Education as
part of the negotiated rulemaking process regarding the Trump Administration’s proposed changes to eligibility for the Public Service Loan Forgiveness (PSLF) program. Negotiated rulemaking, or “neg reg,” is a process through which federal agencies
engage members of the public and solicit feedback when drafting new rules and regulations.
As a refresher, on March 7, the Trump Administration published an Executive Order (EO) entitled, “Restoring Public Service
Loan Forgiveness,” which outlined plans to restrict access to PSLF by revising employer eligibility requirements – notably, for certain categories of nonprofit organizations (for more on that, see here).
Spoiler alert: this approach to PSLF eligibility is flatly at odds with the authorizing statute, which President George W Bush signed into law in
2007 to provide an incentive for public service work.
In addition to contradicting the statute, which affirms PSLF eligibility for employees at tax-exempt, 501(c)(3) nonprofit organizations, restricting access to PSLF would also limit access to the public services that keep students and families safe, healthy,
and on a path to realize their educational and economic dreams.
Industries and organizations across the country rely on PSLF to recruit and retain essential employees in hard-to-staff fields and geographic areas, such as teachers, nurses, and first responders. These professionals are among the largest groups that have received loan forgiveness under this program. The long-term investment in PSLF provides dividends to the American economy, encourages skilled workers to enter high-demand jobs and fills critical gaps in our nation’s workforce – particularly
those in rural areas. As a result of PSLF, children across the country are able to learn from talented teachers, students receive support from dedicated college access professionals, families have gained access to skilled healthcare providers, and
neighborhoods are safer.
To qualify for PSLF, borrowers must make 10 years of student loan payments while working for an eligible employer. An abrupt change to PSLF requirements would mean that Americans who have invested close to a decade of work as public servants, giving back
every day to support the advancement of our country, are left with no path to the loan forgiveness they were promised when they began their careers. Many borrowers participating in PSLF have made significant financial planning decisions supported
by their eligibility for loan forgiveness. In removing their access to PSLF, the Administration would fall short of this promise, doing a major disservice to a wide variety of essential workers, including employees at NCAN member organizations, and
the towns, cities, and states they serve.
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