ED Requests Comments for New Public Service Loan Forgiveness Application, Revised Employer Certification Form
By Jill Desjean, NASFAA Policy & Federal Relations Staff
On December 15, 2016, the Department of Education (ED) issued a Comment Request for the newly-created Application and revised Employer Certification Form (ECF) for Public Service Loan Forgiveness (PSLF). The Application was created in anticipation of the first borrowers to attain PSLF eligibility on October 1, 2017, the earliest a borrower can have made 120 qualifying payments after October 1, 2007. The ECF has been in use for several years but has been revised.
NASFAA is preparing comments that will be submitted by the comment deadline of February 13, 2017. A summary of the draft comments are detailed below. We encourage interested members to submit their own comments to ED but ask that you also share your thoughts with us at [email protected] by February 6, 2017 to ensure that we represent the interests and concerns of our member institutions.
- NASFAA notes a change in terminology from qualifying employment to qualifying employer in “Section 6: Definitions”, which appears to have been made to accommodate the new subheading of Qualifying Employment Definitions. While acknowledging ED’s effort to better organize this section, NASFAA expresses concern that it may lead to confusion because the term qualifying employment is still used in the definition of full-time, which itself falls under the Qualifying Employment Definitions subheading, creating a circular reference. We suggest that, if the term qualifying employer is to replace the term qualifying employment throughout, that the definition of full-time be edited to incorporate the new term qualifying employer instead, in the interest of consistency with the rest of the form.
- ED changed wording in another definition, from public service organization to private not-for-profit organization, deviating from regulatory language. NASFAA suggests that the form maintain the same terminology as the regulations for consistency.
- NASFAA makes several suggestions for revising the order of sections, cross-references to other sections, and corrections to inconsistent or unclear language.
- NASFAA suggests that FedLoan be required to notify borrowers of their PSLF eligibility if they have made 120 qualifying payments and have not yet applied for forgiveness.
- NASFAA urges ED to allow borrowers to authorize multi-year IRS income verification in place of the existing requirement that borrowers re-apply for income-driven repayment plans annually.
- NASFAA urges ED to allow borrowers reporting zero income to be able to confirm their income by phone without submitting paper documentation.
- NASFAA acknowledges the limitations of an entirely electronic Application or ECF due to the challenges of obtaining signature authentication for employers but still suggests ED permit the borrower section of the forms be available electronically.
- NASFAA asks ED to provide borrowers with a reasonable estimate of the time it will take for their PSLF applications to be processed.
Publication Date: 1/27/2017
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