By Maria Carrasco, NASFAA Staff Reporter , Hugh T. Ferguson, NASFAA Managing Editor
Update: On Monday, the Department of Education (ED) said it was reviewing the White House’s executive order to revise the Public Service Loan Forgiveness (PSLF) program. “The PSLF Program is not changing today, and borrowers do not need to take any action,” ED wrote on X and LinkedIn. “To learn more about the current program requirements, see your progress and payment counts, or submit a PSLF form, visit http://StudentAid.gov/publicservice.”
President Donald Trump on Friday signed an executive order directing the Department of Education (ED) to make changes to the Public Service Loan Forgiveness (PSLF) program and rescind eligibility from organizations engaged in “illegal activities.”
The order calls on ED and the Treasury Department to propose regulatory changes to ensure that the definition of “public service” excludes organizations engaged in what the administration considers to be a “substantial illegal purpose.” However, ED is required by law to use the negotiated rulemaking process to develop new regulations for the Title IV programs, unless the Secretary determines that doing so is “impracticable, unnecessary, or contrary to the public interest.”
Trump said the Biden administration “abused” the program's implementation and “misdirected” tax dollars to activist organizations.
One of the Biden administration’s key efforts was overhauling the PSLF program – including its high denial rate and streamlining the application process. In total, the Biden administration granted PSLF to 1,069,000 borrowers, totaling $78.5 billion.
“The PSLF Program also creates perverse incentives that can increase the cost of tuition, can load students in low-need majors with unsustainable debt, and may push students into organizations that hide under the umbrella of a non-profit designation and degrade our national interest, thus requiring additional Federal funding to correct the negative societal effects caused by these organizations’ federally subsidized wrongdoing,” the order states.
According to the order, “substantial illegal purposes” would include: illegal immigration, human smuggling, child trafficking, pervasive damage to public property, and disruption of the public order.
Rep. Tim Walberg (R-Mich.), chair of the House Education & Workforce Committee, said that the order “is in line with House Republicans’ goal of delivering the reforms to PSLF that are sorely needed.”
“Committee Republicans have long had concerns about the open-ended nature of PSLF,” Walberg said in a statement. “This money has to come from somewhere—taxpayers, many of whom never went to college, are footing the bill for a program that provides hundreds of thousands of dollars in forgiveness to those making six figure salaries.”
Many outstanding questions remain about the order's impact and how it will be administered, particularly for borrowers whose employment has already been certified as PSLF-eligible.
Linda McMahon, who was confirmed as secretary of education last Monday, was questioned during her confirmation hearing about the implementation of PSLF. Sen. Tim Kaine (D-Va.) asked the then-nominee if she would continue to fully implement the program. McMahon, during the committee’s questioning, said ED would honor PSLF and other loan forgiveness programs created by Congress.
“So your commitment is, should you be confirmed, you will fully implement existing Public Service Loan Forgiveness programs that have been passed by Congress,” Kaine asked.
“Those that have been passed by Congress? Yes, that's the law,” McMahon said in response during her confirmation hearing.
In response to Trump's executive order the National Student Legal Defense Network, which was created by a group of former ED officials focusing on policies related to student debt and consumer protections, expressed significant concern that the Trump administration is threatening to withhold debt forgiveness that is codified in federal law.
“Threatening to punish hardworking Americans for their employers’ perceived political views is about as flagrant a violation of the First Amendment as you can imagine,” said Aaron Ament, the president of the National Student Legal Defense Network. “If the Trump Administration follows through on this threat, they can plan to see us in court.”
Karen McCarthy, NASFAA’s vice president of public policy and federal relations, expressed concerns over Trump’s executive order since the definition of qualifying public service jobs in the PSLF program has been established through the required negotiated rulemaking process to align with Congressional intent.
“Today’s order creates more confusion for student loan borrowers, particularly for those who have already had their employment certified as eligible,” McCarthy said. “Withdrawing promised assistance for those Americans working in good faith to fulfill the program requirements would be unethical and serve to undermine public trust in our federal institutions.”
Stay tuned to Today’s News as we continue to monitor the implementation of this executive order.
Publication Date: 3/10/2025
Sheree T | 3/13/2025 5:21:38 PM
"Experts interpret" is just another way of indicating an opinion. The text of the order says no such thing.
Jason J | 3/13/2025 10:3:24 AM
Folks saying, "Well, just don't do these things" are missing the entire point.
To quote from this article from Inside Higher Ed:
"Although the president didn’t say so directly, experts interpret the order as yet another attempt to discourage activism and chill efforts Trump disagrees with, such as those related to diversity, equity and inclusion; LGBTQ+ advocacy; pro bono defense for undocumented immigrants; and Palestinian statehood."
https://www.insidehighered.com/news/government/student-aid-policy/2025/03/08/trump-order-restricts-pslf-eligibility-certain#:~:text=According%20to%20the%20order%2C%20activities,children%20or%20the%20trafficking%20of
Joel T | 3/12/2025 2:58:40 PM
I believe this is another instance of individuals responding to social media posts and information from unreliable news sources. It is well-known that certain influencers are making significant efforts to oppose every action taken by this administration (this occurs on both sides). It would be beneficial for everyone to pause, take a moment, and carefully review the text of the order rather than relying on secondhand interpretations to gain the full context.
The actual text says individuals involved in the following will be ineligible for PSLF:
(a) aiding or abetting violations of 8 U.S.C. 1325 or other Federal immigration laws;
(b) supporting terrorism, including by facilitating funding to, or the operations of, cartels designated as Foreign Terrorist Organizations consistent with 8 U.S.C. 1189, or by engaging in violence for the purpose of obstructing or influencing Federal Government policy;
(c) child abuse, including the chemical and surgical castration or mutilation of children or the trafficking of children to so-called transgender sanctuary States for purposes of emancipation from their lawful parents, in violation of applicable law;
(d) engaging in a pattern of aiding and abetting illegal discrimination; or
(e) engaging in a pattern of violating State tort laws, including laws against trespassing, disorderly conduct, public nuisance, vandalism, and obstruction of highways.
As long as you're not working for a non-profit or public agency involved in activities that break federal law, such as supporting terrorism, human trafficking, discrimination, or violating trespassing and vandalism laws, you should be fine. I don't see how this would effect anyone working in Title IV aid administration.
It would be beneficial if NASFAA could clearly emphasize this fact and adopt a more neutral, factual approach with articles of this nature.
Sheree T | 3/12/2025 11:37:23 AM
This is ridiculous. President Trump signed an EO that people don't like. It is not fascism. If it is illegal, it will be challenged because we have a system of checks and balances in this country. The over-reaction only serves to exacerbate division.
Jesse H | 3/12/2025 10:9:21 AM
"However, ED is required by law to use the negotiated rulemaking process to develop new regulations for the Title IV programs, unless the Secretary determines that doing so is “impracticable, unnecessary, or contrary to the public interest.”"
I'm sure Linda McMahon will claim allowing borrowers to let the HR Offices in their child trafficking jobs sign off on PSLF forms (!) is contrary to the public interest and move forward with this nonsensical order. This is a lawless administration governed by executive fiat, and it certainly will meet with little internal resistance now that half of the Department of Education got canned overnight.
Gotta say, though, early stage fascism is a weird reality to live in. Even the lies don't make much sense.
Michelle C | 3/10/2025 1:25:51 PM
To Micheal B's extensive comment: legitimate oversight doesn't need an executive order - that follows the same path as other illegal directives from this Republican administration as any daily reading of the news will highlight. There are already congressional pathways to evaluate who is getting what relief under PSLF. Using the inflammatory language of illegal immigration, human smuggling, child trafficking, pervasive damage to public property, and disruption of the public order is fascist dog whistling pure and simple and I applaud NASFAA for calling out what is clearly at attempt to undermine a valuable program. And for the record I didn't benefit when the government bailed out the banks, auto industry or the PPP Loan forgiveness programs that truly were egregious in nature with virtually no accountability. Investing in education and public service is 1000% more worthy than those industry's I just mentioned.
Amanda P | 3/10/2025 12:29:34 PM
This is so bogus. Employment eligibility requirements are written into law. The EO is unlawful and no changes can or should be made unless by Congress and only for new borrowers. Also, anyone remember the ABA case? They'll have a hell of a time trying to revoke PSLF certification from orgs that already qualify.
I expect NASFAA to stand for the rule of law--please consider all avenues (advocacy & litigation) to prevent the administration from moving forward with this unlawful order.
David S | 3/10/2025 11:59:52 AM
Michael, once someone claims, from a bully pulpit as amplified as that of the president, that PSLF is helping people commit abhorrent crimes, including against children, this argument goes way beyond whether or not PSLF is a responsible use of taxpayer money (and no matter what argument one makes there, it's still the law, and payments can't be withheld unless Congress takes legislative action to change or eliminate the program).
While we wait for anyone to produce even a scintilla of evidence of the absurd claim that PSLF has contributed to, for example, human trafficking, it is an obvious smear campaign designed to weaken public support for all forms of relief to student loan borrowers.
And thank you NASFAA for shining the light on this issue.
Michael B | 3/10/2025 11:36:07 AM
The NASFAA article and subsequent comments regarding President Trump’s executive order on PSLF eligibility reflect a highly partisan perspective, failing to consider the broader policy and legal rationale behind the directive. While student loan forgiveness programs are a critical support mechanism for public servants, they should not be exempt from scrutiny or reform, particularly when taxpayer dollars are at stake.
NASFAA, as a professional organization, should maintain a nonpartisan stance. However, the language used by its representatives and the comments in the article indicate a strong partisan bias. Karen McCarthy’s statement that withdrawing assistance is “unethical” presumes that any change to PSLF is inherently malicious rather than a policy adjustment in response to concerns about misuse.
The comments further this bias by framing the order as an attack on students and public servants rather than an attempt to ensure fiscal responsibility. For example, one commenter states, “One side is trying to help students, and the other side is going to extreme lengths … to stop all progress to college affordability and access.” Such absolutist framing is not only misleading but also dismisses legitimate policy concerns.
Several comments argue that PSLF reform will lead to a decline in the public sector workforce, particularly among doctors, lawyers, and teachers. However, the notion that PSLF is the primary incentive for individuals entering these fields is an oversimplification. Many professions eligible for PSLF—such as lawyers working in public defense or nonprofit organizations—receive additional benefits, including competitive salaries, loan repayment assistance programs (LRAPs), and other incentives outside of PSLF.
Yolanda T | 3/10/2025 11:7:52 AM
Same concerns as the above comment. This is not an administration who is about helping the college students. Many people need this help. People of all races, political views, and socioeconomic backgrounds.
Luis J | 3/10/2025 10:3:42 AM
Dear reader of my comment, if something happens to the PSLF program, we can expect a reduction in public servant workforce. No more doctors, lawyers, teachers, administration, financial aid advisors. Who will want to work jobs that pay below average, and deal with angry people, students, parents, community.
I chose the public sector to help people and seeing how the president is "poisoning the well" with this type of fallacy bring the question. What would happen after your job becomes vilified after the lie becomes the truth?
Hopefully I will make six figures in the future, but I do not see it happening because I work for the public. I wonder how Trump come up with this statement?
Sarah B | 3/10/2025 9:27:59 AM
25 years helping low-income, first-generation college students with access to postsecondary education and this is the first time the administration has looked at who we serve and thought "no, not you".
It's already difficult to recruit and retain student services staff and painting them as a burden to taxpayers, grifters, or just disgusting humans is more smoke to stoke division in the population. Public service workers have always served those with less education, often for less pay than in the private sector. Cutting off access doesn't just affect the "six-figure earners" (though there are not many that meet that description 10 years into a public service career, especially when that masters degree is for a career in human services) but also the students that use TIV funds for direct to workforce programs and trades that find their work in the public service arena.
Shades of the 2007-2008 Sunshine Act and 2007 NYS Slate Act when Financial Aid Offices and FFELP lenders were vilified as extortionists and grifters, it was then end of FFEL and a full conversion to DL followed. Of course there was the subprime mortgage bubble burst and a recession involved but the parallels are concerning.
David S | 3/10/2025 8:40:20 AM
Yay, financial aid has its own Pizzagate now.
In 40+ years in financial aid, I have seen people and political parties disagree on how it should work, how much money to appropriate, the distribution formula and other details. I never imagined that we would see the president of the United States equate a financial aid program with human smuggling, child trafficking, and other things stated in his Friday order not mentioned above, including terrorism and truly bizarre lies about gender transitions. And then for an elected Republican to say that this illegal action based entirely on ridiculous, baseless lies “is in line with House Republicans’ goal of delivering the reforms to PSLF that are sorely needed" shows that there no longer is any middle ground. One side is trying to help students, and the other side is going to extreme lengths - including making up an alternate reality - to stop all progress to college affordability and access.
This administration has attacked the First Amendment through its DEI ban, it's arbitrarily and illegally withheld funds appropriated by Congress, who knows how many ED and FSA staff have been let go or forced to retire, and now his message to American is that student loan forgiveness is tied to heinous crimes. And we're not even two months in. This is not "government reform." His intention is to dismantle the best higher education system in the world because Republicans think it's "woke," and that he knows that he has stronger support among those with less education.
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