Celebrating 10 years! 2007-2017

PSLF Eligibility Question

Calling all PSLF experts.. I'm starting work as a risk manag mrtor07/28/17
Taking my personal opinions aside, nobody can answer that qu triplesix07/28/17
"I bet under Obama admin, it would have went through. Trump plumber07/28/17
Your job position doesn't matter. Whether the employer quali fettywap07/28/17
It appears PSLF focuses more on qualifying employers rather mrtor07/28/17
Working for a 501(c)(3) *should* be safe, but the DOE has sh 6figuremistake07/28/17
Hopefully the ABA and other recently excluded employers prev mrtor07/28/17
I didn't realize that the position versus the employer matte jd4hire07/28/17
How'd you get your job? I want in. Tired of poverty wages as vohod07/28/17
Risk compliance at a pill mill? triplesix07/28/17
Another question: Do you need to be enrolled in an income-dr mrtor08/04/17
I'm not sure it will count towards PSLF, as we are seeing, n thirdtierlaw08/04/17
That's probably the best way to ensure your payment fits wit soupcansham08/04/17
This is basically right. A "qualifying payment" is a regular onehell08/10/17
Just applied for PAYE. Anyone with experience know how long mrtor08/10/17
I think in my case it took about two months, and they put my onehell08/10/17
You need to read the employment certification form more care onehell08/10/17
mrtor (Jul 28, 2017 - 10:05 am)

Calling all PSLF experts.. I'm starting work as a risk manager for a healthcare system next month. The healthcare system is organized as a 501(c)(3). I have reviewed the PSLF employment certification and it includes "public health" as a qualifying employment sector for 501(c)(3)'s. However, it also directs you to the definition section which provides, "Public health includes nurses, nurse practitioners, nurses in a clinical setting, and full-time professionals engaged in health care practitioner occupations and health support occupations, as such terms are defined by the Bureau of Labor Statistics." I'm concerned because the risk manager position is not a front line provider position, as the definition seems to focus upon. Could it be considered a "health support occupation"?

The Bureau of Labor Statistics' definition for "healthcare support occupations" again focuses upon providers such as physical and occupational therapy assistants and massage therapists. (https://www.bls.gov/soc/2010/soc310000.htm). There are medical assistants, dental assistants, pharmacy aides, veterinary assistants, phlebotomists, and medical equipment preparers. It also lists medical transcriptionists.

Then there is the umbrella term "Healthcare Support Workers, All Other." The illustrative example again focuses upon providers with the listed illustrative example being "Ortho/Prosthetic Aide."

The BLS definition's inclusion of "medical transcriptionist," which is not a provider position, and the broad umbrella term are what I am hanging my hat on to argue that this risk manager position could qualify. However, I do not want to risk more debt than I started with if there is a challenge when I go to apply for forgiveness. I can make my payments -- I would simply welcome the opportunity to cut them in half and save six figures at the end.

So I guess my ultimate questions is, does your position matter for PSLF? Or is working for a qualifying employer enough?

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triplesix (Jul 28, 2017 - 10:12 am)

Taking my personal opinions aside, nobody can answer that question for you with any certainty. Just file with DoE for preliminary approval and go from there.

I bet under Obama admin, it would have went through. Trump administration is not so inclined about giving out any loan forgiveness.

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plumber (Jul 28, 2017 - 11:32 am)

"I bet under Obama admin, it would have went through. Trump administration is not so inclined about giving out any loan forgiveness."

What makes you think that? The pslf program was initiated under Bush's presidency, and Obuma's administration was proposing a cap on it. Trump has not.

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fettywap (Jul 28, 2017 - 10:21 am)

Your job position doesn't matter. Whether the employer qualifies nobody seems to know.

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mrtor (Jul 28, 2017 - 10:22 am)

It appears PSLF focuses more on qualifying employers rather than specific positions, which makes sense since it would be very difficult and very time consuming to draw lines when the same positions can involve very different duties from employer to employer. Recent challenges seem to be attacking whether an employer qualifies as a public service organization. I think this healthcare system is safely within the realm of a "qualifying employer."

I guess the definitions may be an attempt to illustrate the type of employer rather than which types of jobs qualify.

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6figuremistake (Jul 28, 2017 - 10:58 am)

Working for a 501(c)(3) *should* be safe, but the DOE has shown sign of being restrictive about granting PSLF forgiveness.

If you work for the government or what is clearly a charity/public interest group (e.g. United Way, World Wildlife Foundation), you're probably golden - if people in these categories don't qualify, then nobody does. With anything else, you're taking at least some risk.

I wouldn't take a job where there is a reasonable question if I would qualify - if the primary reason for taking the job is because of PSLF. If I otherwise wanted the job, I would just see it as a nice potential bonus.

Like triplesix said, there's nothing you can do except try to prequalify with DOE and hope they don't change their minds. Hope the job works out well.

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mrtor (Jul 28, 2017 - 11:04 am)

Hopefully the ABA and other recently excluded employers prevail and hold the DOE accountable. If the DOE wants to exercise more control over who qualifies for PSLF, which I encourage, then invest in a process that provides definitive answers during the application process. Don't kick the can back and forth until the very end. That's plainly unfair.

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jd4hire (Jul 28, 2017 - 11:07 am)

I didn't realize that the position versus the employer matters. My understanding was that eligibility was based on the employer's status.

Hope the new gig goes well. I'm curious to hear about your perspective after leaving litigation and the billable hour. Please update a few months down the line.

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vohod (Jul 28, 2017 - 11:20 am)

How'd you get your job? I want in. Tired of poverty wages as a private attorney 60 hrs a week + subsidizing PSLFers.

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triplesix (Jul 28, 2017 - 11:32 am)

Risk compliance at a pill mill?

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mrtor (Aug 4, 2017 - 3:33 pm)

Another question: Do you need to be enrolled in an income-driven repayment plan before applying for PSLF certification? I planned on applying for PAYE after I'm approved for PSLF when I start in September. I want to make sure PSLF is an option before jumping on PAYE. Will payments made during the transition period it takes to get on an income-driven plan count for PSLF?

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thirdtierlaw (Aug 4, 2017 - 3:39 pm)

I'm not sure it will count towards PSLF, as we are seeing, nobody knows. I believe a payment at the full 10-year repayment amount during the application period counts as a "qualified payment" under both PAYE and PSLF. Those who choose to pay only the nominal $5 amount doesn't count. At least according to great lakes, it also doesn't count if you make a payment equal to the IBR you are currently paying.

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soupcansham (Aug 4, 2017 - 4:21 pm)

That's probably the best way to ensure your payment fits within the rules. As far as I know, PSLF kicks in after 120 qualifying payments under IBR, which caps your payment amount at what it would be under a ten-year repayment plan. While the paperwork is being processed, my guess is that the only way to ensure you'd be meeting that standard is to pay at least the ten-year-payoff amount.

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onehell (Aug 10, 2017 - 12:32 pm)

This is basically right. A "qualifying payment" is a regularly-scheduled payment made on an income-driven repayment plan OR the 10 year standard plan.

Of course, on ten year standard there would be nothing left to forgive at 10 years. But it can make sense, for example, in my case: I was on an income-adjusted IBR payment for my first few years out of law school, then I made too much money to qualify for any income adjustment. This put me on a payment that is the same as my 10 year payment would have been at the time I entered IBR, but each payment still qualifies. So even though I'm on a payment that would drop my balance to zero if I had been making that payment from day one, I wasn't making it from day 1 and will therefore still hit payment #120 before the balance drops to zero. By the time I hit payment #120 there will only be like $20,000 left to forgive but hey, better than nothing. And since I'm locked in to the old APR of like 2%, it's not like the interest will be eating up much of that benefit so even though I could just pay it off now, there's no reason to do so.

Payments made in any other way, like extended standard or graduated, or any payment made outside of the regular schedule or optionally, or something you paid during a forbearance or a deferment, will not be a "qualified payment." Similarly, payments made before IBR came into existence in 2009 don't count.

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mrtor (Aug 10, 2017 - 10:50 am)

Just applied for PAYE. Anyone with experience know how long it takes the loan servicer to make a decision?

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onehell (Aug 10, 2017 - 12:12 pm)

I think in my case it took about two months, and they put my loans in some kind of forbearance while they figured out what my payment should be. That was back in 2009 or whenever the program first came into being though, so it might be more or less now.

If you are also submitting an ECF form for PSLF, then they are also going to change your servicer to FedLoan Servicing, which may add some time. If you are doing PSLF, make sure your loans are all consolidated first, because if you have any old FFEL loans, they have to be consolidated into direct loans before any payments on them can count towards PSLF.

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onehell (Aug 10, 2017 - 12:03 pm)

You need to read the employment certification form more carefully, specifically question 10:

https://studentaid.ed.gov/sa/sites/default/files/public-service-employment-certification-form.pdf

Notice, question 10 says "is your employer a c3? If yes, SKIP TO SECTION FOUR." Section 4 is the signature block. If your employer is a c3, you skip question 14 where it asks what the organization actually does.

In other words, if your employer is a c3, it does not matter what it does. It automatically qualifies. Question 14 applies where you have an employer that is a state-only nonprofit (i.e. not tax exempt) or if it is tax-exempt under something OTHER than c3, like a c6 membership organization (e.g. a chamber of commerce).

If the EIN on your W2 comes back to a 501c3 or government agency, there is no need to engage in the substantive/subjective analysis of what the organization actually does. These subjective cases are the only ones where there is any uncertainty, but the ABA and other non-c3 nonprofits are milking this to create anxiety and public outcry about a problem that does not apply to most PSLF people.

One thing to watch out for: In hospitals and health systems, it is somewhat common for the nonprofit to contract day-to-day operations out to a for-profit company under a "management services agreement," which of course changes who you are technically employed by. You need to ask HR exactly what EIN number will appear on your W2. Then, check guidestar and make sure that EIN comes back to a 501c3. If it does, you're in the clear. It doesn't matter if it's health or education or pro bono legal services or whatever, that test doesn't apply unless the organization is a nonprofit OTHER than a c3.

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