Useful information for chaplains on the PSLF program

Leslie Ahuvah, a seminarian who hopes to become a hospital chaplain, has done some investigating on the impact of the Dept of Education’s new criteria for the Public Service Loan Forgiviness program.  The bottom line is that anyone concerned needs to contact the company issuing the loan and find out what its policy is.

Here is her comment in full:

I had several illuminating conversations today with the Department of Ed and Direct Loan Services. Below is the text of an email I sent to my seminary’s financial aid office that I think will be of interest to your readers as well:

Today I called the Dept of Ed and asked for an explanation of the new language. I was told that Dept of Ed was not responsible for making decisions regarding what jobs qualify for PSLF, and that I needed to contact my loan servicer directly. In my case, that is Direct Loan Services.

The information that I received from Direct Loan Services directly contradicts the new language on the Dept of Ed fact sheet. The representative I spoke with sent me to a page on myedaccount.gov explaining their policy, but unfortunately it requires you to sign in in order to view it. Here is their definition of who qualifies for PSLF:

“To be eligible to have some or all of the remaining balance of your Direct Loan(s) forgiven because you are a public service employee, there are specific eligibility requirements, including:

You must be employed full-time in (in any position) by a public service organization when you make each of the required 120 separate qualifying monthly payments, when you submit your application for forgiveness, AND when the balance of the loan is forgiven.”

I looked over this information while on the phone with a Direct Loan Services representative. I asked him specifically: “Does this mean that people employed by churches holding nonprofit status, or those employed by nonprofits who do work that is religious in nature, will qualify for PSLF?” The representative answered: “Yes. We have no restrictions except for the nonprofit status of your employer, and that you make the appropriate number of payments on time while employed by them.” I asked him if he was aware of the contradictory information on the Dept of Ed website, and all the arguing going on in the media between clergy/their advocates and various Dept of Ed spokespeople, and he cut me off, saying: “We do not have any regulations regarding religious work.”

I requested a hard copy fact sheet containing this information … and then called back and went through the whole process again to see if I would get the same story twice. I did.

I encourage everyone who is concerned about what the new language on the Dept of Ed website might mean for them to find out who holds their loans (Dept of Ed will tell you this) and then contact your servicer directly to find out their policy.

 

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4 Comments

Filed under chaplains, chaplains, Church-State, First Amendment, military

4 responses to “Useful information for chaplains on the PSLF program

  1. I hope this information is useful. But please DON’T take my word for any of it – find out who services your loans and call them, ask them these questions, ask for something in writing. In my case, I still need to call ACS, the company that holds the undergraduate loans that I consolidated, and see their policy is on this.

    Also: It is clear that there is a chasm between what the Dept of Ed is saying and what the loan servicing companies are telling people. The earliest anyone will qualify for PSLF is October of 2017 … we’ve got a few years of keeping our eyes on how his develops, and being our own advocates.

  2. Loan Crusader

    Clergy is eligible. See the Dept of Ed’s entry on PSLF in the CFR (the agency’s explanation of implementation of Congress’ plan).

    34 CFR 685.219 – Public Service Loan Forgiveness Program

    • We post this but WITH A CAUTION: anyone interested in applying for a loan needs to double check the information personally. The Dept of Ed states the following in its FAQs:
      Q74 My organization is an otherwise qualifying religiously affiliated not-for-profit organization. Does my employee’s work qualify for PSLF?
      A74 It depends on how much of your employee’s job is related to religious activities. When determining full-time public service employment your employee may not include time spent on participating in religious instruction, worship services, or any form of proselytizing.
      When an authorized official signs the Employment Certification Form, the official is certifying that the number of hours worked on the form do not include any of the activities above. (March 14, 2012)
      Q75 My organization is an otherwise qualifying not-for-profit, but my employee’s job duties include participating in religious activities. Does my employee’s work qualify for PSLF?
      A75 It depends on how much of your employee’s job is related to religious activities. When determining full-time public service employment your employee may not include time spent on participating in religious instruction, worship services, or any form of proselytizing.
      When an authorized official signs the Employment Certification Form, the official is certifying that the number of hours worked on the form do not include any of the activities above. (March 14, 2012)

  3. It seems like on the form “religious activities” applies to only “religious instruction, worship services, or any form of proselytizing”. We’re allowed to do those activities and gt paid for them, but they can’t count toward our full-time employment requirement in regard to this form. It’s also worthy to note that this requirement doesn’t apply to government organization, therefore VA chaplains, government prison chaplains, or military chaplains wouldn’t have to exclude those “religious activities” from their hours worked for the week. I know that my time spent as a chaplain resident involves the occasional worship service (about 30 minutes a month to formal worship services). Is praying for a patient a “worship service”? And if so, is 10 hours of a 40 hour work-week devoted to “religious activities”? I think when filling out the form I’d need to consider those factors and claim less than the full paid work week as qualifying time. Maybe it’s 35 hours a week out of 40 just in case worship happened during devotion time or maybe proselytizing was taking place when two chaplains had a friendly debate over a religious hot topic behind closed doors.

    Form language:
    NOTE: For purposes of the full-time requirement (Section 3, Item 2.(b) above), an individual borrower’s qualifying employment with a Section 501(c)(3) non-profit or
    other private public service organization does not include time spent on job duties that are related to religious instruction, worship services, or any form of proselytizing. I’m glad my wife is more clear-cut as an RN!

    Link to form: http://studentaid.ed.gov/sites/default/files/public-service-employment-certification-form.pdf

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