Military chaplains in or out of Public Service Loan Forgiveness?

A plea went out on a list-serve of clergy because the Dept. of Education recently amended its criteria for its Public Service Loan Forgiveness program.  Basically, if you work in one of a number of public service areas — the military among them — you can apply for this program.  If accepted, you make “120 on-time, full, scheduled, monthly payments on your Direct Loans” (basically your pay off your loan for 10 years) and the balance is then forgiven.

What this clergyman flagged was a new criterion which specifiies that “if you work for a non-profit organization, your employment will not qualify for PSLF if your job duties are related to religious instruction, worship services, or any form of proselytizing.”

It raises interesting questions.  The criterion seems to be written with churches in mind, i.e.non-profits serving the community of a particular faith.  But if chaplains are serving in the military and their  duties include ensuring the freedom of religion of all troops, does that violate this criterion?

We just sent a request to Federal Student Aid and hope to learn more…. if anyone has any information in the meantime, please let us know.

 

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13 Comments

Filed under chaplains, chaplains, Church-State, military

13 responses to “Military chaplains in or out of Public Service Loan Forgiveness?

  1. I’m an attorney specializing in providing information about Public Service Loan Forgiveness and have worked with the statute and regulations regarding this program for years. My interpretation of the law is that all full-time paid employees of the government should qualify. But honestly, I don’t see the legal basis for the Department of Education’s assertion that clergy in nonprofits do not qualify. I’m working with others and seeking more information.

    • jvs

      Would love to know hear any information you find on this matter. My husband is a Chaplain and we are looking at getting all loans under Direct Loan in hopes he qualifies for this program. Thank you for keeping us in the loop.

    • Ms. Jarvis,

      I would be interested to hear anything you find out. I am a Jewish/UUA seminarian headed toward hospital chaplaincy. When I read the law itself, I could only find the language excluding employees working in jobs involving “religious instruction, worship services, or proselytizing” in the section referring to people who work for private companies who do not hold 501(c)3 status. Now that the Dept of Ed has slapped that language on their fact sheet as though it applies to people in *all* nonprofit/governmental organizations, it begs the question: Does this contradict the original language of the law?

      It’s also interesting to note that in the recent Huffington Post article about the language change sparked an immediate response from the Dept of Ed meant to calm people who work for religious nonprofit orgs, but do not do “religious” work. Below is a quote from Daren Briscoe (Dept of Ed spokesman):

      “individuals working at religiously-affiliated non-profit organizations who perform at least 30 hours of non-religious activities are eligible for PSLF, and that, consistent with similar long-standing programs, the federal government does not subsidize explicitly religious activity.”

      It’s important to note that a large portion of the work we do as chaplains is not specifically “religious.” We are mediators, ethicists, addiction and abuse counselors, marriage counselors … we support the military men and women, families, the staff of our community hospitals, the people who make this country work. Educating the public about the comprehensive nature of the work that we do may prove helpful as we advocate for our place in this loan forgiveness program.

      Thanks for listening.

      L’Shalom

      Leslie-Ahuvah

  2. Thank you, Ms. Jarvis. My own request to the Dept of Education yielded only an automated response that did not address the question. The fact sheet from the Federal Student Aid site states “NOTE: Your employment at a non-profit organization does not qualify if your job duties are related to religious instruction, worship services, or any form of proselytizing.” It does not specify that clergy are ineligible; that was my interpretation. My guess is that this criterion is intended to prevent situations in which the government is subsidizing activities that promote a particular faith — leaving military chaplains in an interesting situation since they are paid to represent their faith but provide for all faiths. Let me know what you find out — and, again, thank you for responding.

  3. We will report anything we discover, JVS.

  4. You are so right — in fact, one of the comments we get after screenings is that people didn’t realize how integral military chaplains are to the unit and the wide range of their duties. I assume it is may be similar in hospitals. Thanks for pointing out the remarks published in the Huff Post. I’ll try to link up to them.
    Lee

    • 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.

      (Sorry to leave such a huge comment!)

      • Cedric

        I woulda note that the federal servicers do not have the right to institute their own policies on the application on the Public Service Loan Forigveness regulations. So, if you were told something like that by one of the servicers, it is very likely incorrect.

        The Department’s regulations do say something about religious work, as have number Departmental officials.

        And, the Department does exercise a great deal of control in determining which employers qualify.

  5. Pingback: More about the PSFL program and chaplains | chaplainsunderfire

  6. Not only is your comment not too long, Leslie, it is so informative and useful that I have copied it into a blog to make sure people see it. Thank you!!!

  7. Pingback: Useful information for chaplains on the PSLF program | chaplainsunderfire

  8. Thanks, Cedric. I hope to be able to speak with someone at the Dept of Education next week and I’ll post what I find out. If you have any suggestions as to whom I should contact let me know.

    • Honestly, I don’t know who has the right to institute their own policies and who is 100% beholden to whom … and neither do any representatives from the Dept of Ed or Direct Loan Services, it seems. I spoke to several representatives (one from Dept of Ed and two from Direct Loans) who confirmed the info I posted.

      However, given how contradictory and muddled everything has been, I really don’t know what to expect.

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