4 Questions & Answers To Help Borrowers Maximize PSLF

Recently, we’ve received multiple questions around certifying PSLF Forms for qualifying staff. We wanted to share a few of them (along with the answers), as they might be applicable to you now or in the future:

Q: “With the Education Department taking over PSLF administration, what should I do if I get a PSLF Form request before July?”

A: Go ahead and complete it. While no PSLF Forms will be processed during the 5/1 to 7/1 transition period, those submitted over this time will be in the queue for processing once ED takes over.

Q: “Should I complete a PSLF Form for a borrower with privileges at our 501c3 organization?”

A: This is evolving as PSLF requirements have been broadened. There are two items to consider:

• Do these privileges constitute at least 30 hours per week?
  • If a borrower works at least 30 hours weekly in a nonprofit environment, whether just for you or cumulatively, they may qualify for PSLF under the most recent regulations.
• Who is the borrower/s direct employment with: A non-profit, or are they 1099/private?
  • PSLF was recently broadened to include contractors where state law prohibits an organization from employing them directly, such as CA and TX. Specifically: “A qualifying employer may certify employment for a contractor if that individual is providing services that by State law cannot be filled or provided by an employee of that organization.”

Q: “We received a PSLF form for a borrower who is .9 FTE with us, but they are working 35 hours/week. Should I complete the form?”

A: Absolutely. The new rules allow for PSLF certification as long as an employee meets the Department requirement, no matter how your system defines it.

Q: “A borrower just submitted a PSLF Form and indicated they worked 80 hours per week. We have them at 40 in our system.”

A: Now that (thankfully) digital signatures are available to certify past employment, you may not be able to update hours per week on requested forms. In these cases, note that whether the form says 80 or 40 hours, it does not affect PSLF. Anything over 30 hours per week is counted the same way; you won’t be “speeding up” the PSLF process by signing off on more than 30.

To summarize, while processing times are painfully slow, borrowers have been getting generous outcomes where there are gray areas. There is nothing preventing you from signing off on a PSLF form for review if you believe a borrower is meeting the requirements.

If you have any further questions, schedule some time with us here. Thank you for your continued trust!

About Author

Jason DiLorenzo

Jason is the Founder of BenElevate, an early stage fintech company working to address the student debt crisis by bringing to bear tools, expertise, and bespoke solutions to streamline student debt management for borrowers and employers.