The US Department of Education needs to hear from doctors NOW about lending

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08/02/2022
Interests: advocacy medical staff

Recently, the US Department of Education released a draft regulation to reform the national PSLF (Public Service Loan Forgiveness) program. Despite the department’s stated interest in correcting its existing PSLF regulation — which inadvertently disqualifies many physicians in California and Texas from participating — the draft regulation language still inexplicably doesn’t solve the problem.

The California Medical Association (CMA) Urges that all doctors, residents and medical students send a letter to the Ministry of Education before August 12, 2022and urges them to grant federal student loan forgiveness to qualified California and Texas physicians who provide care in private, not-for-profit hospitals/clinics.

The Department of Education is accepting comments on its draft regulations until Friday 12th August and we need as many of you as possible to submit a letter to demonstrate the urgency of this matter. CMA has prepared a sample letter and instructions for submitting the letter through the Regulatory Comment Submission Portal. It only takes 3 minutes.

It is vital that the Department of Education resolves the issue once and for all to ensure that physicians across all 50 states are able to participate equally in this important program to encourage students to pursue careers in medicine and serve our most needy and most vulnerable patients to help underserved communities. Unless regulations are established to allow physicians in California and Texas to participate, physicians will choose to practice in other states where they can receive credit waivers, accelerating our worsening physician shortage and impacting our ability to serve patients provide for those who need us most.

background

The PSLF program was designed to provide credit forgiveness and improve access to healthcare for individuals who commit to 10 years of community service by working full-time (30 hours/week) in nonprofit organizations such as nonprofit hospitals. Unfortunately, the program’s rules of implementation have been narrowed down to requiring physicians to be “directly employed”. As a result, many physicians in our nation’s two largest states have been inadvertently disqualified because while they are members of their hospital’s medical staff, they work full-time in private not-for-profit hospitals/clinics and can meet all other PSLF eligibility requirements that California and Texas state laws provide ban these private, not-for-profit hospitals run by employed doctors. But for this employment ban by law, these California and Texas physicians could be eligible for loan forgiveness, just as physicians from all other 48 states who similarly work in private, not-for-profit hospitals are eligible.

The wording in the new draft regulations seeks to address the “direct employment” problem in California and Texas by instead requiring physicians “to contract with” private not-for-profit hospitals “to provide payroll or similar services” in order obtain a loan waiver. The proposed regulation, while well-intentioned, doesn’t solve the problem and still excludes doctors in California and Texas because they don’t contract with hospitals to provide payroll services. Additionally, many physicians in these states do not practice in not-for-profit hospitals with a contract and would still not be eligible whether or not it is a contract for payroll services.

Working with the California Hospital Association, the Texas Medical Association, and the Texas Hospital Association, CMA is asking the department to accept an alternative for physicians practicing in states that prohibit direct employment. The plan would allow PSLF eligibility for physicians in California and Texas through additional written certification from an authorized official of the public service organization (hospital, clinic) certifying that the physician is working full-time (30 hours/week) at the private non-profit facility . is authorized through the clinical privilege eligibility process, but cannot be employed at the facility due to state law. This is an additional standard for California and Texas physicians who are prohibited by state law from being hired and paid directly by the facility.

Act until August 12th

Please join the CMA in sending a strong message to the US Department of Education that qualified physicians in California and Texas must be allowed to participate in the federal loan forgiveness program to reverse physician shortages and protect access to care. Click here to download our sample letter. Below are instructions on how to send the letter:

  • Update the sample CMA letter by writing Medical Student or Physician on the first line where highlighted in yellow and add your name at the end. You are also welcome to add personal comments.
  • Click here to access the Department of Education’s comment submission portal.
  • According to the proposed rule: General Provisions on Student Aid…”
    click the Comment button.
  • Click on “Comment/Write a comment”.
  • Copy the sample CMA letter with your name and paste it into the comments box.
  • Scroll down and enter your email address.
  • Click on “Individual” and enter your personal data.
  • Check the “I’m not a robot” box.
  • And make sure you click “SUBMIT COMMENT” at the end.

Thank you in advance for helping us send a strong message to the Department of Education to ensure that physicians in all 50 states are able to participate equally in this important program.

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