In October 2022, the Department of Education (DOE) issued a press release titled “Charting the Path Forward to Public Service Loan Forgiveness (PSLF).” In this release, there were a couple of regulations listed that could help borrowers who are pursuing PSLF. One of those regulations could be huge for doctors in California and Texas. Here’s what it says:
“Allow a qualifying employer to 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. The Department is aware of specific circumstances where existing state laws generally prevent doctors at nonprofit hospitals in California and Texas from working for the hospital directly. This change would cover those individuals as well as any other contractor whose employment is similarly barred by state law.”
This regulation would allow thousands of docs (and other health care professionals) in California or Texas that are currently ineligible for PSLF to qualify, potentially saving physicians hundreds of thousands of dollars in forgiven student loans.
First, let's talk about how some doctors in California and Texas have a tough time qualifying for PSLF.
California and Texas have had unusual state laws for years that prohibit many nonprofit hospitals from directly employing doctors. As a result, many doctors in those states are employed by a contractor with a hospital. However, in this specific situation, a doctor can't get PSLF, because in order to qualify, they must receive their paycheck directly from a qualifying organization—such as a nonprofit, a 501(c)(3), or a government employer. A doctor who's working for a nonprofit but who is being paid by a contractor wouldn't qualify.
With PSLF out of the picture, these doctors then select an alternative method of repayment, such as student loan refinancing or IDR forgiveness. That's usually a more costly option than PSLF.
If a doctor in California or Texas wants to pursue PSLF, they are constrained to employment at an academic institution, in public health, or in a government setting like the VA. If they aren’t interested in those environments, they must settle for employment at hospital contractors such as Kaiser Permanente. These contractors do not currently qualify for PSLF. This can pose a difficult decision for new docs who often have large student loan balances. Many new docs plan to pursue PSLF after they graduate training and desire to live in California or Texas. They risk losing out on PSLF, as there are fewer job options in those states that qualify because of the unusual state law.
One of the largest employers of docs in the country, Kaiser Permanente, could be on the list of employers that could fit as PSLF eligible, thanks to this new DOE adjustment. Many doctors finishing training who want to work in California will work for Kaiser. The unfortunate reality is they usually finish training with 3-7 years of work experience that is PSLF eligible, but they have to forfeit the program because Kaiser is not a qualifying employer. Now, with an opportunity for those docs to qualify for PSLF, many more physicians could end up pursuing PSLF and have their loans forgiven just a few years out of training.
More information here:
Refinance Student Loans and Pay Off or Go for PSLF?
Is Public Service Loan Forgiveness Worth It for Doctors?
How Do I Know If I Qualify for PSLF?
If you want to qualify for PSLF, here are six things you need to remember:
- Have direct federal student loans. If your loans aren’t direct, consider a direct federal consolidation.
- Enroll in an income-driven repayment (IDR) program such as REPAYE, PAYE, IBR, or ICR.
- Work full-time or the equivalent of full-time across multiple agencies or organizations (minimum of 30 hours per week).
- Make on-time monthly payments.
- Complete an employer certification form.
- Work at a qualifying employer. Qualified employers tend to be nonprofits, 501(c)(3), government employers, etc.
Once you’ve hit 120 qualifying monthly payments, you would be eligible for your loans to be forgiven tax-free.
More information here:
The (Nearly) Perfect PSLF Situation for a Physician
How Do I Know If My Employer Qualifies for PSLF?
The easiest way to determine if your employer qualifies is by using the PSLF help tool on studentaid.gov. To verify your eligibility, you need to insert the employment identification number (EIN) from the organization(s) that is paying you. Your EIN is usually on a tax form like your W-2. If you don’t have this, reach out to human resources.
Below is an example of a qualifying employer indicating “Eligible.”
This means, as long as you are following the rest of the PSLF rules, then you are accumulating credit (or have in the past) for the PSLF program.
If you are working at a community hospital but are employed by a contractor, you are likely paid by the contractor. Today, if you tried to input Kaiser Permanente (likely a contractor with a nonprofit hospital), you would come back with this “Not Eligible” status.
How Do I Know If My Employer Qualifies for This PSLF Loophole?
As of this writing, Kaiser Permanente employment or any other situation in which you are paid by a contractor with a non-profit/501(c)(3) doesn’t qualify for PSLF. Based on the new DOE regulations to start July 1, 2023, Kaiser is likely an employer that would qualify.
After recent guidance, borrowers are now eligible to qualify their employment.
In order to qualify your employment you need to complete a PSLF certification form and input your qualifying nonprofit/501(c)(3) employer information. That means, you'll input their EIN and request a signature from an official of the qualifying employer not your actual employer (generally the contractor). On the PSLF help tool, you'll input an email for a representative at the qualifying employer. Once it is signed, your form will be sent to MOHELA for processing. If you don't use the help tool, you'll need to procure a wet signature from a representative at the qualifying employer. And later on send the signed PSLF form to MOHELA via their upload portal or fax/mail.
You do not need to add your actual employer that does not qualify for PSLF.
Here are some other questions I've been thinking about.
PSLF Loophole Q&A
How Do I Fill Out My PSLF Certification Form if I'm Employed by Kaiser Permanente?
If you are a doctor at Kaiser Permanente, you can now verify your employment to qualify for PSLF. If you work at The Permanente Medical Group (TPMG) or Southern California Permanente Medical Group (SCPMG) here's the information you'll need to enter into the PSLF help tool
EIN: 94-1105628 or 94-1340523
Employer Name: Kaiser Foundation Hospitals or Kaiser Foundation Health Plan
Address: 1950 Franklin Street, Oakland, CA 94612
Email for verification of employment: [email protected] (TPMG) and [email protected] (SCPMG)
When Can the Qualifying Employer Sign the PSLF Certification Form?
The qualifying employer can sign the PSLF certification form if either of these point are true:
1.) You are employed under a contract or by a contracted organization in a position that, under state law can't be filled by a direct employee of the organization or,
2.) You provide services that, under state law, can't be provided by a direct employee of the organization
Can I Qualify If I Already Refinanced My Student Loans?
If you have already privately refinanced all your federal student loans, you would not be eligible for the PSLF program. There is no undoing a private refinance. If you’re considering refinancing, make sure you consider this loophole, among other factors, prior to making your final decision.
Is This Retroactive?
Yes it is retroactive. Although the change happened on July 1 2023, previous employment is considered for PSLF eligibility back to October 2007.
Do Only Doctors Qualify?
No. In the ruling it mentions any borrower that works in a state that has laws that prevents their direct employment at a health care facility can qualify. So, I believe this would be inclusive for PAs, NPs, pharmacists, etc. However, it is our experience with Kaiser Permanente you would have to be a doctor to qualify.
Do I Qualify If I Work Outside of California or Texas?
No. This regulation only applies to those who are working in California and Texas.
What Impact Could This Have If You Qualify?
Picture this. You’re a new pulmonary critical care doctor working in San Diego at your first attending job making $325,000. You trained for six years at academic institutions and have six years of PSLF credit. You fit the unique situation in this loophole in that you are employed at a hospital contractor that, in the past, wasn’t eligible for PSLF.
You owe $300,000 in student loans at a 7% interest rate. You are trying to decide the optimal paydown plan and whether you should privately refinance or do PSLF.
Private Refinance
You privately refinance your loans to a 5% interest rate and a five-year term. You make a monthly payment of $5,661 and pay $39,682 in interest. You’re out of debt in five years, and your total loan cost is $339,682.
Public Service Loan Forgiveness
You decide to pursue PSLF for four more years. You are on the PAYE program and you just recertified your income from the year prior when you worked half the year as a fellow at $60,000 income and half the year as an attending making $325,000. Over the next three years, your pay increases a little.
Over four years, your monthly payments in PAYE are usually about $2,500 and your total loan cost is $111,550. Your remaining loan balance of $275,000 is forgiven tax-free.
This new attending could end up saving over $228,000 in student loan payments by pursuing PSLF with this newest regulation. For many, PSLF forgiveness might not be life-altering money. However, it could also mean earlier retirement, partial retirement, more money in rental properties, 529 plans for kids, or just more time to spend with your loved ones.
As more information on this loophole becomes available, I will update this post. If you have questions about whether you qualify for this loophole or need general advice on the best way to pay down your student loans, contact our experienced team at studentloanadvice.com today!
If you're a doctor in California or Texas, could this loophole apply to you? Did you even know about this potential PSLF adjustment? How could qualifying for PSLF change your life?
Any insight on how being an incorporated physician that works at a 501c3 hospital works? We, as the individual, would be paid by our corporation, and the corporation would contract with the group that holds the hospital contract where we work full time. Should we be able to certify if its our corporation that is contracted with the group?
And now that incorporated physicians are eligible, is the IDR based on the “fair wage” salary our corporation pays the individual physician? Or will it be based off the corporations income?
Good question. I think it would probably work. Mostly you just need the entity to sign off on you.
IDR payments are based on your total income, not just your salary.
So your IDR payments would account for the total income your corporation makes? Or only your total income as an individual?
Or perhaps I’m not understanding the difference well enough
Your clinical income. Your professional income. Your business income. Your personal income. Your corporation income. Your spouse’s income. Your investment income. All your income. All of it. You certify your income using your tax returns and all of that shows up on the tax return.
So to clarify we enter the EIN for hospital we work at that is a qualifying employer not the employer we directly work for?
Susan,
Correct.
Andrew SLA
This is great news for us providers that live in either Texas or California.
I do have a few questions:
1) Does this new change apply to APP (PA or NPs)? I am an APP practicing in California.
2) In terms of getting the form signed, I am unsure who I should be asking to get this form signed — I understand you mentioned to get it signed by an employee at the hospital (but I am unsure who exactly).
This is my current situation – I work in the ED and am contracted by a for-profit physician group (hence, non-qualifying). But the actual hospital I work at is a 501c(3) eligible hospital (qualifying). My paycheck only mentions all the information by the for-profit group. There is no mention on my paycheck that I work at the qualifying hospital. If I were to go through the actual hospital’s HR, I am afraid they will not be willing to sign the PSLF form given they have nothing to do with me nor my actual employer (which is understandable). So, who do you suggest I ask to get this new form completed? I appreciate your help and I hope my situation makes sense. If not, I can further clarify if needed. TIA.
1.) I don’t think it’s exclusive to physicians, so give it a shot.
2a.) On the PSLF form it says it needs to be an authorized official. So this can be someone in HR, finance, payroll, your direct manager, etc.
2b.) Just explain the new PSLF form to them that they can sign on your behalf. Might have to sit down with someone and explain that to them.
Looking over the Temporary Expanded PSLF Certification Form, it doesn’t mention anything about only holding true for CA or TX borrowers. Washington state has an equally restricted law. Could medical professionals in other states also qualify for this or does it say somewhere it is only for CA and TX?
Sandra,
Currently no. It is only CA or TX where this situation qualifies. Here’s the full legal doc if you wanna dig in https://www.govinfo.gov/content/pkg/FR-2022-11-01/pdf/2022-23447.pdf
See page 74
Andrew SLA
What’s the chances the California/Texas loophole gets reversed in the future? I work for private group contracted to non profit hospital in California. I just got the green light from hospital admin to sign these forms but I have 5 years of payments until I hit 120. My worry is that I make these minimum payments then this somehow gets rescinded.
Don,
No idea. There could be changes in the future, but usually they will grandfather in those who qualify (existing borrowers) for PSLF, IDR, etc.
If you’re worried then just set up a side fund in the event it doesn’t work. https://www.whitecoatinvestor.com/pslf-side-fund/
Andrew SLA
This is and will forever be shocking news. Congrats to the people who this helps but I am a recent graduate who refinanced my loans and had to deal with the decision well I enjoy Kaiser and will choose to stay but they aren’t PSLF. It was the best thing to do at the time when interest rates were at all time low. But this wasn’t even in the cards . Loan forgiveness should extend to everyone.
Hard not to feel like you got hosed huh? Besides you and others like you that paid off their loans (or are in the process of doing so), there are all the people who didn’t go to school because they couldn’t afford it.
This is a tough outcome. If you refinanced during the COVID forbearance, you may consider trying for a hail mary and asking for a refund of the payment to refinance your loan. We know that you can ask for a refund of payments made during the pause, even if it paid off the balance in full, and even if a 3rd party made the payments. I’m also aware of this happening successfully with at least 2 borrowers.
I’m working with a client right now (an OD) to try and reverse this. It may not be successful or have a low probability of working, but it is possible. If PSLF is what makes the most sense for your specific situation long-term, it’s something to consider trying. ** Otherwise, if you made the best decision you could with the information at hand, then you have to focus on the process over results. Nothing you could have foreseen about this.
**Of course, not advice. I have no clue what the right decision would be for your particular situation. Talk with your own pros and do your own due diligence.
This is a tough outcome. If you refinanced during the COVID forbearance, you may consider trying for a hail mary and asking for a refund of the payment to refinance your loan. We know that you can ask for a refund of payments made during the pause, even if it paid off the balance in full, and even if a 3rd party made the payments. I’m also aware of this happening successfully with at least 2 borrowers.
I’m working with a client right now (an OD) to try and reverse this. It may not be successful or have a low probability of working, but if PSLF is what makes the most sense for your specific situation long-term, there’s probably no reason not to try.** Otherwise, if you made the best decision you could with the information at hand, then you have to focus on the process over results. Nothing you could have foreseen about this.
**Of course, not advice. I have no clue what the right decision would be for your particular situation. Talk with your own pros and do your own due diligence.
What happens if you’re working in Texas for a group that provides services to a qualifying employer but no one at the qualifying employment is willing to sign the form? I keep getting told to get it signed from my actual employer.
E Riaz,
Your actual employer won’t qualify that’s the point of this whole post is that the qualifying organization needs to sign it. If they won’t sign it you can mark on the PSLF form they aren’t willing to sign.
Andrew SLA
I am having the same problem with one of the hospitals I worked at before. It’s amazing how dense some of these HR workers are who refuse to listen or understand the changes. Getting alternative documentation is difficult also since it states the alternative documentation needs to show the EIN and dates of employment, but my paystubs from my group does not include the EIN of my hospital.
Khoi,
Right, paystubs won’t work. You can also mark on the PSLF form they won’t verify your employment.
Andrew SLA
If paystubs will not work, EIN on tax form includes the for-profit organization, AND the non-profit hospital will not verify employment (hence, mark on the PSLF form they will not sign it), then how will they know that I actually work for a qualifying non-profit organization so that my payments would count for PSLF? I feel that this is the situation I will be in when I submit my PSLF form next year when after filing income tax. I can foresee them rejecting my payments for PSLF even though I work AT a non-profit hospital.
Any additional advice on how to fill out the form?
Thank you Andrew for answering my inquiry.
Hi Jayne,
If they refuse, you should sitdown with someone there and explain why it now can qualify. There will be some employers who are unaware of these changes and just need an introduction. If they continue to pushback, you might have to work with your actual employer and their relationship with the nonprofit hospital to smooth this over. If the guidance is coming from the c-suite, it will be easier for them to adapt. I’m seeing this with other large hospital systems who have their HR departments working very closely with the c-suite to stay up to date on these changes.
Andrew SLA
Andrew,
I appreciate your response. I will have to take that approach and hopefully it will make the process more seamless.
So, if you work for a private practice in Texas and California, there is a high probability at least one of your contracts is at a non profit hospital. So even if you have a mix of sites you work at, as long as part of your work is at a non-profit, you can still qualify for PSLF?
Don,
For sure. Should definitely give it a shot. As long as the reason why you aren’t directly employed by the nonprofit is because of state law.
Andrew SLA
I thought your non-profit work had to be 30+ hours. So if you work 5 days a month in CA at Kaiser and the rest in NV at a for-profit, that’s not going to cut it.
WCI,
Yes, it does need to be a minimum of 30 hr p/wk at one or more qualifying employers.
Andrew SLA
Hello,
I work with Kaiser Permanente in Southern California, I am a licensed mental health therapist who contracts through the same group that the physicians contract with. I was just informed that Kaiser only considers doctors who contract with this group as qualifying as working for the non-profit. The answer I was given, was that this decision was made based on State Law. Do I have any further recourse here?
I can’t imagine this doesn’t apply to you. PSLF is NOT doctor specific. Is Kaiser or the group refusing to sign your forms?
I sent in the form to HR at Kaiser Permanente and filled out the EIN of the nonprofit, as per the Department of Education website, they faxed it to Mohela and marked the box my employment does not qualify. When I called HR, I discussed the new law with them, they indicated that it is only for doctors, as per the State law and that I have no recourse within Kaiser Permanente.
AJ,
Wow this is unfortunate. I wonder if your employment is also barred at nonprofit hospitals like it is for doctors. Very sorry to hear this.
Andrew SLA
AJ- I am also a non-physician healthcare provider contracted by SCPMG. How did you find out that HR marked it as a “no?” Did they send you a copy of the completed form? They also sent my form directly to the Department of Education on 8/7/23, even though I asked them to mail or fax me the completed form. They did not tell me how they responded. I haven’t received a copy yet. It appears as if the form is still in “processing “ status with MOHELA. They’ve always sent me the completed form stating that my employment does not qualify (that’s before the new regulation). They never sent “does not qualify” forms to Dept. of Ed. Why now? Without any communication with us.
VC,
It is my understanding, at least for TPMG, if you are a non-physician employee you do not qualify for PSLF if you are paid by the private enterprise (SCPMG or TPMG). If however you are paid by KFH, then you would be able to verify your employment. I have messaged with many docs, PAs, NPs, etc., and they confirm this as well that HR won’t sign the form unless you are a doctor.
Andrew SLA
Thanks for your response. I’m still waiting to receive a copy of what KP HR sent to the DOE. I’m assuming that they did not certify my employment as eligible for PSLF. Truly heartbreaking, to work side by side with providers who do qualify, while the rest of us do not Of course, physicians should qualify, but it seems very unfair that other hardworking healthcare workers in the same organization do not. I’ve never received an answer from KP to why KP hires non-physician healthcare providers under SCPMG, since the law only bans physicians from being hired by a nonprofit hospital. Any idea why? Also, where could I find the actual law that the new PSLF regulation is referring to?
VC,
My best guess is because the rule only makes specific mention of doctors. You’ll have to take this up with HR as i’ve already tried with them and they have said only doctors will qualify…
Here’s the actual legal verbiage
https://www.govinfo.gov/content/pkg/FR-2022-11-01/pdf/2022-23447.pdf
Andrew SLA
I’m an MD contracted to a 501c3 hospital in northern California (not Kaiser). This hospital belongs to a larger group that also appears to have the same non-profit designation. I have been having trouble trying to get the HR/staff people convinced to sign the paperwork. They are hung up on the fact that I’m not directly employed despite the summarized literature, new law text, and even links to other forums that I sent them. C-suite is involved and they also seem hesitant . From what I’ve been able to read, it ultimately comes down to the folks at MOHELA or the DOE who decides if you’re good to go, right? What else can I say or present to them that will put them at ease with all this? At what point should I check the “Organization has refused to certify your employment” box? Thanks in advance.
DY,
If your employment is barred by state law then you should be able to qualify. Unfortunately, many employers are slow on the implementation. If they continue to fight you on this, then you can mark they won’t sign it for you. If in six months, they change their mind on this and now will sign on your behalf then you could redo your forms if you haven’t already received credit for your employment.
Andrew SLA
I foresee similar situation for myself.
I wonder if a good solution would be to have the 501c3 hospital actually write a formal letter stating that I have worked at X 501c3 hospital from date-date and contracted under X group. This letter are simply just stating the facts. Then, it is up to Mohela or DOE to decide based on this letter. Any comments?
Jayne Z,
If they are wiling to fill out a letter why wouldn’t they just sign an attestation form on your behalf? I’d just keep it simple and complete the PSLF doc. I’ve seen the loophole already start to work with Kaiser Permanente docs.
Andrew SLA
I’m a licensed MFT, who has been with Kaiser for 6.5 years. I have been working tirelessly to find something indicating that there is a law barring MFTs from working for KFH, which would make us eligible for PSLF. I have not, as of yet, seen anything indicating that there is such a law that applies to mental health professionals. Has anyone else seen anything?
Hi Allison,
Unfortunately no. Kaiser will only sign the form if you are a doctor (MD/DO/DPM). Wish this wasn’t the case and it was inclusive to other medical professionals.
Andrew SLA
Has anyone had success getting HR to sign the form with the hospital tax code? NorCal has given me a hard time and they refuse to forward my call directly to the department that signs the forms. I have explained it to them a million times but haven’t been able to get through. Has anyone been able to get HR to sign the form correctly?
Yes! If you’re a doctor at TPMG, I used the KFH EIN and submitted the form to the email address provided on this site , and it was signed and approved and sent to MOHELA!
Email your signed form to
[email protected]
And use the EIN for Kaiser Foundation Hospitals which is 941105628
The online PSLF help tool will fill out the form for you including the address and name of employer when you type in that EIN.
Someone will email you back.
OPT,
Yes, I’ve worked with a bunch who already qualifed for PSLF. Use the detail from HELLO.
You don’t input the permanente medical group. You can use Kaiser Foundation Hospitals.
Andrew SLA
No one has made any mention about the new verbiage regarding PEOs: “some employers will contract with third party organizations called a professional employer organization to perform specific payroll and benefit function as your co employer.” Then it goes on to say to use the EIN of the hospital, not the PEO, to qualify.
It is very vague about what constitutes as a PEO, but I don’t see why this couldn’t be any 1099 or for profit entity staffing a hospital even outside of the states of TX and CA. Does anyone know anything about this?
I haven’t met a doc who pulled that off yet, but who knows? The process has become increasingly lenient over the years.
PSLF SKEPTIC,
I’ve met with a number of docs who work for a private enterprise but are staffed at nonprofit hospitals that have begun to receive credit for PSLF. They have gotten the nonprofits to sign their PSLF forms. All of them have been in CA thus far.
Andrew SLA
Has anybody gotten this to work in Texas? If so, how did you get the non-profit hospital to sign off on the form if they stated you were not on their payroll during the times you were under the private contractor?
SaintsPainter,
I haven’t seen a TX doc yet. I have seen this with CA docs though. You should just ask them to sign and refer them to the dept of ed guidance on the changes
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/futureofpslffactsheetfin.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
It really depends on the employer. Some are easily swayed and others will say they are working on it with their legal team. You’ll need to be persistent on this. We are still in the early days with this. But I can tell you’ve i’ve already seen docs in this situation not only get signatures but have their loans discharged.
Andrew SLA
Thanks to those that responded above!
There has been a lot of discussion regarding TX and CA – however, there are other states that also have Corporate Practice of Medicine statutes. It looks like OR and WA have similar, and possibly even more restrictive, statutes than TX or CA (as they do not have exceptions for nonprofits). This works in favor of the PSLF borrower.
It seems like more people would be taking advantage of this if it were public knowledge – why the emphasis on TX and CA?
Can you comment more specifically on the PNW states?
Thanks again!
PSLF Skeptic,
Do you have a source on the corporate practice of medicine statutes for states outside of CA and TX? I was only aware of those two states that prohibit docs from being directly employed by nonprofits (outside of FQHCs, Academics & VA).
I think the emphasis was made on CA and TX because those are the only states listed in the DOE guidance.
“Allow a qualifying employer to 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. The
Department is aware of specific circumstances where existing state laws generally prevent
doctors at nonprofit hospitals in California and Texas from working for the hospital directly. This
change would cover those individuals as well as any other contractor whose employment is
similarly barred by state law.”
https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/futureofpslffactsheetfin.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
I haven’t heard about PNW states qualifying.
Andrew SLA
Hi Andrew,
Thank you for all the information about PSLF eligibility at TPMG. I am a CRNA (nurse anesthetist) and am employed by TPMG. Kaiser HR says the updated regulations only include the TPMG physicians as contract employees for the nonprofit hospital due to the CPOM ban (law banning physicians in CA to be directly employed by/own a hospital.) However, it seems as though there is room for interpretation of the definition of an eligible employee in the regulations – someone who “works as a contracted employee for a qualifying employer in a position or providing services which, under applicable state law, cannot be filled of provided by a direct employee of the qualifying employer.” KFH is a qualifying nonprofit employer and nurse anesthetists provide anesthesia services for KFH. KFH employees would not be able to provide anesthesia for any of its patients without MD anesthesiologists or CRNAs, under state law. I am hoping to stretch the interpretation of the update beyond a reference to the CPOM ban, so that it can include CRNAs and more advanced practice clinical employees at TPMG. Do you think CRNAs at TPMG are eligible under the new legislation? I am trying to push back because I believe the language is up for interpretation as it does not explicitly refer to the CPOM ban.
Thank you,
Naeha
Hi Naeha Bhambhra,
It’s worth a shot but I haven’t seen any success for CRNAs, NPs, Therapists, RNs, virtually another other provider outside of MDs, DOs and DPMs.
The ruling does specifically state doctors as I’ve referenced when others have asked this same question.
Andrew SLA
Hi Andrew,
I am employed by TPMG in California as a clinical audiologist. I have a doctorate degree in Audiology, but am not a physician. Do you think I would be eligible for PSLF under this new regulation?
Hi Ella,
It’s worth a shot, but I haven’t seen any success for anyone outside of MDs, DOs and DPMs.
Andrew SLA
I’m in private practice, and one of the hospitals at which I round is considered a non-profit organization. The hospital HR sent out a memo from the chief legal officer and from medical staff stating that we would qualify and we should complete an attestation that we meet the requirements to apply for loan forgiveness.
My loan types are FFEL with Navient, but as I understand it, I have to consolidate to a direct consolidation loan. As an attending, I don’t think I would qualify for any type of income dependent repayment plan, but it seems as though that’s the option to choose for PSLF. Am I missing something?
Tuan Ta,
Yes you need to consolidate and enroll into and IDR plan. If you need help we can walk you through this process.
Studentloanadvice.com/book
Andrew SLA
You don’t have to be on an IDR to get PSLF, but I’m not sure you wouldn’t qualify for one.
You’re right—I can choose the IDR. It’s just that the payments are so much higher/month than what I would want to pay. And the total amount of the loan to be paid back on IDR is higher than what it is before consolidation into a direct consolidation loan. I guess that may not matter once the PSLF goes through—it’s just that there’s no guarantee that it will go through!
Tuan Ta,
Sure, not guarantee it goes through but it’s worth a shot.
Andrew SLA
I was told that Kaiser is only certifying PSLF eligible employment for physicians. I acknowledge that the new regulation is allowing a qualifying employer such as Kaiser Hospital Foundation to certify employment for employees providing services that by State law cannot be filled or provided by an employee of that organization. Although, the new regulation is not physician specific, I was told that my position as a psychologist would not qualify because there is no state law banning their ability to become employed by the Kaiser Hospital Foundation, which is a qualifying employer.
It is my understanding that the state law bans physician employment in California, is the California Business & Professions Code 2400 which states that “corporations or other artificial intelligence shall have no professional rights, privileges or powers” over the practice of medicine. I have recently become aware that the California Board of Psychology Laws and Regulation also includes a regulation similar to the one that makes physicians eligible. California Business & Professions code 2907 states “corporations shall have no professional rights, privileges, or powers, and shall not be permitted to practice psychology, nor shall the liability of any licensed psychologists be limited by a corporation.” Hence, wouldn’t that mean that California psychologist working for Kaiser should also be certified? Of course, I am a psychologist and not an attorney, so I may be grasping at straws here. That is why I would appreciate your thoughts and legal insight on this matter. At the very least any suggestions on whom within the Kaiser system could answer this question. It is a behemoth organization, thus figuring out who could help me with this has been a challenge.
PSLF Hopeful,
This is a similar sentiment for how I thought they would interpret this as well. But, I’ve been told this is not the case by Kaiser HR. They will only verify you for PSLF if you are a DO, MD or DPM.
Here’s more literature on this subject https://www.cmadocs.org/Portals/CMA/files/public/PSLF%202023%20-%20What%20California%20Physicians%20Need%20to%20Know.pdf?ver=2023-07-12-102942-047
This guide is regularly being updated –
Here’s a question that speaks directly to what you are asking — Does the new change impact allied practitioners in California or Texas, such as Physical
Therapists, Nurse Practitioners, or Physician Assistants?
These providers have been eligible for the PSLF program since its inception in 2007 and will continue to
be eligible if they meet all other requirements. California and Texas state laws do not prohibit hospitals
and other health care entities from directly employing these other providers. The new PSLF exception is
only for California and Texas physicians because they are prohibited by state law from being employed by
certain hospitals and other health care entities
Andrew SLA
Anyone know if this will apply to teachers as well? My wife is a teacher with a large K-12 for-profit organization that has been contracted by a local school in Indiana to operate a public charter school. Per Indiana law, employees of charter schools must be employees of the organization, not the state, thus they would be prohibited from being state employees. Would this qualify under this exemption?
I doubt it but why not try.
Hello!
I have a similar question, contracted by Pacific Inpatient Medical Group in Northern California – however we work out of Sutter Health Hospitals. Who would be the contact person here, and what EIN#? Thank you
RP,
Someone at Sutter would need to sign. It needs to be someone who works at Sutter who has access to employment records. You need Sutter’s EIN and a signer at sutter. Call the Medical Staff office to inquire about loan forgiveness. They are probably getting these calls everyday and can either sign for you or at least direct you to the right contact who can sign for you.
Andrew SLA
As an RN with a master’s degree, I worked 32-40 hours/wk (per diem) in a Nor Cal KF hospital for several years and did not qualify for PSLF (nor had benefits) bc I did not have a “set schedule” while my co-workers earned forgiveness (and benefits) working 24h/wk. I then transferred to a benefitted “40h/wk set schedule” in TPMG direct-patient care in an office next to the hospital but still didn’t qualify bc it was TPMG (one building over, same property). I don’t feel anyone owes me anything, I just feel completely insulted by working so passionately in such a broken system. Such is life.
Has anyone had any luck that works for Optum/United Health Group? Which EIN are you using?