August 02, 2022
Hobbies: Advocacy Medical workforce
Recently, the US Department of Education released draft regulations to reform the National Public Service Loan Forgiveness Program (PSLF). Despite the department’s stated interest in fixing its existing PSLF regulations — which inadvertently exclude many California and Texan doctors from participation — the draft regulatory text still fails to address the issue.
The California Medical Association (CMA) urgently needs all physicians, residents and medical students to send a letter to the Department of Education by August 12, 2022urging them to allow qualified physicians in California and Texas who provide care in private, not-for-profit hospitals/clinics to qualify for federal student loan forgiveness.
The Department of Education is accepting comments on its draft regulations until Friday, August 12, and we need as many of you as possible to submit a letter to show the urgency of this issue. CMA has prepared a template letter and instructions for submitting the letter through the Regulatory Comment Submission Portal. It only takes 3 minutes.
It is critically important that the Department of Education resolve this issue once and for all to ensure that physicians in all 50 states can also participate in this important program to encourage students to pursue careers in medicine and to help our patients. the most needy and vulnerable in underserved communities. If regulations are not set to allow doctors from California and Texas to participate, doctors will choose to practice in other states where they can get loan forgiveness, accelerating the worsening doctor shortage and affecting our ability to care for the patients who need us most.
Background
The PSLF program was intended to provide loan forgiveness to individuals who engage in community service for 10 years by working full-time (30 hours/week) in non-profit organizations, such as non-profit hospitals , and improve access to health care. Unfortunately, the regulations implementing the program have been narrowed to require physicians to be “directly employed”. Many doctors in the two largest states of our country have consequently been inadvertently excluded because, although they may be members of their hospital medical staff working full-time in private, not-for-profit hospitals/clinics and able to respond to all other PSLF eligibility requirements, California and Texas state laws prohibit these private, nonprofit hospitals from employing physicians. But for this legal employment ban, those doctors in California and Texas could be eligible for loan forgiveness, just as doctors in the other 48 states who similarly work in private, nonprofit hospitals are eligible for loan forgiveness. to participate.
The wording of the new draft regulations attempts to address the issue of the “direct employment” requirement in California and Texas by instead requiring physicians to “contract with” private, nonprofit hospitals. to provide payroll or similar services” in order to qualify for loan forgiveness. Although well-intentioned, the proposed settlement does not solve the problem and still excludes doctors in California and Texas because they do not contract with hospitals to provide payroll services. Additionally, many physicians in these states do not practice in nonprofit hospitals with a contract and would still be ineligible whether or not the contract is for payroll services.
The CMA, in conjunction with the California Hospital Association, the Texas Medical Association, and the Texas Hospital Association, urges the Department to accept an alternative for physicians practicing in states that prohibit direct employment. The plan would allow PSLF eligibility for California and Texan physicians 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) in the private, not-for-profit facility, is licensed through the clinical privileges accreditation process, but may not be employed by the facility due to state law. This is an additional standard for physicians in California and Texas who are prohibited by state law from being directly hired and paid by the facility.
Act before August 12
Please join the CMA in sending a strong message to the United States Department of Education that, in order to reverse physician shortages and protect access to care, qualified physicians in California and Texas must be allowed to participate in the federal loan forgiveness program. Click here to download our sample letter. Instructions for sending the letter are below:
- Update the CMA letter template by specifying medical student or doctor on the first line where highlighted in yellow and add your name at the end. Feel free to add personal comments as well.
- Click here to access the Department of Education’s regulatory comment submission portal.
- Under the Proposed Rule: General Student Aid Provisions…”
click on the “comment” button. - Click on “write a comment/comment”.
- Copy and paste the CMA letter template with your name in the comment box.
- Scroll down and fill in your email address.
- Click on “individual” and fill in your personal information.
- Click on the “I’m not a robot” box.
- And be sure to click “SUBMIT REVIEW” at the end.
Thank you in advance for helping us send a strong message to the Department of Education to ensure physicians in all 50 states can equally participate in this important program.
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