AAMC Responds to Proposed Rule on PSLF Eligibility and Qualifying Employers

The AAMC submitted comments (PDF) to the Department of Education related to proposed rulemaking to amend regulations on the Public Service Loan Forgiveness (PSLF) program.

The AAMC's response opposes provisions in the proposed rule that could negatively impact medical students. The letter emphasizes the PSLF as a critical federal program that strengthens the physician workforce and improves access to care in underserved communities. The comments urge the department to clarify the definition of qualifying employers under current law, ensure transparency in future eligibility determinations, and maintain program stability amidst organizational change within the department. The letter interprets the regulation to maintain PSLF eligibility for physicians when the state in which the employer operates neither prohibits nor restricts the types of care provided.

The AAMC also joined a letter from the higher education community (PDF) opposing the proposed rule, noting that the department's proposal to adapt the definition of qualified employers is not aligned with the law or congressional intent of the program and emphasizing the potential harm to borrowers and the communities.

The Department of Education published a notice of proposed rulemaking on Aug. 18 in the Federal Register to amend regulations governing the PSLF program, effective July 1, 2026. Among other regulatory changes, this proposed rule would amend the definition of qualifying employer, describes activities that have a "substantial illegal purpose," address impact on borrower eligibility, and create a process for employers to respond if found ineligible [refer to Washington Highlights, Aug. 22].