U.S. Department of Education Issues Request for Information on Operational Approaches to Extend Public Service Loan Forgiveness to Early Childhood Educators

The U.S. Department of Education (the Department) issued a Request for Information (RFI) to help the Department better understand operational aspects of potentially expanding Public Service Loan Forgiveness (PSLF) for workers in early childhood education (ECE) settings.

“Early childhood educators help young children learn, grow, and thrive. But they are often poorly compensated, and student debt is a problem. If these educators can access Public Service Loan Forgiveness, we can help our youngest children, their families, and their communities,” said U.S. Under Secretary of Education James Kvaal.

Since its creation in 2007, PSLF has been available to Federal student loan borrowers who are employed by a government or certain types of not-for-profit organizations. Participating borrowers see the remaining balance of their Federal student loans forgiven after making 120 qualifying payments on their loans, which typically takes about 10 years. Through the Biden-Harris Administration’s efforts to overhaul this program and provide relief to as many borrowers as possible, more than 900,000 borrowers (compared to 7,000 prior to this Administration) have already been approved for $68 billion in forgiveness through PSLF.

While many borrowers have received relief, under the current PSLF program rules, hundreds of thousands of ECE educators, many of whom operate small businesses, are excluded from the program because of their employer’s tax status. The ECE workforce, regardless of the tax status of the employer, is made up almost entirely of women, including a disproportionate number of women of color and immigrants. Additionally, the ECE workforce is among the lowest-paid categories of occupations in the country.

Based on data from the National Survey of Early Care and Education conducted by the Department of Health and Human Service’s Office of Planning, Research, and Evaluation, extending PSLF eligibility to include employers of ECE workers, regardless of their employer’s tax status, could potentially allow more than 450,000 ECE workers—about 68,000 in home-based settings and 390,000 in center-based settings—to make progress toward PSLF if those workers have Federal student loans. This reflects roughly one-third of the overall ECE workforce.

Since day one, the Biden-Harris Administration has worked to improve the broken student loan system, including making lasting improvements to the PSLF program. This request will help the Department gather important information about how it could implement any potential expansion of PSLF for ECE workers, yet another step toward these goals.

In July 2022, the Department published a notice of proposed rulemaking (NPRM) in the Federal Registerthat proposed improvements to PSLF to reduce regulatory and administrative barriers that have historically made it more difficult for borrowers to make progress toward PSLF. Additionally, in the NPRM, the Department asked directed questions about the possibility of allowing employers that operate as private, for-profit businesses and employ ECE workers to be considered eligible employers for PSLF. In November 2022, the Secretary published these final regulations in the Federal Register. Although the Department received many detailed comments in response to the directed questions, those final regulations did not address whether, or under what circumstances, private, for-profit ECE providers employing borrowers working in ECE should be treated as qualifying employers for PSLF.

Accordingly, the Department is soliciting comments from researchers, academics, policy experts, administrators, and other individuals familiar with ECE employer data and the administration of ECE programs about how the Department would determine employer eligibility and related considerations if for-profit ECE employers who provide services listed in the statute were to be considered eligible employers. Members of the public will have 30 days to submit comments for the Department to then review. The comments received in response to this RFI will not be used as part of the rulemaking related to the treatment of for-profit employers, including ECE providers, and eligibility for PSLF. Instead, the feedback from this RFI will help inform the Department’s understanding of different operational approaches.