On June 30, 2025, Department of Education Negotiated Rulemaking Committee held a hearing on proposed rules to change the Public Service Loan Forgiveness program. Below are NCN's public comments, slightly edited for clarity.
Good Afternoon. My name is Tiffany Gourley Carter, Public Policy Director and Counsel at the National Council of Nonprofits (NCN). Thank you for the opportunity to speak today on the importance of PSLF to the charitable nonprofit sector, and – most importantly – to the people who dedicate their careers to public service.
For more than 30 years, NCN has championed, connected, and informed the nonprofit sector. We, and our more than 30,000 nonprofit members, strongly oppose any efforts by the Department of Education (Department) to unlawfully restrict which 501(c)(3) nonprofits are eligible employers under the program. The proposal to limit nonprofits based on their missions and who they serve exceeds the Department’s legal authority.
Nonprofits make up approximately 10% of the workforce, employing more people than the construction, finance, and manufacturing industries. And we are unique in that nonprofit employees are dedicated to public service. That’s why charitable nonprofits are the second-largest category of eligible employers for PSLF, behind only service in government.
Charitable nonprofits rely on PSLF to attract and retain the high-performing workforce needed to address the pressing needs of everyday life. Nonprofits run local food banks, serve veterans, assist domestic violence survivors, deliver meals to seniors, provide faith-based services, teach kids in after school programs, and much, much more. Nonprofits are woven into the fabric of every community in America. They must be able to identify and meet those local needs without political interference, fear of retribution, or removal from a program designed to support their employees.
The PSLF authorizing statute clearly states that the term “public service job” includes full-time work at 501(c)(3) organizations. The bipartisan law states that an eligible employer is “an organization that is described in section 501(c)(3)." Put simply, the Department does not have the legal authority to restrict which 501(c)(3) organizations do or do not qualify under the law.
In addition, this proposal risks politicizing the nonpartisan work of nonprofits. It would allow each administration, regardless of political party, to decide what counts as an allowable employer under PSLF without an objective set of criteria.
Nonprofits are the most transparent sector in civil society with strong oversight at the federal and state levels. Moreover, the Department’s proposal is rendered moot because the IRS already has a process to determine 501(c)(3) status. The Department of Education is required to cover those organizations that meet those rigorous standards.
PSLF is designed to make it affordable for individuals who choose this career path despite often lower paying jobs. It allows them to contribute to society and the economy by giving back to others without having to worry about the overwhelming burdens of educational debt.
Preserving the current definition of qualifying employer, without limitations, serves the best interest of nonprofit employees, recent grads pursuing public service, and taxpayers who depend on strong, community-based solutions.
Thank you.
More About PSLF
- Public Service Loan Forgiveness, National Council of Nonprofits
- Public Service Loan Forgiveness, Federal student Aid
- Preserve PSLF, The Coalition to Preserve PSLF