August 02, 2022
Area(s) of Interest: Advocacy Physician Workforce
Recently, the U.S. Department of Education launched draft rules to reform the nationwide Public Service Loan Forgiveness (PSLF) program. Despite the division’s acknowledged curiosity in fixing its current PSLF regulation—which inadvertently excludes many California and Texas physicians from taking part—the draft regulatory language inexplicably nonetheless fails to repair the issue.
The California Medical Association (CMA) urgently needs all physicians, residents and medical college students to ship a letter to the Dept. of Education earlier than August 12, 2022, urging them to enable certified California and Texas physicians who present care in personal non-profit hospitals/clinics to obtain federal pupil loan forgiveness.
The Dept. of Education is accepting feedback on its draft rules by Friday, August 12, and we’d like as lots of you as attainable to submit a letter to present the urgency of this matter. CMA has ready a pattern letter and directions for sending the letter through the regulatory remark submission portal. It solely takes 3 minutes.
It is critically necessary that the Dept. of Education resolve the issue as soon as and for all to make sure that physicians in all 50 states can equally take part on this necessary program to encourage college students to pursue careers in drugs and to assist our neediest, most susceptible sufferers in underserved communities. If the rules should not mounted to enable physicians in California and Texas to take part, physicians will select to apply in different states the place they will obtain loan forgiveness, accelerating our worsening doctor shortages and harming our capacity to look after the sufferers who want us most.
Background
The PSLF program was supposed to present loan forgiveness to people who commit to group service for 10 years by working full time (30 hours/week) in non-profit organizations, comparable to non-profit hospitals, and enhancing entry to well being care. Unfortunately, this system’s implementing rules had been narrowed to require physicians to be “directly employed.” Many physicians in our nation’s two largest states consequently had been inadvertently excluded as a result of, whereas they might be members of their hospital medical staffs working full time in personal nonprofit hospitals/clinics and ready to meet all different PSLF eligibility necessities, state legal guidelines in California and Texas prohibit these personal, non-profit hospitals from using physicians. But for this authorized prohibition on employment these California and Texas physicians may very well be eligible for loan forgiveness simply as physicians from all different 48 states who equally work in personal non-profit hospitals are eligible to take part.
The language within the new draft rules makes an attempt to clear up the issue of requiring “direct employment” in California and Texas by as an alternative requiring that physicians “contract with” personal non-profit hospitals “to provide payroll or similar services” to obtain loan forgiveness. While well-intended, the proposed regulation doesn’t clear up the issue and nonetheless excludes California and Texas physicians as a result of they don’t contract with hospitals to present payroll companies. Moreover, many physicians in these states don’t apply in nonprofit hospitals with a contract and would nonetheless be ineligible no matter whether or not the contract was for payroll companies.
CMA, working collectively with the California Hospital Association, the Texas Medical Association, and the Texas Hospital Association, is urging the Department to settle for an alternate for physicians working towards in states that prohibit direct employment. The plan would enable PSLF eligibility for California and Texas physicians by further written certification from a licensed official of the general public service group (hospital, clinic) certifying that the doctor works full time (30 hours/week) within the personal non-profit facility, is allowed by the scientific privileges credentialling course of, however just isn’t ready to be employed by the ability due to state legislation. This is a further normal for California and Texas physicians who’re prohibited by state legislation from being immediately employed and paid by the ability.
Take Action by August 12
Please be part of CMA in sending a powerful message to the US Department of Education that so as to reverse doctor shortages and shield entry to care, certified California and Texas physicians have to be allowed to take part within the federal loan forgiveness program. Click right here to obtain our pattern letter. Instructions for sending the letter are under:
- Update the CMA pattern letter by specifying medical pupil or doctor on the primary line the place highlighted in yellow and add your identify on the finish. Please be at liberty to add private feedback as nicely.
- Click right here to entry the Dept. of Education regulatory remark submission portal.
- Under the Proposed Rule: Student Assistance General Provisions…”
click on on the “comment” button. - Click on “write a comment/comment.”
- Copy and paste the CMA pattern letter along with your identify into the remark field.
- Scroll down and fill in your e-mail deal with.
- Click on “individual” and fill in your private info.
- Click the “I’m Not a Robot” field.
- And be certain to hit “SUBMIT COMMENT” on the finish.
Thank you prematurely for serving to us ship a powerful message to the Dept. of Education to make sure that physicians in all 50 states can equally take part on this necessary program.
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