This is facially absurd, but it may actually be a valid point. There are several student loan websites that suggest that a part-time faculty position at a community college is the only part-time position that satisfies the employment requirements for the PSLF program. Other websites are adamant that you must be full-time regardless of the position or that you must have two part-time positions and through the amalgamation of the hours worked in those two positions that one could meet the full-time requirement. Notably, the statutory language supports the interpretation that a part-time faculty position is not only qualifying, but sufficient (this, very possibly, could be an error in the statutory writing). By contrast, the Department of Education’s guidance is wholly unresponsive on this point.

So, here is the full detailed inquiry per a letter I wrote to the Department of Education this week and for which I received a wholly unresponsive reference to a student loan website.

I was curious whether you had any guidance regarding a particular amendment included within the Higher Education Opportunity Act (of 2008). The amendment adjusted the qualifying “public service employment” as articulated in the PSLF’s (Public Service Loan Forgiveness Program) enabling statute (the College Cost Reduction and Access Act of 2007).

The amendment that I am interested in is the inclusion of “part-time faculty at community colleges” under “faculty teaching in high-needs subject areas or areas of shortage” per Section 455(m)(3)(B)(ii) (20 U.S.C. 1087e(m)(3)(B)(ii)).

The amended language in question is on page 185 of the document below which is a PDF of the final and passed version of the Higher Education Opportunity Act (of 2008)

http://www.gpo.gov/fdsys/pkg/BILLS-110hr4137enr/pdf/BILLS-110hr4137enr.pdf

For purposes of understanding the amendment, I found this link helpful, too—http://www.tgslc.org/pdf/HEOA_summary.pdf

My questions are as follows:

(1) Does teaching of any community college class qualify? Only standard or transferrable community college courses? Only community college courses in a particular field?

(2) Is working as “part-time faculty at [a] community college[]” sufficient to satisfy the employment prong of the PSLF requirements OR is it merely included towards satisfying some broader full-time service (i.e.—is it not sufficient, but qualifies, and may be stacked in conjunction with another qualifying position to satisfy some 30-hour requirement)?

(3) If the latter (it qualifies, but is not by itself wholly sufficient), how are the hour requirements calculated for work as a “part-time community college faculty member”? Is there a baseline calculation of how much this counts towards the requirement based on how many course credits are taught? Is there some other method of calculation.

is there any more info on this and whether teaching one course at a community college qualifies or how to account for the hours towards PSLF?

It’s my understanding that if the community college is non-profit, any hours worked there, part-time, or full-time, would count. If you are part-time, you’d have to average 30 hours more a week, or have another part time job elsewhere at another qualifying institution to have a combined total of 30 hrs a week or more. It is questionable how many hours teaching one course at a community college would count for, and that seems to be dependent entirely on how the HR department chooses to dictate actual number of hours worked per credit hour. I worked at two universities part time and was able to qualify. I can’t imagine it would be different for a community college, unless the school was for-profit.

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