Dental groups urge safeguards in student loan forgiveness rule

ADA-led letter discusses proposed changes to Public Service Loan Forgiveness program

A coalition of 13 dental organizations, including the ADA, is urging the Department of Education to exercise caution before finalizing a new rule affecting millions of student loan borrowers enrolled in the Public Service Loan Forgiveness program, according to comments filed Sept. 17.

The proposed rule would expel employers from the Public Service Loan Forgiveness program for 10 years if they are found to be taking part in activities with a “substantial illegal purpose.” The goal is to prevent taxpayer-funded loan forgiveness from benefiting employees of organizations engaged in unlawful activities.

“While we support the intended purpose of this rule change — which is to remove bad actors from the PSLF program — we would like to see safeguards in place to ensure participating dentists are not penalized should their employer’s qualifying status be suddenly removed,” the coalition wrote. “We would also like to avoid unnecessary interruptions to care delivered to those in need before allegations of qualifying employer misconduct are substantiated.”

The Public Service Loan Forgiveness program forgives all federal student loan balances for borrowers who have made 10 years of on-time payments — and had uninterrupted employment in certain public service jobs for qualifying employers. Qualifying public health employers can include community health centers, federally qualified health centers, teaching health centers, migrant health centers and others that furnish a disproportionate amount of care to those who cannot afford to pay.

Under the proposed rule, participating dentists would have one month to find new qualifying employment if the Education Department deems their employer to be guilty of illegal activities, as defined by the department.

The coalition recommended a six-month deferment period for affected borrowers, reinstatement of program eligibility if a court later overturns an employer’s disqualification, and due process protections before any changes in employer status are finalized. It also urged the department to differentiate between unlawful discrimination and broader interpretations of illegal activity, and to allow corrective action plans for less serious infractions.

The group emphasized the critical role the Public Service Loan Forgiveness program plays for new dental graduates. According to the letter, 78% of dental school graduates with debt owe more than $312,000, making the program an important tool for enabling them to work in public health and underserved communities.

“The PSLF program is a pathway these indebted dentists can use to achieve financial independence while advancing oral health equity for the vulnerable and underserved,” the letter stated. “We are confident that those noble ends can be preserved while also removing bad actors from the program.”

Organized by the ADA, the letter was signed by 13 national dental groups. They include the Academy of General Dentistry; American Academy of Oral & Maxillofacial Pathology; American Academy of Pediatric Dentistry; American Academy of Periodontology; American Association for Dental, Oral, and Craniofacial Research; American Association of Endodontists; American Association of Oral and Maxillofacial Surgeons; American Association of Orthodontists; American Dental Education Association; American Society of Dentist Anesthesiologists; Hispanic Dental Association; and Society of American Indian Dentists.