Stafford Loan Justice

A Proposal for Public Service Forgiveness

I had a deep thought today about how adjunct and contingent faculty working part time in the public service sector might have the opportunity to fully participate in the Public Service Loan Forgiveness Program.  Due to higher ed cutbacks, many adjuncts and contingent faculty don’t teach five courses @ 40 hours per week and thus do not qualify for participation under the current Public Service Loan Forgiveness Program.

Simply, the Program could be amended by adjusting the amount of payments with hours worked. The first place to start, as Deanne Loonin,** Director of National Consumer Law Center’s Student Loan Borrower Assistance Project suggests, is to have the Department of Education define full time employment:

2. Simplify and remove inequity in the definition of full-time employment for Public Service Loan Forgiveness. (34 C.F.R. § 685.219). Section 401 of the CCRAA defines a “public service job” specifically as a full-time job, but it does not define “full-time.” In its final regulations governing public service loan forgiveness (Sec. 685.219(b)), the Department has defined “full-time” as working in qualifying employment in one or more jobs for the greater of –;

(i)(A) An annual average of at least 30 hours per week, or
(B) For a contractual or employment period of at least 8 months, an
average of 30 hours per week; or
(ii) Unless the qualifying employment is with two or more employers, the number of hours the employer considers full-time.

The second half of clause (ii) creates both unnecessary administrative complexity and inequity for individuals whose employers consider full-time to be more than 30 hours per week. Borrowers will have to submit proof of their employer’s definition of full time, and the Department will have to collect and verify this information for each borrower in the Public Service Loan Forgiveness program. Defining full time as 30 hours per week for all applicants, would greatly simplify the administration of the program and ensure that all borrowers are treated equitably with regard to eligibility for Public Service Loan Forgiveness. (p. 5-6)

So for example, if one works less than the proposed 30 hrs/full time – let”s say 25-28 hours teaching courses at several institutions – the repayment schedule might be adjusted up from the current 120 payments to perhaps 125-130.  Or an extra service component could be added to the program. Either way, my plan would allow adjuncts and contingent faculty to participate in loan forgiveness even if they teach at several institutions in order to scrape out a living (often without benefits).  I’m not sure if the Department of Education has authority to adapt the program or if Congress must amend the College Cost Reduction and Access Act of 2007 to enable public service part timers to qualify.

According to the Digest of Education Statistics (2010), in fall 2009, there were 1.4 million faculty members in degree-granting institutions, including 0.7 million full-time and 0.7 million part-time faculty (“Faculty, Staff, and Salaries,” para. 1).  In sum: 0.7 million part time faculty teaching at colleges and universities around the U.S. can’t participate in the Public Service Loan Program even though they might teach almost full time and to boot, at several institutions.

Isn’t it time to really reward part time faculty for their public service?


** See Loonin’s excellent proposals in Written Testimony of Deanne Loonin, Director of National Consumer Law Center’s Student Loan Borrower Assistance Project in Response to the May 5, 2011 U.S. Department of Education Notice of Establishment of Negotiated Rulemaking Committees and Notice of Public Hearings, Submitted: May 20, 2011 at:

Update April 20, 2012

MLA (Modern Language Association) offers a searchable database of higher ed institutions. While not current, the database lists number of tenure track faculty and adjunct and contingent faculty.

Written by S.

July 18, 2011 at 1:28 am