Tackling the Public Service Loan Forgiveness Form: Employer Tips
You may have had an employee ask you to certify their employment on something called the Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application (PSLF form). The PSLF form is your employee’s request to have us, the U.S. Department of Education, review their eligibility for the PSLF and/or TEPSLF program.
These programs have many requirements, which you can learn more about at StudentAid.gov/publicservice. One of these requirements is that your employee must demonstrate that they have made 120 qualifying student loan payments while employed by a qualifying employer. This is where you, as an employer, contribute to the process.
This article will provide the information and resources you need to certify your employee and submit your signature.
Why PSLF and TEPSLF Are Important to Your Employee and You
The PSLF and TEPSLF programs were created to encourage student loan borrowers to enter the public sector of the workforce. After a borrower certifies their 120 qualifying payments, we forgive their remaining Direct Loan principal balance and accrued interest.
Tip: Advertise that you are a PSLF qualifying employer.
While this is a potentially life-changing benefit for your employee, it’s also an opportunity for you. You can use your eligibility as a qualifying employer for the PSLF and TEPSLF programs as a recruitment tool to attract highly qualified employees to your organization.
The PSLF Help Tool and Employer Database
Using the PSLF Help Tool, a borrower (your employee) can prefill and generate their PSLF form by searching for their employer (you) in our database. We’ve worked hard to build and refine a large database of employers. Our database includes both eligible and ineligible employers and is always growing (more on this later).
Tip: Strongly encourage your employees to opt to have their forms signed electronically when they use the PSLF Help Tool.
Your employees can now request that you review and certify their employment electronically via DocuSign. This means PSLF forms can now be electronically submitted to the PSLF servicer—no more need for paper applications and fax machines!
The PSLF Form
The PSLF form has three parts: borrower demographics, employment information, and certification.
We’ll go into more detail later about how to correct errors you see on the form. Here’s what you should expect to see in each section of the form:
Part 1: Borrower Demographics
The first part of the PSLF form is completed by the borrower and provides you with all the information you need to confirm that the employee is in fact your employee. There should be nothing in this part that you would need to modify or change.
Part 2: Employment Information
The second part of the form is where you may need to review your records and confirm or modify information provided by your employee. Specifically, this part includes the Employer Identification Number (EIN) and how long the employee worked for you (employment/certification period). We’ll go over more detailed info about EIN and employment periods below.
Part 3: Employer Certification
In the third part of the form, your representative (who we refer to as an “authorized official”) must certify that the information on the form is correct. We’ll cover who counts as an authorized official further below.
Your authorized official must provide all the information requested in this section of the form, including the date, their contact information, their title, and especially their signature. If these questions are unanswered, your employee’s form will be incomplete and cannot be processed.
Employer Identification Number (EIN or FEIN)
We instruct the borrower to search for their employer using the EIN that appears on their IRS Form W-2.
Tip: Direct your employees to use the PSLF Help Tool to generate their PSLF form using the EIN that appears on their W-2.
We know that employers may have more than one EIN for different purposes. The EIN that is used for payroll is what would appear on a borrower’s Form W-2 in box b. You may be familiar with this EIN as the one that you report to the IRS on your Form W-3 (Transmittal of Wage and Tax Statements). Do not change the EIN that is included on a PSLF form generated by the Help Tool unless you are indicating that the employee does not receive a W-2 that includes that EIN.
The employer name and address included in our database and populated on the PSLF form may not be an exact match to the name or address you most commonly use for your organization. We try to make sure that the employer names in our database are easily recognizable for the borrower. However, much of this information is sourced from official IRS documents or other publicly sourced databases, so the name populated on the form may differ from the name you and your employee expect to see.
When we are aware of “Doing Business As” names, we present the employee with all the options we have in the database.
Government Employers and Shared EINs
Many government employers (at all levels) use centralized payroll processors or share a single EIN across multiple departments or agencies. When this is the case, you shouldn’t be concerned if the name that appears on the form is not an exact match for the specific department or agency that your employee works for.
For example, state employers often have a shared statewide EIN, which shows up in our database as “[Name of State] – All Employees.” Similarly, an EIN may be shared by multiple departments in a municipality, but the name in our database may simply be “City of [Name of City].”
You are certifying that the EIN on the PSLF form is what your department or agency uses for payroll purposes. For the sake of PSLF eligibility, all we’re concerned about is that the applicant works for a qualifying employer—not a specifically named employer.
Contract employees are generally issued a 1099 form instead of a W-2 form. These employees are classified as receiving non-employee compensation. You should not certify contract employees as employees of your organization for the purposes of PSLF unless they meet the exception below.
Note: We recognize that there may be cases in which an employee physically works in your space but is actually an employee of a contractually hired or separate organization. That person would be an employee of that other organization for PSLF purposes and should include the EIN that appears on their W-2 issued by that organization unless they meet the exception below.
The exception to this is when a contracted employee is filling a position or performing a service that under applicable state law, can’t be filled or provided by a direct employee of your organization. This is most common in states that have laws preventing health care facilities from hiring employees directly, so they contract with physicians’ groups to provide services. If this is the case, the contracted employee should report the EIN of the qualifying employer on their PSLF form (not their direct employer whose EIN appears on their W-2 or 1099) and have that employer certify their employment as an employee filling a position or providing a service that can’t be filled or performed by a direct employee due to state law.
Professional Employer Organizations (PEOs)
Does your organization use a PEO for human resource functions? If so, your employees should not use the EIN on their W-2. That’s because if you use a PEO, the EIN for payroll would be the EIN of the PEO provider, not yours. PEO providers are generally organized as for-profit organizations and are therefore ineligible for the PSLF program.
Instead, your employees should search our employer database using the EIN of the employer for whom they physically work (you). We recommend you inform your employees of what your company’s EIN is in advance.
When your employee uses the PSLF Help Tool or manually completes a PSLF form, they are asked to provide their dates of employment, which we refer to as the “Employment or Certification Period.” This is a field that your authorized official is asked to certify when they sign the form.
The PSLF form allows only one certification period per form. An employee that has had both full-time and part-time employment with you should provide multiple forms with different certification periods so you can certify their full-time and part-time employment separately.
Only periods of employment after October 1, 2007, need to be certified since that is when the PSLF program began.
Generally, we suggest that borrowers recertify their employment
- when they change employers, and
- when they switch between full- and part-time employment with the same employer.
This helps the borrower to track their eligibility and progress toward forgiveness.
What counts as full-time?
The definition of full time has been simplified to mean that an employee is considered full time for PSLF purposes if they work an average of 30 hours per week during the period being certified regardless of whether you consider this full time for other purposes (such as health benefits). This average calculation would include time spent on employer provided leave or leave granted under FMLA.
For a monthly payment to count as eligible for PSLF, the borrower must be a full-time employee with a qualifying employer in the month that they make a qualifying payment.
In general, we ask that you look at the period of time the borrower is requesting you certify and ask yourself: “Do I consider this employee to have worked an average of 30 hours per week during this period of time?” If your answer is yes, mark this employee as full-time and provide an average number of hours per week of 30 hours or more. If your answer is no, mark part-time and determine the average number of hours per week this employee works.
Note: as long as you have certified that your employee is full time because they work 30 or more hours a week on average, the exact number of hours worked is unnecessary. So, if your employee’s average hours per week is not a whole number, standard rounding rules should be used.
You should certify periods of employment when your employee was not full-time. Someone can still qualify for PSLF if they work part-time for more than one qualifying employer, as long as their combined total hours is 30 hours or more.
Teachers often work for a contractual period of at least eight months of the year but are still considered annual employees. In these cases, you should determine if they work at least 30 hours per week during the period they are contracted. So long as they are, you can report them as employed full-time for the full 12 months. This approach also applies generally to other employees who work a contractual period of eight months of the year but are considered annual employees.
Adjunct and non-tenure-track faculty are usually compensated based on their student contact hours. To determine full-time eligibility for these employees, you should multiply the number of contact hours by at least 3.35. If you use a similar multiplier for other reporting purposes, you should use that multiplier in this circumstance, so long as it is not less than 3.35. If the result is 30 hours or more, they should be marked as full-time. If the result is less than 30 hours, mark them as part-time and report the average weekly hours produced by the calculation.
An “authorized official” is anyone in your organization who has access to and is authorized to review employment information about your employees. Typically, this is someone in the human resources or personnel department. You can determine who are the appropriate individuals to certify your employees’ PSLF forms.
Your employees will need your authorizing official’s email address to certify employment electronically. If your employee has their certification request sent to the wrong person, that’s okay! The request email has instructions to redirect the email to the right person. To help facilitate this process, we suggest you inform all your employees of your authorizing official’s name and email address.
Tip: Identify who is responsible for certifying PSLF forms, and let your employees know the email address they should use to request that their form be signed electronically.
An important responsibility of the authorized official is confirming that the information being reported on the PSLF form is accurate, particularly the dates of employment and employment status (either full-time or part-time). If you determine that your employee has included incorrect information based on the employment data you have on file, you must correct that information.
If you are making these corrections on a paper form, you must cross through the answer provided, write in the correct information, and initial the change. If you are making corrections in a form you have been asked to digitally sign, your corrections will be accepted, the system will identify that the employer corrected the data, and the employee will be informed by email that a correction was made. You may want to discuss with your employee why you corrected information to prevent repeated errors.
Similarly, you can decline to certify a form that you are sent electronically for a signature. Your employee will be notified that the request was denied but will not be provided a reason for the denial. We recommend you discuss with the employee why the request was denied so that they don’t continue to submit the same information.
When an employee requests a digital certification, you’ll receive an email from DocuSign (dse_NA4@docusign.net) with the instructions needed to review the information on the form and to provide your digital signature. Once you’ve provided your signature electronically, the form is automatically routed to the employee’s loan servicer for review—no need for printing or mailing.
We strongly encourage you to adopt this method of signing your employees’ forms. And we ask that you encourage your employees to use this feature as well.
If your employee is not able to use the PSLF Help Tool or chooses not to request a digital certification, they will still be provided a paper PSLF form that will need to be signed by both the borrower and an authorized official using an acceptable signature.
Accepted Signatures for Paper Forms
An acceptable signature must be one of the following:
- A signature drawn by hand in ink on a physical form (which can then be scanned and sent electronically or faxed)
- A signature drawn electronically by hand using a pointing device such as a mouse or stylus
- A signature drawn by hand and then digitized and embedded in the document
Aside from the physical signature option, Adobe Acrobat Reader allows you to provide the acceptable signatures mentioned above using its standard suite of electronic signature options.
Unacceptable signatures include the following:
- A digital certificate-based signature (except for the digital signature option available via the PSLF Help Tool that you receive as an email request from DocuSign)
- A typed signature (even if it is typed using a font designed to mimic a signature—this includes the typed signature option available in Adobe Acrobat Reader)
If your employee used one of these unacceptable signatures, we recommend that you notify them before signing. The loan servicer rejects forms with unacceptable signatures, so you’d need to sign a new form that has an acceptable signature.
Are You an Eligible Employer?
To be included in the employer database as an eligible employer, you must be a
- U.S.-based governmental organization at any level (federal, state, local, or tribal), including the U.S. military;
- not-for-profit organization that is tax-exempt under Section 501(c)(3) of the Internal Revenue Code; or
- not-for-profit organization (other than a 501(c)(3) organization) that provides certain types of qualifying public services.
Some examples of ineligible employers are for-profit organizations, partisan political organizations, and labor unions.
If you’ve been asked to certify an employee’s PSLF form that was generated using the PSLF Help Tool or received an email asking you to electronically sign your employee’s PSLF form, it means you are already in our database as an eligible employer.
Don’t worry if your organization is not already in our employer database as an eligible employer. We currently have more than 3.7 million employers in our database, but our database does not contain every employer. We constantly add new employers as borrowers introduce us to new ones.
Checking Your Eligibility in the Employer Database
If your employee brings you a manually completed form, they may have been unable to generate a PSLF form using the PSLF Help Tool because your organization is
- not already in the database or
- in the database as ineligible.
TIP: Check that your employee is using the correct EIN. An incorrect EIN is the number one reason people can’t find their employer in the database.
You can check to see if your organization is in the employer database on our Search Employer Eligibility for PSLF page. There, you can search the database using the EIN your organization uses for payroll purposes. You should also select a date range that your organization was in operation or eligible because our database will return results that are specific to the range of dates provided.
When you search, you will see one of four results:
- Not Found
If you are in the database as eligible, congratulations! You should recommend that your employee use the Help Tool to generate their form. And since your organization is eligible, your employee can also request that you certify their employment electronically.
If you see that your organization is ineligible, you should review the eligibility criteria. If you believe that your organization should be eligible, provide your employee with documentation (described in the next section) to upload with their request for eligibility review.
If you see that your organization is undetermined or not found, we have not previously reviewed your organization’s eligibility. Your employee can provide information when they use the Help Tool that will allow us to make an eligibility determination.
Helping Us Determine Your Eligibility
When a borrower creates a case for eligibility review, they can submit additional documentation to help us in our determination. If you know that you meet the eligibility requirements, you should provide your employee with documentation. The kind of documentation you should provide depends on the type of organization you are. But here are some examples of what we’re looking for:
- Articles of Incorporation showing that you are a non-profit organization
- The state or local statutes that establish you as a governmental organization
- Evidence that you are treated as a disregarded entity of an eligible organization
- Documentation that you have entered into a PEO agreement that provides the FEIN/EIN of the non-PEO co-employer
- Documentation of your organization’s FEIN/EIN (especially when you see that your organization is “not found” in the database)
- Descriptions of your organization’s services that you believe qualify you as a PSLF eligible employer (if you are a nonprofit organization other than a 501(c)(3)).
If you provide your employee with the type of information above, we will be less likely to request additional information to complete our review.