Written By Travis Hornsby, CFA®, CFP®
Editor's Note: This post is not yet fully updated regarding recent changes to the definition of “full-time” for PSLF. For PSLF, full-time is now considered working an average of 30 hours per week or more, regardless of the employer’s definition of “full-time.” For more information, see our post on PSLF changes.
Maybe you’ve thought about reducing your hours at work, but you’re afraid of losing the Public Service Loan Forgiveness (PSLF) program. After all, you need to meet the full-time PSLF eligibility requirements based on worked hours per week in order to get qualifying payments. The ultimate goal is to make 10 years of PSLF payments, and then the government wipes away your remaining balance tax-free.
But what counts as full-time employment for student loan borrowers trying to qualify for the Public Service Loan Forgiveness program? I had to do a lot of thinking when I got this question from a reader trying to help his wife receive credit for all of her qualifying PSLF loan payments.
Hi Travis, I'm in a kind of head-scratcher of a situation regarding what counts as full-time for PSLF, and I'm wondering if you might know of any resources about it.
(The (short) background is: She's been working 30 hours/week for four years, and her hospital employer has signed her PSLF ECF forms for the first three of those four years. This past year, however, they refused to sign because 30 hours is only 0.75 full-time equivalent (FTE), and therefore, according to one possible reading of the situation, not full-time at 1.0 FTE. (The other reading of the situation, which we'd been going by, is that “full-time for benefits purposes,” which begins at 30 hours, is full-time for PSLF.))
I'm just wondering if you know of anyone who's successfully pleaded with their employer to consider .75 or .8 FTE as full-time for the purposes of PSLF. I'm guessing my wife's employer decided that doing so was putting them at some kind of legal risk.
Definition of full-time for PSLF: How many hours per week to qualify?
I love hard questions like this because it forces me to go back to the definitions and regulations of the program.
According to new changes in 2023, full-time for PSLF is considered working an average of 30 hours per week or more, regardless of the employer’s definition of “full-time.” This total can be for one or more jobs if you work for multiple qualifying employers.
If your employer somehow tried to count you as full-time if you’re working less than 30 hours per week, that clearly doesn’t qualify. Thirty hours per week is the lower bound. The number of hours you must work is at least 30 hours per week or more. But now if your job doesn't consider your PSLF employment full-time at 30 hours, under these changes, you'll still be considered full-time and qualify for the program.
What is FTE and why does it matter for PSLF?
University hospitals, government organizations, and other large bureaucratic institutions often use Full-Time Equivalent (FTE) as an accounting statistic.
If you’re at 1.0 FTE, you are at a worker’s full workload, generally 40 hours per week for exempt positions. If you’re at 0.75 FTE, it means you would be at 30 hours per week.
However, many workers who put in less than 1.0 FTE receive full-time benefits, such as health insurance and retirement contributions.
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FTE differences between exempt and non-exempt jobs
You might not have known this since I didn’t before researching this article, but there are often different definitions of FTE for exempt and non-exempt positions.
An exempt position under the Fair Labor Standards Act earns a salary of at least $23,660. This means the employer does not have to pay you overtime when you work more than 40 hours per week. Employers I found online generally view 40 hours per week as 1.0 FTE. Think “white collar” workers or professionals.
A non-exempt position has an hourly wage. Workers in these roles must be given overtime if they work more than 40 hours per week. For most non-exempt roles I looked at, 1.0 FTE was 37.5 hours per week instead of 40.
Hence, 0.75 FTE for an exempt job would be 30 hours per week and 0.75 for a non-exempt job would be 28 hours per week.
If your employer was willing to sign the forms because they consider 0.75 full-time, then you would qualify for PSLF since you’re working at least 30 hours per week. However, if you were in an hourly job, say front desk security for a hospital at 0.75 FTE, you would not be working at least 30 hours a week since you’d be at 28.
Even if your employer was willing to sign off on you being full-time, you wouldn’t qualify for PSLF based on rule (1) above that says you have to work the greater of 30 hours or the employer’s definition of full-time. So your employment eligibility wouldn't quite hit the mark.
Is 0.75 FTE considered full-time?
The answer is that it depends on where you work.
Many hospital systems will give you full-time benefits at 0.75 FTE.
For example, the University of Kentucky hospital system made a change in 2005 so that employees working 0.75 FTE could be considered full-time for benefits purposes. The administration decided it was worth it to extend benefits to folks working a shorter schedule so they could retain talent.
However, if their full-time workload is 1.0 FTE, which definition wins?
My own opinion is that the rules allow an employer to sign or not sign at their discretion. So they can decide to sign your employment certification form for your qualifying public service.
Are there legal risks for employers who sign PSLF forms?
Put yourself in the shoes of the HR Director in the example at the beginning of this article who refused to sign off on the PSLF form. She probably had legal concerns that the hospital would be on the hook for civil or maybe even criminal penalties if she said that an employee was full-time at 0.75 FTE.
It’s one thing when your hospital considers you full-time for benefits, but what about when the government or the U.S. Department of Education asks if the employee is full-time?
Most people I’ve met at large public service employers in decision-making roles or those at big nonprofit organizations are very risk-averse. They don’t want to do anything that could come back on them.
Risk aversion is complicating PSLF sign-offs in HR departments
One reason for that is negative events get punished far more than positive events get rewarded.
Most HR departments have no clue about PSLF student loan forgiveness. They don’t know what they’re signing. But they do know if they commit the hospital to something they shouldn’t have, they could get in trouble.
I think they’re vastly overthinking the issue. If you consider an employee full-time for benefits purposes at 0.75 FTE, that’s your functional definition of full-time.
If the government ever had a question about why you signed off as a hospital, you could defend yourself with the fact that I’ve never seen any guidance on this issue from the Department of Education ever.
The IRS releases rules all the time on how to interpret complex tax regulations. The Department of Education should probably be doing that with the insane complexity of federal student loans these days. However, it’s not set-up to do so and probably won’t be for several years. That means right now, you want to try to follow the rules as best you can without being overly aggressive.
Worst case scenario, if an employer signs off on someone being full-time incorrectly, then the employee would just not get PSLF. Nobody would get massive fines or go to jail over an honest misunderstanding of the rules without guidelines from the government.
Major risks for employers who don't sign off on PSLF
Most hospitals and other PSLF-eligible employers do not have a clue about how valuable this benefit is. You’d be able to pay significantly less for many positions and fill them simply because of your institution being PSLF-eligible.
Right now, the PSLF program is messed up because of how it was created in 2007. By 2024, folks will start qualifying en masse.
Employers that take an unnecessarily rigid view on signing off on PSLF certification forms will absolutely lose employees to institutions that do.
Employers that consider less than 1.0 FTE to be full-time for PSLF
Risk-averse HR departments want to see that they’ll be in good company when they sign off on something they don’t know about.
Here are some employers that consider 0.75 FTE at 30 hours per week to be full time for PSLF purposes
- Children’s Hospital of Omaha – Employed >= 0.75 FTE
- Virginia Garcia Memorial Health Center – Detailed description of benefits you get starting at 0.4 FTE. PSLF sign-offs start at 0.75 FTE.
- Allina Health – Letter from Minnesota Nurse’s Association to Allina Health established 0.8 FTE or 30 hours per week as qualifying for PSLF
If you’re holding back from signing off on PSLF, you’ll lose employees to other organizations as more employers decide to sign the form at 0.75 FTE. That’s true even at lower salaries since PSLF can be worth tens of thousands per year in salary value in many cases and can help significantly with student loan repayment.
Strategies for PSLF with unhelpful employers
Regardless of what the reason is, the rules above state that if you work at least 30 hours per week at two separate employers, you can qualify for PSLF. Workers at two or more qualifying part-time jobs meeting this threshold qualify regardless of the employer definition.
That means the reader who was at 30 hours per week could’ve picked up one hour a week doing literally anything, and she would qualify for PSLF under these rules.
That in my view shows the silliness of not signing the form if your employees are at 30 hours and getting benefits.
That said, if you don’t get full-time benefits and work 35 hours a week, then I would support the employer not signing the PSLF form based on the rules of the program. However, under the new rules as stated on the Federal Student Aid site StudentAid.gov, 30 hours is now considered full-time regardless of what your employer thinks.
So the employer should sign off on that you work there if you’re trying to certify at 35 hours because it meets the 30 hours requirement.
I’ve found that if you ask for meetings with decision-makers, bring in one or more colleagues with the same issue, and explain the risk to your employer that they can lose dozens of employees when they don’t have to, they might change their mind.
Getting help figuring out if PSLF is worth the headache
If you’re working 30 hours a week, maybe you’d prefer to work even less but your high monthly payment amount is stopping you. We have a lot of strategies around helping someone work part-time without worrying about their federal student loan debt.
We also like comparing loan forgiveness options to refinancing to see if you’re making the right decision sticking with an employer for presumably lower pay. We can help you review your options, whether that's an income-driven repayment plan like income-based repayment, deferment, forbearance, and more.
While you can get some support from your loan servicer, you can reach out if you think you want professional help. We go over FAQs and help you with a customized plan for your situation.
Let us know in the comments if you’ve ever had to deal with employers giving you a hard time about the PSLF form. Feel free to use an anonymous or made up name too if you need to.
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In your example above where they were previously signing off on her forms for years prior, are you thinking that all of those years will not count? (I’m assuming that she filled out the PSLF employment certification form annually and she had a rolling count of the monthly payments that were signed off). How can that happen if they authorized the forms annually?
I think it’s unlikely the count from the years before would get reversed. However, it is absolutely up to the employer once you’re at the 30 hrs per week threshold since the PSLF ECF says it’s “30 hours a week or your employer’s definition of full time, whichever is greater.” https://studentaid.ed.gov/sa/sites/default/files/public-service-employment-certification-form.pdf
The law gives wide latitude between certain hourly ranges as to what full time actually is, which means you’re at the mercy of the employer to sign. That said, there’s little reason to not sign if you’re paying someone full time benefits.
My employer has signed off on my being full time due to the fact that I meet the requirement of “an average of at least 30 hours per week” which is one of the options as listed in the section on the “qualifying employment definitions” section of the employment recertification form. Doesn’t the fact that she works that average of 30 hours per week meet that simple criteria on that form like me (of course if the employer is okay with it)? Is there other official documents that state otherwise that you could provide me for reference please? Every individual I have spoken with at Fedloan including those from the ombudsman line have told me “it’s completely up to your employer”. I know these individuals are not reliable in any sense of the word but if that’s all the government has for us to ask questions to isn’t that credible to a certain extent if you keep very intricate details of who/when you discussed it with? Appreciate any input, thanks!
Can you explain more about what this clause means:”for a contractual or employment period of at least 8 months, an average of 30 hours per week”?
Hypothetical: Does that mean a seasonal employee at a qualifying nonprofit or government institution working 30hrs/wk for 8 months is certified for the entire year? Or, does the employee needs to find other qualifying work for the remaining 4 months of the year to be eligible for a full year of PSLF payments?
I’m thinking this clause might exist for teachers who don’t work during the summer, but I’m wondering about other nonprofits (that work seasonally with farms for example) or government professionals (Forest Service employees that work outside and only during warm months for example).
Thanks!
I would think it would apply to both those extra examples you mentioned as long as the employment during the season lasts for 8 months per calendar year. So a Forest Service employee who does 4 months of work and gets paid and then doesnt the other 8 months would not qualify.
I am an RN at a university hospital employee working 36 hrs per week (.9 FTE). My manager is signing my PSLF certification annually. I would like to drop to 16 hrs hours in my department and work in another department for 16 hrs (with a different manager) Would that be considered two jobs and would I still qualify because I am working at least 30:hours? Would I submit two certification forms? Thanks for your help!
That should qualify as its 2 separate part time jobs at a 501c3 totalling 30 hrs a week. You’d just have to get both managers to sign off that you worked there 16 hours I believe and youd def send in the form annually
What I wonder is if that would work since it sounds like 1 employer ( even though two different managers). Whenever I see the language about the part time loophole, it says employers (plural). Is be curious to know if anyone found success with 1 employer, two part time roles/ different managers.
Hilary I am in the same situation – 1 employer, two part time roles.
Curious how that will work out. I may call the ombudsman line.
Any more thoughts on this Travis?
It’s a lot tougher when it’s the same employer bc it makes it less obvious but it should probably work.
Here’s the definition from the PSLF ECF:
Full-time means working for one or more qualifying
employers for the greater of: (1) An annual average of at
least 30 hours per week or, for a contractual or employment
period of at least 8 months, an average of 30 hours per
week; or (2) Unless the qualifying employment is with two
or more employers, the number of hours the employer
considers full time.
Do your two part time jobs at the same employer would need to sum up to what the employer considers full time, not 30 hrs a week like if it was 2 or more employers.
I am a specialty fellow looking at a .8 FTE job at a large non-profit organization. The confusing part is 1.0 FTE for them is considered 32 patient contact hours and .8 FTE is 26 patient contact hours. Obviously docs work way over just the “patient contact hours” with administrative hours, charting, patient calls, etc so I definitely know I will be working over 30 hours a week. Also full time benefits start at .6 FTE for this organization. What are your thoughts Travis? Do you think if my employer considers me full time and I have in my contract that I work 26 patient contact hours and 6 hours administrative that this would be acceptable?
I think so as long as the org will sign off on your form that sounds legitimate to me.
My situation. I have worked over 30hrs per week since hire. I work for a government agency and qualify for full benefits and receive holiday pay. I am considered part time as only 40 hrs is “full time”. Fed loans told me to get a second job when I’m working 75-80 hrs. I don’t want to but I would consider it.
Should I get another job? Have the union fight for a job classification change in wording full time wording? I find it odd that you could work way more hours and not qualify vs someone working 60.25 hrs.
Weirdly you only need to work 1 extra hour as a W2 part time employee at a govt or non profit job. FedLoan allows 2 part time jobs summing up to 30 hours a week or more. So you don’t need to be working 75 hrs a week, you literally need to find basically a tiny shift somewhere and then you’d qualify through that loophole in the ECF
I worked at 2 non-profit companies full-time and ended my employment with each of them as a part-time employee (by choice). When it came time to fill out the PSLF forms, HR for both companies documented my status as a part-time employee. Between both companies, I worked for 6 years full time and now both HRs refuse to acknowledge my history as a 40-hour per week worker. I don’t know what to do.
Well to qualify for PSLF you can use 2 qualifying part time jobs as long as the total hours worked is over 30 hrs a week.
Hey Travis,
I may be pursuing a new 30 hours/week job that is consider part-time with qualifying employer. If I were to find another qualifying employer with a PRN role, would that qualify? In other words, does PRN count to the hours required? If so, do they want the average hours worked (since the ECF form request to put “averaged hours worked”)?
Also, any idea if the part-time + PRN jobs (or two part-time jobs) from the SAME employer qualifies? Thanks for the wonderful blog.
You only need a job that you’re doing 1 hour a week if youre already at 30 if that 1 job is with another employer. For two part time jobs w the same employer you need to hit the full time definition.
My husband and I were just discussing the wording of “an annual average of 30 hours per week”. I have made 71 qualifying payments at 40 hrs per week-but now am considering going part time for a year or two, but am still planning on making payments. During the course of my payments, and considering that I’m planning to be full-time again in a year or two from now when the time comes to make the last few payments- technically I will still have an average of 30 hours a week or more. I feel distrust towards the program to begin wit,h so I suspect that it is highly unlikely that that would fly, but I don’t see it spelled out anywhere in the literature. When you average all 10 years (8 are at 40 hrs per week, and 2 are at 20hrs per week) you get an average of 36 hrs per week. I am a school psychologist working an 11 month contract for a public school system. My employer considers 40 hours per week to be full-time , so would that be the disqualifier? My supervisor says they would give me .75 or .8 so that they can be signed off on, but I’m apprehensive about that. Any insights? Any literature that says otherwise that you know of? Thanks for your time and help 🙂
As long as you’re 30 hours a week and they’ll sign off on you being full time, then you’re good
But don’t you have to receive it at least be eligible for full time benefits as well?
If you work 30 hours a week, are W2 and your employer qualifies and is willing to sign off on you being full time, thats all that counts
I teach at several community colleges and my hours are usually more then 30 hours a week, and get 12 qualiffied payments a year
However just in case it drops to less then 30 hours, would I get a prorated number of qualified payments.
No it’s qualifying or not at all
If I have 2 per diem (PRN) jobs but totaling more than 30 hours/week on average, would I still qualify for PSLF? The application only shows part-time and full-time options, but not a per diem (PRN) option.
If so, my 2 employers would have to sign off on 2 separate PSLF forms… would FedLoans know to put the 2 forms together to see that I worked more than 30 hours/week?
Thank you.
Yes you would put all employers on the form and you should qualify as long as you’re W2 w these hospitals. It’s 30 hours a week minimum if you have 2 or more part time jobs that qualify collectively.
Should the 2 separate employers fill out 1 form or 2 separate forms?
Thank you!
Same form Sharon
Okay, so I have a hospitalist job that will normally do 14 12hour shifts/month, but let me work 10 12hour shifts/month, or 1440hrs/yr. That averages 27hrs/week. They are giving me full time benefits. Can I just ask for 11 shifts/month to get to 30hrs/week and would that count as long as they check “Full Time” and “30 hours/wk” on the PSLF employment certification form?
Or do I need to get a separate part time qualifying non-profit job and work average 3 hours/week more to qualify? And if I do, I thought I heard that 1099 income doesn’t count. No nonprofits want to hire someone as W2 for 3 hours/wk, they would do 1099 or not at all. Is this the case?
It has to be W2 yes, so I would ask them to sign off based on being full time if you can justify it based on conversations w your employer
Do you know of any qualifying organizations that will hire someone for 1 hour per week? I am in a situation where I work 0.8FTE (32 hours per week) at a VA hospital. I am not considered full time despite receiving full time benefits.
Maybe a church or faith community? You can do non religious work and qualify for PSLF
Hello, thank you for this very informative article! I am considering decreasing my hours from full time to 30 hrs per week at my current not-for-profit job, and picking up a 2nd job working 10 hours per week getting paid hourly (not salaried) at a for-profit company. Would I still qualify for PSLF if I work at 2 jobs but only one is not-for-profit (still working there 30 hrs per week though)? Also would the hourly pay at the 2nd job make a difference in qualifying, since it’s not technically a salaried part-time position? Thanks!
You need to be full time or have at least 2 part time jobs that are non profit that sum to more than 30. So your non profit job would have to be considered full time by the employer
Hello Travis,
I’m enrolled in PSLF. I had three different part-time positions at one college that totaled 30 hours per week, but the institution marked my form as “part-time”. I’ve received differing information from the loan forgiveness company. Some people I talk to at Fedloan state that the three jobs count as one since the EFIN number for all jobs are the same and are shown on one tax form. Others there have told me that they do count. Do I qualify with three part-time positions at one institution that equal 30 hours/week?
I’ve been waiting over 2 years for them to make a decision and I have a stack of paperwork inches high. I’ve made about 130 payments so far.
I added another two jobs that qualify for PSLF and worked them for six years (five different titles/positions) and then switched to a full-time position at another college, so 94 of the payments should count, but I can’t get anyone on the phone there that seems to know what’s going on and I just get the runaround.
If you look at the ECF form, it says “Full-time means working for one or more qualifying employers for the greater of: (1) An annual average of at least 30 hours per week or, for a contractual or employment period of at least 8 months, an average of 30 hours per week; or (2) Unless the qualifying employment is with two or more employers, the number of hours the employer considers full time.” Since your different positions were with the same employer, those three part-time jobs at one college should count.
I worked for several years as an exempt hourly employee for a public agency before becoming FT for 5 more years at that agency. My agency did not consider that FT work even though I often worked more than 40 hours/wk. in that position. I thought this would disqualify those years as counting toward PSLF. I was also employed 1/3 time as a church pianist during this time period and never considered that that position, in combination with the agency work would help those years qualify toward PSLF. Now I’m inspired to apply, even though I no longer work at either position. I’m uncertain how to get the paperwork completed. Do both employers need to fill out the form?
Your employers would have to fill out the form. However, you must meet your employer’s definition of full time.
Here’s my situation… I’m non-exempt and classified as 0.80 FTE, which is 32 hours per week. My hospital considers 36 hours as FTE, something they rarely offer due to the savings in benefits from part-time to full-time.
Here’s the rub… I almost never work 32 hours per week. I always pick up overtime (they pay double time for shifts attached to regular shifts), and I’d estimate my hours worked at an average of 50/wk. Some weeks I’ll work 32 or 40 hours when I need a break, but I typically work 48 to 64 hours per week.
So how does that work? Can I get my employer to sign off based on the fact that I consistently work above and beyond a standard FTE?
Unfortunately, your employer gets to decide whether you meet their definition of full time employment.
I have two part-time jobs with separate 501c3’s. I am usually above 30 hours/week with both jobs combined. A few weeks my hours dropped below 30. Do I get credit for the months I was above 30 or does that make my annual average below 30hrs/week and I don’t qualify for that entire year?
Hey Sunny, here is what our consultant Meagan has to say: It’s an annual average of 30hours/week so you should be fine as long as that’s not a prolonged thing.