What Counts as Full-Time Employment for PSLF?

Maybe you’ve thought about reducing your hours at work, but you’re afraid of losing Public Service Loan Forgiveness (PSLF). After all, you need to meet the full-time PSLF eligibility requirements to get qualifying payments, and after 120 of them, the government forgives your remaining balance tax-free. So how many hours per week does full-time employment for PSLF actually require?

The answer is simpler than it used to be. You’re full-time for PSLF if you average at least 30 hours per week at one or more qualifying employers. Your employer’s own definition of full-time doesn’t matter anymore.

That last part is a big deal. Picture a nurse working 30 hours a week at a hospital that signed her PSLF forms for three years, then refused in year four because 30 hours is only 0.75 FTE. That happened to plenty of borrowers before the rule changed on July 1, 2023, and it could cost them a year or more of credit.

Today, that nurse qualifies. Her average weekly hours meet the threshold, and her hospital’s FTE label is irrelevant. If the refusal cost her credit, she can submit a new PSLF form for that same period and the Department of Education will review it under the current 30-hour rule.

Definition of full-time for PSLF: How many hours per week to qualify?

In the past, borrowers working for a single qualifying employer generally had to work the greater of 30 hours per week or their employer’s definition of full-time. That created confusion for people whose employers offered full-time benefits at fewer hours than a standard full-time workload.

However, regulatory changes that took effect July 1, 2023, simplified the definition. Full-time for PSLF now means working an average of 30 hours per week or more, regardless of the employer’s definition of “full-time.” The total can be for one or more jobs if you work for multiple qualifying employers. For more background, see our post on big PSLF changes.

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. But now if your employer calls you part-time at 30 hours, you still qualify.

What is FTE and why did it make certifying PSLF confusing?

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'd be at 30 hours per week under that schedule.

However, many workers who put in less than 1.0 FTE receive full-time benefits, such as health insurance and retirement contributions.

Before the rule change, these differences complicated PSLF employment certification. Now, your average weekly hours determine whether you meet PSLF's full-time requirement, not your FTE designation or benefits eligibility.

FTE differences between exempt and non-exempt jobs

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 $35,568 and gets no overtime, and employers generally treat 40 hours as 1.0 FTE.

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, 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.

Under the current rules, if you average at least 30 hours per week at a qualifying employer, you meet PSLF's full-time requirement even if your employer considers you part-time.

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 based on a 37.5-hour workweek, 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 that schedule alone. The employer's full-time designation can't replace the required weekly average. You could, however, combine those hours with another qualifying job to reach the 30-hour threshold.

Is 0.75 FTE considered full-time?

It depends on whether you're asking about workplace benefits or PSLF eligibility.

Many hospital systems provide 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?

Before the new rules, that question complicated PSLF certification for many borrowers and employers. Today, PSLF uses its own definition: an average of at least 30 hours per week. If your 0.75 FTE schedule meets that threshold, you meet the full-time employment requirement regardless of your employer's benefits policy.

Why some employers hesitate to 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 nurse's 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 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, and most HR departments don’t know much about PSLF.

Fortunately, the current rules remove that worry. Federal Student Aid’s employer guidance tells employers to certify employees as full-time for PSLF if they average at least 30 hours per week, regardless of whether the employer considers them full-time for other purposes. An employer should use PSLF's definition of full-time when completing the form, even if it uses a different definition for staffing or benefits.

Employers still need to verify employment dates and hours before signing. The PSLF form warns that knowingly making false statements can result in penalties. But certifying an employee who averages at least 30 hours per week as full-time for PSLF simply follows the program’s rules. It doesn’t change the employee’s FTE designation or benefits.

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, considering PSLF has been historically riddled with issues and unclear guidance.

How employers handled less than 1.0 FTE before the rule change

Risk-averse HR departments want to see that they’ll be in good company. Before PSLF adopted its across-the-board 30-hour standard, these examples helped employers decide how to treat workers below 1.0 FTE:

1. Children’s Hospital of Omaha: Certified employees at 0.75 FTE or above
2. Virginia Garcia Memorial Health Center: Offered benefits starting at 0.4 FTE and signed PSLF forms starting at 0.75 FTE
3. Allina Health: A letter from the Minnesota Nurses Association established 0.8 FTE or 30 hours per week as qualifying for PSLF

Today, employers can follow the Department of Education's explicit instructions rather than looking to another organization’s FTE policy. If you were working for one of these employers or a similar one before 2023 and your forms were signed at 0.75 FTE, your credit should already be intact. If you were denied, keep reading.

Were you denied credit before 2023? You can fix it

PSLF forms are reviewed under the rules in effect when the form is reviewed, not the rules in effect when you did the work. That’s straight from Federal Student Aid’s PSLF FAQ.

So if your employer certified you as part-time before July 2023 while you were averaging 30 or more hours per week, submit a new PSLF form for that same period. Use the same employment dates. Your employer certifies your average weekly hours, and the Department applies the current 30-hour definition to count your payments.

This also applies if your employer refused to sign at all. Go back and ask again, and point them to the current employer guidance on StudentAid.gov. For physicians and other hospital employees who spent years at 0.75 FTE, this can mean recovering a lot of qualifying payments.

Strategies for PSLF with unhelpful employers

Previously, borrowers whose single employer didn’t consider them full-time could potentially meet PSLF’s employment requirement by working two or more qualifying part-time jobs with a combined average of at least 30 hours per week.

That means the nurse in our example, who was working 30 hours per week, could’ve picked up one hour a week at a second qualifying employer to meet the combined-employment rule. The additional job had to be qualifying employment — it couldn’t be just anything.

She wouldn’t need that workaround today. Her existing 30-hour schedule at a qualifying employer meets the requirement on its own.

Combining hours is still an option if you average fewer than 30 hours at one qualifying employer. For example, someone averaging 28 hours at one qualifying job and two hours at another could meet the requirement. Each employer would certify its own employment dates and hours.

Likewise, if you don’t get full-time benefits but average 35 hours a week, you still meet PSLF’s full-time employment requirement. Your employer’s benefits policy doesn’t determine that eligibility.

That said, if you run into issues, you can point to clear PSLF employer guidance on the Student Aid website. Beyond that, I’ve found that if you ask for meetings with decision-makers, bring in one or more colleagues with the same issue, and explain that the employer risks losing dozens of employees over a definition it doesn’t have to use.

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 for working part-time without worrying about your federal student loan debt.

We also like comparing loan forgiveness options with 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 (IBR), deferment, forbearance or something else.

Your loan servicer can offer some support, but if you want professional help, reach out. We’ll build a customized plan for your situation.

FAQ: PSLF hours per week requirement