Overview
- The Notice of Proposed Rulemaking, published Aug. 18, implements a March directive from President Trump and opens public comments through Sept. 17.
- Borrowers would lose future PSLF credit if their employer is found to pursue a “substantial illegal purpose,” with examples including violations of immigration law, certain gender-affirming care the department characterizes as “chemical castration or mutilation,” and acts of terrorism.
- The department could deem employers ineligible based on court outcomes or its own preponderance-of-evidence determinations; organizations can appeal, but the process is not specified, and individual borrowers cannot request reconsideration.
- The proposal is explicitly non-retroactive, protecting PSLF credit already earned, and it targets a potential effective date of July 1, 2026.
- Officials note the changes may delay or prevent forgiveness for a subset of borrowers, while unions and higher-education groups warn of ideological targeting and signal likely legal challenges.