MEMORANDUM OF UNDERSTANDING - Counting Hours Worked for the Public Service Loan Forgiveness (PSLF) Program

Sep 19, 2026

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Memorandum of Understanding between Santa Monica Community College District and Santa Monica College Faculty Association, effective September 12, 2017, defines how “hours worked” is calculated for applications to the Public Service Loan Forgiveness (PSLF) program. It confirms full-time certification at the PSLF minimum of 30 hours per week. For part-time and reduced-load faculty, it adopts IRS Safe Harbor and reasonable standard rules, including time counting methods for instructional and non-instructional assignments, with office hours counted hour for hour.

LanguageEnglish

CategoryLetters

FormatPDF

Pages2

Reading Time1 min

AccessFree to download

Memorandum of Understanding

Parties and Effective Date

Purpose and Background

Hours Worked Calculation Rules

PSLF Hours of Service Calculator and Verification

Scope and Limitations

# MEMORANDUM OF UNDERSTANDING COUNTING“HOURS WORKED”WITH REGARDS TO APPLICATIONS TO THEPUBLIC SERVICE LOAN FORGIVENESS(PSLF)PROGRAM This MEMORANDUM OF UNDERSTANDING("MOU")is entered into by andbetween the Santa Monica Community College District("District")and Santa Monica CollegeFaculty Association(“FA”)as of September 12,2017. WHEREAS,the Federal Government has implemented a program named the PublicService Loan Forgiveness(“PSLF”)program¹to help relieve the burden of student debt forqualified applicants;and WHEREAS,qualified applicants must document working thirty or more hours a weekfor appropriate governmental and not-for-profit employers,of which the District is one;and WHEREAS,federal agencies have acknowledged that counting only the hours thatinstructional faculty members spend in the classroom severely undercounts "hours worked"bysuch faculty members²;and WHEREAS,the Internal Revenue Service("IRS")has issued guidelines as to how hoursofservice should be calculated in the context of the Affordable Care Act³;and WHEREAS,the usage of the IRS guidelines will result in no financial cost to the Districtwhile at the same time potentially helping many faculty members be eligible to apply for thePSLF program. NOW,THEREFORE,in consideration of the covenants and agreements hereincontained,the parties agree as follows: 1.Full-time faculty members will continue to be certified to meet the minimum hours(currently 30 hours per week)required to be considered working full-time under thePSLF program. 2.Part-time faculty members with instructional assignments shall calculate “hours worked”using the IRS "Safe Harbor"rules,where each LHE in class counts as 2.25 hours ofservice,and time spent performing office hours shall be counted hour for hour with noadjustment factor. 3.Part-time faculty members with non-instructional assignments(including reassigned timeand hourly task assignments)shall calculate “hours worked”using the IRS reasonablestandard,counting each paid hour as 1.00 hours of service. 4.Full-time faculty members with reduced load assignments shall have their hours of service calculated as if they were part-time faculty members. 5.The FA will create,share and maintain an online "PSLF Hours of Service Calculator"⁴that performs the above calculations when hourly faculty assignments are entered. 6.Part-time faculty members and full-time faculty members on reduced load requestingverification of hours worked from Human Resources for the purpose of the PSLFprogram shall utilize the PSLF Hours of Service Calculator and generate a printout oftheir entries and the resulting calculations.This printout shall be attached to the federalPSLF application form⁵that is submitted to Human Resources for verification. 7.This MOU applies only to the PSLF program and shall not apply to the calculation ofcompensation or benefits under the collective bargaining agreement between the parties. IN WITNESS WHEREOF,the parties have hereunto set their hand by their respectiverepresentatives as of the date first set forth above. THE DISTRICT FANen MMugle 1.Public Service Loan Forgiveness Program:https://studentaid.ed.gov/sa/repay-loans/forgiveness-cancellation/public-service 2.American Association of Community Colleges member memorandum: http://www.aacc.nche.edu/Advocacy/AdvocacyNews/Documents/ACAMMemberMemoFeb20 Final.pdf 3.IRS Guidelines for ACA:https://www.federalregister.gov/documents/2014/02/12/2014-03082/shared-responsibility-for-employers-regarding-health-coverage 4.PSLF Hours of Service Calculator webpage: https://sites.google.com/view/smcfa/miscellaneous/public-service-loan-forgiveness-calculator 5.PSLF Application Form:https://studentaid.ed.gov/sa/sites/default/files/public-service-employment-certification-form.pdf

FAQs

Who are the parties to this Memorandum of Understanding and when does it take effect?

The District and the Santa Monica College Faculty Association are the parties. The MOU is effective as of September 12, 2017.

How do full-time faculty members’ hours meet the PSLF requirement?

Full-time faculty are to continue being certified as meeting the PSLF minimum hours, currently 30 hours per week.

What method does the MOU use to calculate “hours worked” for part-time faculty?

Part-time faculty with instructional assignments use IRS Safe Harbor rules (each LHE in class counts as 2.25 hours; office hours count hour for hour). Part-time faculty with non-instructional assignments use an IRS reasonable standard where each paid hour counts as 1.00 hour of service.

Sep 19, 2026

Upload by Ezra