[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-306796-105":53,"doc-detail-306796-en":127},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":120,"head_meta":122,"extra_data":124,"updated_unix":126},105,"en","pslf-proposed-language-omb-remediation-proposal-for-catx-physician-exclusion","PSLF Proposed Language OMB - Remediation Proposal for CA/TX Physician Exclusion","","Proposal remediates the Public Service Loan Forgiveness (PSLF) CA/TX physician exclusion without affecting other health care professionals. It adds a revised “employee or employed” definition to 34 CFR 685.219(b) and the PSLF application, and introduces three form changes: a physician-specific understanding clause, expanded employment eligibility instructions, and verification guidance based on hospital chief medical officer certification. Rationale links PSLF’s “public service job” purpose to credentialing/privileging as a proxy for employment under corporate practice of medicine constraints.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/pslf-proposed-language-omb-remediation-proposal-for-catx-physician-exclusion/306796/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/pslf-proposed-language-omb-remediation-proposal-for-catx-physician-exclusion/306796.png","ImageObject",442,249,{"name":88,"@type":89},"Asher","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-18","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",7,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"What change does the proposal make to the PSLF program’s “employee or employed” concept?","Question",{"text":109,"@type":110},"It expands the definition so “hired and paid by” can include conferring clinical privileges to a licensed health care provider/physician by a private nonprofit public service organization where direct employment is prohibited by state law.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"What is added to the PSLF application’s borrower understandings for physicians under state employment restrictions?",{"text":114,"@type":110},"It adds a statement that physicians who cannot be employed due to state law must be engaged to practice medicine full time at a private not-for-profit public service organization when applying for and receiving forgiveness.",{"name":116,"@type":107,"acceptedAnswer":117},"How does the proposal propose to verify “full-time” eligibility for covered physicians?",{"text":118,"@type":110},"It allows verification through an oath-signed certification submitted by the hospital’s Chief Medical Officer or equivalent, confirming the physician’s active medical staff membership and time worked at the hospital.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},306796,1790472967,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":76,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":9},687197207639,"https://ap-avatar.wpscdn.com/davatar_a8503ba1806abce46bf441b54a3ca4cd","Below is a proposal that remediates the CA/TX physician exclusion from the Public Service Loan Forgiveness (PSLF) program without impacting other health care professionals. The proposal includes a change to the general language definition for the program as well as three changes to the PSLF application and certification form.  \nADDITION TO THE PSLF REGULATIONS 34 CFR SECTION 685.219(b) AND THE APPLICATION FORM:  \n“Employee or employed means an individual who is hired and paid by a public service organization.‘Hired and paid by’ includes conferring of clinical privileges to a licensed health care provider/physician by a private nonprofit public service organization that is prohibited by State law from directly employing such individual.”  \nAMENDMENT TO THE PSLF APPLICATION FORM:  \n1. DEFINITIONS  \nThe new definition listed above should be added to the definitions section.  \n2. BORROWER REQUEST, UNDERSTANDINGS, AND CERTIFICATION  \nInsert the following:  \nI understand that:  \n- To qualify for loan forgiveness, I must be employed full-time by a qualifying employer when apply for and get forgiveness. (existing language)  \n-For physicians who are prohibited from being employed by state law, to qualify for loan forgiveness, I must be engaged to practice medicine (in a health care practitioner occupation) full time at a private notfor-profit public service organization when I apply for and get forgiveness.  \n3. INSTRUCTIONS SECTION OF PSLF APPLICATION FORM Add the following:  \nEMPLOYMENT ELIGIBILITY  \nPhysicians who are engaged to practice medicine at a private not-for-profit public service organization in states that prohibit physicians from being employed by private non-profit hospitals, can be verified to meet the “full-time” requirements for eligibility by submission of a certification signed under oath by the hospital’s Chief Medical Officer or equivalent position confirming the physician’s active membership on the medical staff and time spent working at the hospital.  \nRATIONALE  \nThe Public Service Loan Forgiveness (PSLF) program forgives federal student loans for certain individuals who meet its eligibility requirements, including being “employed in a public service job.” 20 U.S.C. §1087e(m)(1)(B)(i) . Regulations specify that,“Employee or employed means an individual who is hired and paid by a public service organization.” 34 CFR §685.219(b) .  \nEmergency physicians, other hospital-based physicians working full time at private nonprofit hospitals, or primary care physicians working full time at private nonprofit hospital clinics that serve predominantly Medicaid patients work at a “public service organization.” However, under California and Texas state laws known as the Corporate Practice of Medicine law (CPOM), these physicians cannot legally be employed by their hospitals, even though they work full time at the hospitals. Thus, these physicians meet the full spirit of the PSLF program but cannot qualify for loan forgiveness due to a technical legal distinction concerning “employment” of doctors that stems from state laws unique to California and Texas.  \nCPOM laws are more than a century old and originally are premised on recognition that licenses to practice medicine are conferred on individuals and that corporations cannot practice medicine. As the delivery of medicine diversified and became more commercialized/corporatized, CPOM evolved to shift away from concerns about profit motive to more broadly prohibit lay interference in the practice of medicine (e.g., medical decision-making, rationing care by managed care entities) . While exceptions to CPOM have been created, California and Texas law remain consistent in prohibiting employment by private nonprofit hospitals of physicians.  \nAlthough doctors cannot be employed by the hospitals, they must legally be admitted into the professional medical staffs ofthe hospitals and granted professional privileges. Privileging and credentialing is the process whereby the physician ","cbCairldhdkr7ECh","https://ap.wps.com/l/cbCairldhdkr7ECh","pdf",107228,"English","# Proposed regulatory addition and definitions\n## Amendment to PSLF application form: definitions\n## Borrower request, understandings, and certification changes\n## Instructions section: employment eligibility\n## Rationale and supporting discussion","[{\"question\":\"What change does the proposal make to the PSLF program’s “employee or employed” concept?\",\"answer\":\"It expands the definition so “hired and paid by” can include conferring clinical privileges to a licensed health care provider/physician by a private nonprofit public service organization where direct employment is prohibited by state law.\"},{\"question\":\"What is added to the PSLF application’s borrower understandings for physicians under state employment restrictions?\",\"answer\":\"It adds a statement that physicians who cannot be employed due to state law must be engaged to practice medicine full time at a private not-for-profit public service organization when applying for and receiving forgiveness.\"},{\"question\":\"How does the proposal propose to verify “full-time” eligibility for covered physicians?\",\"answer\":\"It allows verification through an oath-signed certification submitted by the hospital’s Chief Medical Officer or equivalent, confirming the physician’s active medical staff membership and time worked at the hospital.\"}]","PSLF Proposed Language OMB - Remediation Proposal for CA/TX Physician Exclusion | PDF",1789841307]