PSLF on the Brink of Change: What the New Executive Order Means and How to Speak Up

There’s been a lot of buzz recently about Public Service Loan Forgiveness. A new executive order signed on March 7 by the Trump Administration has raised concerns about possible future changes to the PSLF program.

What did the order say?

The order directs the Department of Education to deny PSLF to individuals working for organizations that have a “substantial illegal purpose.” While this is a new direction, it’s important to understand: no changes have taken effect yet. This executive order does not immediately impact the existing PSLF rules that have been in place since 2007.

So, what is “substantial illegal purpose”? The executive order does not provide a clear definition. It leaves a lot of room for interpretation, which is part of the concern. In general, it seems to suggest that if a nonprofit or other qualifying organization is found to be engaging in illegal activity as a core part of its operations, its employees could be disqualified from PSLF. This raises a big question: Who decides what counts as “substantial” illegal purpose?

Until formal rules are written, there’s no certainty about how this language would be applied — or who might be affected.

Although the executive order has been issued, the Department of Education cannot change the PSLF program overnight. Any changes must go through a formal rulemaking process with opportunities for public comment. That process — called negotiated rulemaking — is already underway.

• In-person hearing session: April 29

• Virtual hearing session: May 1

• Public comments: Read the Proposed Rule and Comment at Regulations.gov

This is an opportunity for borrowers, advocates, and organizations to share their stories and concerns about PSLF — especially in light of this executive order.

The most important thing to know right now: Nothing has changed yet.

• If you are working in public service, keep submitting your employment certification and making payments as usual.

• Stay enrolled in your income-driven repayment plan.

• Track your qualifying payments, and stay on course.

• If you've already reached 120 payments or are close to it, your progress remains intact.

At Student Debt Solutions, we’re closely monitoring these developments. Whether you're just getting started with PSLF or nearing forgiveness, we’re here to help you understand how potential changes may affect your path.