Kate Mullan
PRA Coordinator, Strategic Collections and Clearance
Governance and Strategy Division, Office of Chief Data Officer
U.S. Department of Education
550 12th Street SW, PCP, Room 9086
Washington D.C. 20202-0023
Ms. Mullan,
On April 15, 2020, the U.S. Department of Education published a notice in the Federal Register (85 FR 20992) soliciting public comment regarding the Application and Employment Certification for Public Service Loan Forgiveness [Docket No.: ED-2020-SCC-0021].
We recommend the following updates to the form:
Section 2 - Heading
Although this section is titled, “Borrower Request, Understandings, Certification, and Authorization”, it does not contain an Authorization piece. Therefore, we recommend removing “Authorization” from the heading to state “Borrower Request, Understandings, and Certification”, unless the U.S. Department of Education incorporates the standard “Authorization” language that is present on other OMB approved forms.
FSA accepts and has incorporated this change into the final version of the form. 7-31-2020
Section 8 - Heading
Please correct the typo in the heading of this section. “TESPLF” should be “TEPSLF”.
Thank you for catching that error, it has been corrected on the final version of the form. 7-31-2020
Section 8 – Payment Eligibility (Continued)
Under the third paragraph in this section, beginning with “Your payments must be made under..”, we believe the 3rd sentence outlining the qualifying repayment plans for TEPSLF is misleading. As written, it insinuates that the Graduated, Extended, Standard Repayment Plan for Direct Consolidation Loans and Graduated Repayment Plan for Direct Consolidation Loans are the only plans that qualify. However, this should also indicate that all of the repayment plans that qualify under PSLF are eligible. For example (and similar language is used elsewhere on the form), “Qualifying repayment plans for TEPSLF include the qualifying repayment plans for PSLF, as well as the Graduated, Extended, Standard Repayment Plan for Direct Consolidation Loans and Graduated Repayment Plan for Direct Consolidation Loans”.
FSA accepts and has incorporated this change into the final version of the form. 7-31-2020
We appreciate the opportunity to comment.
Sincerely,
Kimberly Myers
Senior Compliance Specialist
FedLoan Servicing • 1200 North Seventh Street, Harrisburg, PA 17102
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