How Many Hours Per Week Counts as Full-Time Employment For PSLF?

Maybe you’ve thought about reducing your hours at work, but you’re afraid of losing the Public Service Loan Forgiveness (PSLF) program.After all, you need to meet the full-time PSLF eligibility requirements based on worked hours per week in order to get qualifying payments.The ultimate goal is to make 10 years of PSLF payments, and then the government wipes away your remaining balance tax-free.But what counts as full-time employment for student loan borrowers trying to qualify for the Public Service Loan Forgiveness program? The current rule is an average of at least 30 hours per week for one or more qualifying employers, regardless of the employer's definition of full-time.

Previously, the answer was more complicated.I had to do a lot of thinking when I got this question from a reader years ago, trying to help his wife receive credit for all of her qualifying PSLF loan payments.Hi Travis, I'm in a kind of head-scratcher of a situation regarding what counts as full-time for PSLF, and I'm wondering if you might know of any resources about it.(The (short) background is: She's been working 30 hours/week for four years, and her hospital employer has signed her PSLF ECF forms for the first three of those four years.

This past year, however, they refused to sign because 30 hours is only 0.75 full-time equivalent (FTE), and therefore, according to one possible reading of the situation, not full-time at 1.0 FTE.(The other reading of the situation, which we'd been going by, is that “full-time for benefits purposes,” which begins at 30 hours, is full-time for PSLF.)) I'm just wondering if you know of anyone who's successfully pleaded with their employer to consider .75 or .8 FTE as full-time for the purposes of PSLF.I'm guessing my wife's employer decided that doing so was putting them at some kind of legal risk.Their situation illustrates why the full-time employment rule needed to change.

Today, someone in the wife's position meets the PSLF hours requirement if she averages at least 30 hours per week at a qualifying employer.Her hospital's 0.75 FTE designation doesn't change that.But it wasn't always that straightforward.Definition of full-time for PSLF: How many hours per week to qualify? I love hard questions like this because it forces me to go back to the definitions and regulations of the program.

In the past, borrowers working for a single qualifying employer generally had to work the greater of 30 hours per week or their employer’s definition of full-time.That created confusion for people whose employers offered full-time benefits at fewer hours than a standard full-time workload.However, regulatory changes that took effect July 1, 2023, simplified the definition.Now, full-time for PSLF means working an average of 30 hours per week or more, regardless of the employer’s definition of “full-time.” This total can be for one or more jobs if you work for multiple qualifying employers.

For more background, see our post on big PSLF changes.If your employer somehow tried to count you as full-time if you’re working less than 30 hours per week, that clearly doesn’t qualify.Thirty hours per week is the lower bound.The number of hours you must work is at least 30 hours per week or more.

But now if your job doesn't consider your PSLF employment full-time at 30 hours, under current rules, you'll still be considered full-time and qualify for the program.What is FTE and why did it make certifying PSLF confusing? University hospitals, government organizations, and other large bureaucratic institutions often use Full-Time Equivalent (FTE) as an accounting statistic.If you’re at 1.0 FTE, you are at a worker’s full workload, generally 40 hours per week for exempt positions.If you’re at 0.75 FTE, it means you would be at 30 hours per week under that schedule.

However, many workers who put in less than 1.0 FTE receive full-time benefits, such as health insurance and retirement contributions.Previously, these differences complicated PSLF employment certification.Now, your average weekly hours determine whether you meet PSLF's full-time requirement — not your FTE designation or benefits eligibility.FTE differences between exempt and non-exempt jobs You might not have known this since I didn’t before researching this article, but there are often different definitions of FTE for exempt and non-exempt positions.

An exempt position under the Fair Labor Standards Act earns a salary of at least $35,568.This means the employer does not have to pay you overtime when you work more than 40 hours per week.Employers I found online generally view 40 hours per week as 1.0 FTE.Think “white collar” workers or professionals.

A non-exempt position has an hourly wage.Workers in these roles must be given overtime if they work more than 40 hours per week. For most non-exempt roles I looked at, 1.0 FTE was 37.5 hours per week instead of 40.Hence, 0.75 FTE for an exempt job would be 30 hours per week and 0.75 for a non-exempt job would be 28 hours per week.Under the current rules, if you average at least 30 hours per week at a qualifying employer, you meet PSLF's full-time requirement even if your employer consider you part-time.

If your employer was willing to sign the forms because they consider 0.75 full-time, then you would qualify for PSLF since you’re working at least 30 hours per week.However, if you were in an hourly job, say front desk security for a hospital at 0.75 FTE based on a 37.5-hour workweek, you would not be working at least 30 hours a week since you’d be at 28.Even if your employer was willing to sign off on you being full-time, you wouldn’t qualify for PSLF based on that schedule alone.The employer's full-time designation can't replace the required weekly average.

You could, however, combine those hours with another qualifying job to reach the 30-hour threshold.Is 0.75 FTE considered full-time? The answer is that it depends on whether you're asking about workplace benefits or PSLF eligibility.Many hospital systems will give you full-time benefits at 0.75 FTE.For example, the University of Kentucky hospital system made a change in 2005 so that employees working 0.75 FTE could be considered full-time for benefits purposes.

The administration decided it was worth it to extend benefits to folks working a shorter schedule so they could retain talent.However, if their full-time workload is 1.0 FTE, which definition wins? Before the new rules, that question complicated PSLF certification for many borrowers and employers.Today, PSLF uses its own definition: an average of at least 30 hours per week.If your 0.75 FTE schedule meets that threshold, you meet the full-time employment requirement regardless of your employer's benefits policy.

Are there legal risks for employers who sign PSLF forms? Put yourself in the shoes of the HR Director in the example at the beginning of this article who refused to sign off on the PSLF form.She probably had legal concerns that the hospital would be on the hook for civil or maybe even criminal penalties if she said that an employee was full-time at 0.75 FTE.It’s one thing when your hospital considers you full-time for benefits, but what about when the government or the U.S.Department of Education asks if the employee is full-time? Most people I’ve met at large public service employers in decision-making roles or those at big nonprofit organizations are very risk-averse.

They don’t want to do anything that could come back on them.Fortunately, the updated rules resolve that distinction.An employer should use PSLF's definition of full-time when completing the form, even if it uses a different definition for staffing or benefits.Risk aversion can complicate PSLF sign-offs in HR departments One reason for that is negative events get punished far more than positive events get rewarded.

Most HR departments have no clue about PSLF student loan forgiveness.They don’t know what they’re signing.But they do know if they commit the hospital to something they shouldn’t have, they could get in trouble.But employers now have clear instructions.

Federal Student Aid’s employer guidance tells employers to certify employees as full-time for PSLF if they average at least 30 hours per week, regardless of whether the employer considers them full-time for other purposes.Employers still need to verify employment dates and hours before signing.The PSLF form warns that knowingly making false statements can result in penalties.But certifying an employee who averages at least 30 hours per week as full-time for PSLF simply follows the program’s rules.

It doesn’t change the employee’s FTE designation or benefits.Worst case scenario, if an employer signs off on someone being full-time incorrectly, then the employee would just not get PSLF.Nobody would get massive fines or go to jail over an honest misunderstanding of the rules, considering PSLF has been historically riddled with issues and unclear guidance.Major risks for employers who don't sign off on PSLF Most hospitals and other PSLF-eligible employers do not have a clue about how valuable this benefit is.

You’d be able to pay significantly less for many positions and fill them simply because of your institution being PSLF-eligible.Employers that take an unnecessarily rigid view on signing off on PSLF certification forms will absolutely lose employees to institutions that do.With clear federal instructions now available, an employee averaging at least 30 hours per week shouldn’t have to argue that their benefits or FTE designation make them full-time.How employers have treated less than 1.0 FTE for PSLF Risk-averse HR departments want to see that they’ll be in good company when they sign off on something they don’t know about.

In a previous version of this article, I highlighted some examples for HR departments navigating PSLF certification for employees working less than 1.0 FTE.These examples help explain how employers approached the issue before PSLF adopted its current 30-hour across-the-board standard.Children’s Hospital of Omaha – Employed >= 0.75 FTE Virginia Garcia Memorial Health Center – Detailed description of benefits you get starting at 0.4 FTE.PSLF sign-offs start at 0.75 FTE.

Allina Health – Letter from Minnesota Nurse’s Association to Allina Health established 0.8 FTE or 30 hours per week as qualifying for PSLF.Today, employers can follow the Department of Education's explicit instructions rather than looking to another organization’s FTE policy -– or risk losing employees to other organizations if you continue to hold back from signing off on PSLF forms out of fear.Strategies for PSLF with unhelpful employers Previously, borrowers whose single employer didn’t consider them full-time could potentially meet PSLF’s employment requirement by working two or more qualifying part-time jobs with a combined average of at least 30 hours per week.That means the reader’s wife, who was working 30 hours per week, could’ve picked up one hour a week at a second qualifying employer to meet the combined-employment rule.

The additional job had to be qualifying employment—it couldn’t be just anything.Today, she wouldn’t need that workaround.Her existing 30-hour schedule at a qualifying employer would meet PSLF’s full-time employment requirement.Combining hours is still an option if you average fewer than 30 hours at one qualifying employer.

For example, someone averaging 28 hours at one qualifying job and two hours at another could meet the requirement.Each employer would certify its own employment dates and hours.Likewise, if you don’t get full-time benefits but average 35 hours a week, you still meet PSLF’s full-time employment requirement.Your employer’s benefits policy doesn’t determine that eligibility.

That said, if you run into issues, you can point to clear PSLF employer guidance on the Student Aid website.Beyond that, I’ve found that if you ask for meetings with decision-makers, bring in one or more colleagues with the same issue, and explain the risk to your employer that they can lose dozens of employees when they don’t have to, they might change their mind.Getting help figuring out if PSLF is worth the headache If you’re working 30 hours a week, maybe you’d prefer to work even less but your high monthly payment amount is stopping you.We have a lot of strategies around helping someone work part-time without worrying about their federal student loan debt.

We also like comparing loan forgiveness options to refinancing to see if you’re making the right decision sticking with an employer for presumably lower pay.We can help you review your options, whether that's an income-driven repayment plan like income-based repayment, deferment, forbearance, and more.While you can get some support from your loan servicer, you can reach out if you think you want professional help.We go over FAQs and help you with a customized plan for your situation.

Let us know in the comments if you’ve ever had to deal with employers giving you a hard time about the PSLF form.Feel free to use an anonymous or made up name too if you need to.