Executive Order 14235’s vague definitions could unjustly disqualify employees of nonprofits, public health, education, and advocacy organizations from participating in the Public Service Loan Forgiveness (PSLF) program. Public health workers involved in immigrant support, protests, diversity, equity, and inclusion initiatives, or gender-affirming care may be at particular risk of exclusion. By narrowing eligibility, the Executive Order threatens to deter health professionals from working in essential safety-net institutions. It directly undermines economic security and hampers recruitment for public sector roles, especially lower-paid positions such as teaching, nursing, and advocacy. Additionally, by limiting debt relief to those employed by “approved” entities, it creates inequities in financial support within the public service sector. It’s important to note, however, that to enforce these new definitions, the Department of Education must promulgate updated regulations, a process that has not yet been completed
A directive issued by the President that manages operations of the federal government. Executive orders have the force of law but must align with existing statutes and constitutional authority.
Who It Impacts: Federal agencies and employees, directing them on how to implement laws or carry out government functions. Executive orders can also influence businesses and individuals when they relate to issues like immigration, trade, or labor policies.
Who Is Not Impacted: Private citizens and businesses do not have to directly follow an executive order unless it leads to regulations or policies that apply to them. For example, an executive order directing federal agencies to increase renewable energy use does not mandate action from private companies, but it may influence policy shifts that eventually affect them.
Summary
The Public Service Loan Forgiveness (PSLF) Program was created by Congress to encourage Americans to enter the public service sector by offering student loan forgiveness after qualifying service. This EO directs the Secretary of Education to propose updates to the federal regulations governing PSLF to restrict organizations - and therefore the employees - that are eligible for loan forgiveness. While at face value expanding the ineligibility of PSLF to criteria such as terrorism and child abuse appears rational, the broad EO purposes uses broad terminology and phrasing which could allow for unjust and discriminatory application of the EO such as denying eligibility to employees at organizations serving LGBTQI+ youth or mixed immigrant status households.
Impact Analysis
Legal Challenges
Take Institutional Action
• Designate a PSFL liaison within your organization to guide and assist employees through the PSFL application process and any future changes to the program.
• Issue a formal statement opposing the EO’s exclusionary criteria if they conflict with your organization’s mission (ex. LGBTQI+ care, immigrant health, reproductive justice).
• Research the feasibility of establishing an internal institutional loan repayment assistance programs for employees.
• Maintain strong internship, fellowship, and residency programs that continue to prioritize health equity work.
• Collect anonymized data and testimonials to illustrate unintended consequences and submit formal public comment when the draft regulations are published in the Federal Register to public comment (https://www.ecfr.gov/)
Associated or Derivative Policies
Policy Prior to 2025
Additional Resources
Public Service Loan Forgiveness Program website: https://studentaid.gov/manage-loans/forgiveness-cancellation/public-service
State Loan Forgiveness Programs: https://www.forbes.com/advisor/student-loans/student-loan-forgiveness-by-state/
