July 14, 2022
Hobbies: Medical workforce

Recently, the US Department of Education released draft regulations to reform the National Public Service Loan Forgiveness Program (PSLF). The California Medical Association (CMA), California Hospital Association (CHA), Texas Medical Association (TMA), and Texas Hospital Association (THA), which represent nearly 100,000 physicians and hundreds of hospitals, applaud the actions taken to improve this important national program. Our organizations also appreciate the Department’s stated interest in correcting its existing PSLF regulations, which have inadvertently excluded many California and Texan physicians from participation. However, the draft regulatory wording still fails to address the issue. There continues to be a fundamental misunderstanding of doctor-hospital relationships in our states.

“We implore the U.S. Department of Education to resolve the issue once and for all to ensure that physicians in all 50 states can equally participate in this important program to encourage low-income minority students to pursue a career in medicine and help our neediest, most vulnerable patients in underserved communities,” says CMA President Robert E. Wailes, MD

The PSLF program was intended to provide loan forgiveness to individuals who engage in community service for 10 years by working full-time in nonprofit organizations, such as nonprofit hospitals, and improving the access to health care. Unfortunately, the regulations implementing the program have been narrowed to require physicians to be “directly employed”. Physicians from the two largest states in our country have therefore been inadvertently excluded because, although they may be members of their hospital medical staff working full-time in private, not-for-profit hospitals and able to respond to all PSLF eligibility requirements, state laws in California and Texas prohibit these hospitals from employing physicians. But for this legal ban, those California and Texan doctors could be eligible for loan forgiveness, just as doctors in the other 48 states who similarly work in private, nonprofit hospitals are eligible to participate.

Earlier this year, a bipartisan group of congressional officials sent U.S. Secretary of Education Miguel Cardona a joint letter pointing out that Congress never considered excluding doctors from two of the nation’s largest states. when creating the program.

The wording of the proposed regulations attempts to address the issue of the “direct employment” requirement in California and Texas by instead requiring physicians to “contract with” private, nonprofit hospitals” to provide payroll or similar services” in order to qualify for loan forgiveness. Although well-intentioned, the proposed settlement does nothing to address the problem and still excludes doctors in California and Texas because they do not contract with hospitals to provide payroll services. Additionally, at least 75% of doctors in these states do not practice in nonprofit hospitals with a contract and would still be ineligible whether the contract is for payroll services or not.

“Our organizations have submitted an equitable solution that provides California and Texas equivalent accreditation for direct employment in hospitals, which we believe meets the intent of the original law and the Department’s standards and policy objectives. “, says TMA President Gary Floyd, MD. “Employment equivalent is the granting of clinical privileges to hospital medical personnel to a physician licensed by a private, nonprofit hospital who is prohibited by state law from directly employing such a physician This is a rigorous process similar to employment that includes verifiable information about hours worked at the hospital providing medical care.

“With an average medical student loan debt of over $200,000, most students cannot afford to become doctors without loan forgiveness,” says CHA President and CEO Carmela Coyle. “California and Texas are expected to experience the two largest doctor shortages over the next decade, and access to care for patients in nonprofit community hospitals, children’s hospitals, and rural hospitals will become even more difficult. more difficult if these regulations are not corrected.”

“We urge the ministry to reconsider our proposed solution. If the regulations aren’t fixed, California and Texas doctors working full-time at private, nonprofit hospitals won’t be able to participate. Physicians will choose to practice in other states where they can receive loan forgiveness, accelerating the worsening physician shortage and hurting our ability to fully care for the patients who need us most. said THA President and CEO John Hawkins.

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