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PSLF Under Fire
- Thread starter belkatronic
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A big issue is the definition of a qualifying organization. The first two criteria, government organization or 501(c)(3), are pretty clear but the third "other" category is very ambiguous. The person in the article worked for Vietnam Veterans of America which is a 501(c)(19) so it falls into the questionable third category. The end of the article states that he switched jobs and now works for Paralyzed Veterans of America which is a 501(c)(3) and he met criteria with that position.
I think that if you're seriously aiming for PSLF, you have to seek out a government organization or 501(c)(3). Taking a job at an organization that may potentially fall into the "other" category would be a big risk.
I think that if you're seriously aiming for PSLF, you have to seek out a government organization or 501(c)(3). Taking a job at an organization that may potentially fall into the "other" category would be a big risk.
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This suggests that residency time will not count at all.
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Isn't residency 503c? Nevertheless. Troubling.
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Many residency programs are associated with non-profit medical centers. However, as aPD alluded to, there doesn't seem to be anything stopping the government from simply deciding that postgraduate medical education doesn't count.
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Lets be honest, this program needs to go away. According to PSLF an ER doc making 300K/year with 2/3 days off each month could be considered (before this new thing from the department of education) a 'public servant' because his hospital files as a nonprofit, while a Pediatrician in a small clinic in a rural town taking Q3 call and seeing 6 days/week of clinic isn't because his practice pays taxes. Its insane. More that that it is pushing more physicians towards being employees rather than practice owners, which is the last thing that we need.
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I still don't see where people are getting this.
The issue the DOE has is retroactively looking at people employed not by 503(c)1 or the government, but things like the ABA, a 506(c)6. That is, as long as you work for either a non-profit or the government, which the vast majority of residencies are, there's no ambiguity here.
They could do a completely separate change looking at residencies, but that is not even implied in the current "controversy".
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Are residents actually employees of the hospital? Or is the training program a different legal entity affiliated with the hospital? Also are residents really employees at all? I thought they were some kind of special non employee trainee, and that's why they don't qualify for overtime pay or other employee protections.
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Residents are employees. Otherwise we'd be exempt from social security taxes across the board (which we aren't). Federal government is very clear about this. The department of the treasury states "that in all cases 'the services of a full-time employee are not incident to and for the purpose of pursuing a course of study' and specifies that residents working more than 40 hours per week are categorically ineligible for the student exemption." and this was upheld by SCOTUS in 2011. There was a little ambiguity prior to that regulation in 2005 with the student/employee question but that shouldn't apply to anyone currently in residency or participating in PSLF (which came about in 2007).
We're exempt from overtime pay because we're salaried and we meet one of the 1,000,001 exemptions from overtime. Very few salaried individuals get overtime (they have to have no supervisatory responsibilities, not have a job that requires "advanced knowledge", not work in a very long list of industries including such random stuff as movie theatres, etc etc). Residents would never qualify for overtime based on a half dozen of the exemptions at least. Overtime pay realistically is only required for people who work for hourly wages. The Obama administration did try to clamp down on some of the exemptions, but not any of the ones that would apply to us (the "advanced knowledge" exemption is the easy one). Attendings don't get overtime pay either, no matter their employment status.
For both my residency and my fellowship, I am/was directly employed by the University of X (X being different in the two cases). I get the same benefits as any other employee of the university, qualify for the university pension plan, and have my paychecks cut by the university. Both of them would qualify just fine and dandy for IBR with no ambiguity whatsoever. For residencies that aren't part of a university, the vast majority are directly under an umbrella that is still a 503(c)1. There's exemptions of course, but they aren't that common.
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Yes, sorry. Looks like I may have jumped to conclusions that were not warranted. My institution is 503(c)(3). Affiliated with a Uni, but a stand alone hospital system.
During my TRI year at a county hospital, I was a county employee (pay checks were from the County, there was some sort of special retirement program, etc). My IM residency is through a large Florida for-profit chain and I'm employee of them. My health insurance options are the same, I qualify for employee stock purchase program (ESPP) the same as the other employees, and my 401k is the same as the other employees (albeit since we start in July and end in June, I'll have an extra year of vestment). Unfortunately, since I'm an employee of the hospital and not the consortium, I'm currently not getting time towards PSLF.
That being said, I don't think most people are going to qualify for PSLF because, even for the attendings who work at a non-profit or government hospital, they are still employed by a private group contracted for that hospital... thus not earning qualified months.
