July 14, 2022
Area(s) of Interest: Physician Workforce
Recently, the US Department of Education launched draft rules to reform the nationwide Public Service Loan Forgiveness (PSLF) program. The California Medical Association (CMA), California Hospital Association (CHA), Texas Medical Association (TMA) and Texas Hospital Association (THA)—representing practically 100,000 physicians and a whole bunch of hospitals—applaud the actions taken to enhance this necessary nationwide program. Our organizations additionally recognize the Department’s acknowledged curiosity in fixing its present PSLF regulation, which inadvertently excluded many California and Texas physicians from collaborating. However, the draft regulatory language inexplicably still fails to repair the issue.
“We implore the Department of Education to resolve the problem 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 careers in medicine and to help our neediest, most vulnerable patients in underserved communities,” mentioned CMA President Robert E. Wailes, M.D.
The PSLF program was supposed to offer mortgage forgiveness to people who decide to group service for 10 years by working full time in non-profit organizations, comparable to non-profit hospitals, and enhancing entry to well being care. Unfortunately, this system’s implementing rules had been narrowed to require physicians to be “directly employed.” Physicians in our nation’s two largest states consequently had been inadvertently excluded as a result of, whereas they could be members of their hospital medical staffs working full time in personal nonprofit hospitals and capable of meet all PSLF eligibility necessities, state legal guidelines in California and Texas prohibit these hospitals from using physicians. But for this authorized prohibition, these California and Texas physicians may very well be eligible for mortgage forgiveness simply as physicians from all different 48 states who equally work in personal non-profit hospitals are eligible to take part.
Earlier this yr a bipartisan group of Congressional representatives despatched U.S. Education Secretary Miguel Cardona a joint letter emphasizing that Congress by no means contemplated excluding physicians in two of the nation’s largest states after they created this system.
The language in the draft rules makes an attempt to resolve the issue of requiring “direct employment” in California and Texas by as an alternative requiring that physicians “contract with” personal non-profit hospitals “to provide payroll or similar services” to obtain mortgage forgiveness. While well-intended, the proposed regulation doesn’t resolve the issue and still excludes California and Texas physicians as a result of they don’t contract with hospitals to offer payroll providers. Moreover, many physicians in these states don’t observe in nonprofit hospitals with a contract and would still be ineligible no matter whether or not the contract should be for payroll providers.
“Our organizations have submitted a fair solution that provides a California and Texas credentialing alternative to direct hospital employment, which we believe meets the intent of the original statute and the Department’s standards and policy goals,” mentioned TMA President Gary Floyd, M.D. “The credentialing alternative would enable participation by licensed physicians who have been conferred hospital medical staff clinical privileges by a private non-profit hospital that is prohibited by state law from directly employing such physicians. Credentialing is a rigorous process that includes verifiable information about the hours worked in the hospital providing medical care. We urge the Department to ensure Texas and California physicians, who are dedicated to serving marginalized patients and the public good, have access to this national loan forgiveness program.”
A possible compromise resolution, which may very well be extra inclusive and mirrors doctor eligibility in the opposite 48 states, is perhaps to undertake 1) the California-Texas proposed language that enables medical employees privileges as a surrogate for employment in states the place employment is prohibited and 2) the Department’s proposal to permit contracts between physicians and non-profit hospitals for medical providers (not payroll providers). Such an answer may enable extra main care physicians, who’re in quick provide, to be eligible simply as they’re in different states.
“With the average medical education loan debt at more than $200,000, far too many students simply cannot afford to become doctors without loan forgiveness,” mentioned CHA President and CEO Carmela Coyle. “The situation is worst in our largest states, as California and Texas are projected to have the two biggest physician shortages over the next decade. Access to care for people served by non-profit community hospitals, children’s hospitals, and rural hospitals will be in even greater jeopardy if regulations are not changed to address this fundamental problem that creates shortfalls of clinicians in our most vulnerable communities.”
“We urge the Department to reconsider our proposed solution. If the regulations are not corrected, California and Texas physicians working full-time in private non-profit hospitals will be blocked from participating. Physicians will choose to practice in other states where they can receive loan forgiveness, accelerating our worsening physician shortages and harming our ability to fully care for the patients who need us most,” mentioned THA President and CEO John Hawkins.