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Domino: A Blog About Student Debt Broken Promises: Investigating the Department of Education’s Employer Certification Process

Broken Promises: Investigating the Department of Education’s Employer Certification Process

By Tariq Habash | July 31, 2020

In conjunction with the release of the report, “Broken Promises: Employment Certification Failures,” the SBPC has released two new sets of documents and records that have never before been available to the public: (1) internal government communications and records about the process for certifying public service employment, and (2) the first-ever public, purportedly “comprehensive,” list of approved and denied employers produced by PHEAA and released to AFT and SBPC by ED’s Office of Federal Student Aid (FSA). 

Internal Government Communications and Records About the Process for Certifying Public Service Employment

In response to requests filed under the Freedom of Information Act, FSA produced more than 9,200 pages of documents and records. Due to the large size of this production, we have divided these documents and records into segments, which are keyword searchable and available for download below. 

In addition to the thousands of pages of email correspondence produced in February 2019, FSA also produced a list of organizations that had previously been certified as eligible for PSLF through the end of 2016. This list was described by FSA at the time as “a list of approved employers categorized by type of ‘qualifying employment.” We are providing this list in its entirety as it demonstrates the critical flaws identified in our report, including:

(1) Mischaracterized employers (e.g., government agencies designated as nonprofit organizations as well as nonprofit organizations characterized as government agencies);

(2) Employers documented on the list as qualifying employers for PSLF, but show up in other ED communications as ineligible; and

(3) Employers that are deemed qualifying employers, but in subsequent communications by the Department (see “comprehensive list” below) are inexplicably missing.

“Comprehensive” List of Public Service Employer Approvals and Denials

In our efforts to get answers for borrowers about the recordkeeping of approved and denied employers, we continued asking questions, including whether there existed an accurate and comprehensive list of employers. This ultimately led FSA to produce a new series of records purported to be a “comprehensive” database of all employer certification approvals and denials through June 2019. Until it was produced in 2019, the government had no complete record of these decisions.

AFT and SBPC have elected to release this “Comprehensive” List of Public Service Employer Approvals and Denials in six parts, as it was originally produced by FSA. Users should note that this list codes employer certification decisions into five possible categories—(A) Approved, (D) Denied, (AR) Approved Religious, (I) Inconclusive, and (R) Review. We have also converted these files into a single .dta file for use by researchers, available for direct download at the link below.

  1. PSLF Organization Database- Part A (.xlsx/19 mb)
  2. PSLF Organization Database- Part B (.xlsx/17 mb)
  3. PSLF Organization Database- Part C (.xlsx/16 mb)
  4. PSLF Organization Database- Part D (.xlsx/22 mb)
  5. PSLF Organization Database- Part E (.xlsx/17 mb)
  6. PSLF Organization Database- Part F (.xlsx/17 mb)
  7. Complete “Comprehensive” PSLF Organization Database (.dta/633 mb)

In the coming months, we will continue to analyze the data released in this production and remain committed to releasing new documents and records as they become available. Borrowers, researchers, advocates, and policymakers interested in partnering with us as we continue to pursue evidence of mismanagement and abuse in the PSLF program can email us at investigations@protectborrowers.org.

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Tariq Habash is Head of Investigations at the Student Borrower Protection Center.

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