U.S. Department of Education

Student Loan Debt Relief

Negotiated Rulemaking

Session 4 Meeting Summary

February 22 & 23, 2024

Welcome

Introductions & Opening Remarks

The Federal Negotiator, Tamy Abernathy introduced Under Secretary James Kvaal for Opening 

Remarks

Department of Education Under Secretary of Education James Kvaal thanked the convening of 

this 4th and final session of the negotiation committee members related to financial hardship 

waivers. He shared context for needed relief. He acknowledged the prior work of the committee 

at the first 3 sessions held in October, November, and December 2023. He expressed it has been 

a very successful effort.

FMCS Facilitator welcomed the parties to Session 4 and conducted the roll call of non-federal 

negotiators, General Counsel for the Department of Education, and the Department’s Federal 

Negotiator. 

Old Business

The Federal Negotiator shared that the proposed regulatory text had been sent out to negotiators 

before Session 4 regarding financial hardship waivers.

Membership

The following individuals are the members of the Student Loan Debt Relief Negotiated 

Rulemaking Committee. Some primary or alternate negotiators were unable to attend the 

Session days. In the case where the primary was unable to attend, the alternate filled the role of 

primary. Those in attendance are indicated on the chart below with an *. 
Community of Interest Primary Negotiator Alternate Negotiator

Civil Rights Organizations *Wisdom Cole, NAACP India Heckstall, Center for Law 

and Social Policy 

Legal Assistance Organizations 

that Represent Students or 

Borrowers

Kyra Taylor, National Consumer 

Law Center

*Scott Waterman, Student Loan 

Committee of the National 

Association of Chapter 13 Trustees

State Officials, including State 

higher education executive 

officers, State authorizing 

agencies, and State regulators of 

institutions of higher education.

*Lane Thompson, Oregon DCBS 

-Division of Financial

Regulation 

Amber Gallup, New Mexico 

Higher Education Department 

States Attorneys General

*Yael Shavit, Office of the 

Massachusetts Attorney General Vacant

Public Institutions of Higher 

Education, Including Two-Year 

and Four-Year Institutions

*Melissa Kunes, The 

Pennsylvania State University

J.D. LaRock, North Shore 

Community College

Private Nonprofit Institutions of 

Higher Education

*Angelika Williams, University 

of San Francisco

*Susan Teerink, Marquette 

University

Proprietary Institutions

*Kathleen Dwyer, Galen College 

of Nursing

*Belen Gonzalez, Mech-Tech 

College 

Historically Black Colleges and 

Universities, Tribal Colleges and 

Universities and MinorityServing Institutions (institutions 

of higher education eligible to 

receive Federal Assistance under 

title III, parts A and F, and title 

V of the HEA)

Sandra Bohan, Salish Kootenai 

College 

*Carol Peterson, Langston 

University

Federal Family Education Loan

(FFEL) Lenders, Servicers or 

Guaranty Agencies

*Scott Buchanan, Student Loan 

Servicing Alliance

Benjamin Lee, Ascendium 

Education Solutions, Inc.
Student Loan Borrowers Who 

Attended Programs of TwoYears or Less

*Ashley Pizzuti, San Joaquin 

Delta College

David Ramirez, Pasadena City 

College 

Student Loan Borrowers Who 

Attended Four-Year Programs

Sherrie Gammage, The University 

of New Orleans

*Sarah Christa Butts, University of 

Maryland

Student Loan Borrowers Who 

Attended Graduate Programs

*Richard Hasse, State University 

of New York at Stony Brook

*Dr. Jalil Bishop, University of 

California, Los Angeles

Currently Enrolled 

Postsecondary Education 

Students

Jada Sanford, Stephen F. Austin 

University

*Jordan Nellums, University of 

Texas

U.S. Military Service Members, 

Veterans, or Groups 

Representing them

*Vincent Andrews, Veteran Vacant

Consumer Advocates

*Jessica Ranucci, New York 

Legal Assistance Group

*Ed Boltz, Law Offices of John T. 

Orcutt, P.C. 

Individuals with Disabilities or 

Groups Representing them

*John Whitelaw, Community 

Legal Aid Society, Inc. (CLASI)

Waukecha Wilkerson, Sacramento 

State University

Federal Negotiator 

*Tamy Abernathy, Director of 

Policy Coordination Group for the 

Office of Post Secondary 

Education

Agenda

February 22, 2024 – Hardship proposed regulatory text. 

 Public Comment 

February 23, 2024 – Hardship amended proposed regulatory text

 Consensus 

Discussion

The Department provided proposed regulatory text of 34 CFR Part 30-Debt Collection 

(Section 30.91) Subpart G – Waiver of Federal Student Loan Debts for the negotiators to 

consider prior to the session and shared amended regulatory text before any consensus decisions 

were made. 

Throughout the two-day session, the Department of Education provided background and context 

for the proposed regulatory text, received feedback from the negotiators, addressed concerns, and 
then had the negotiators decide via consensus on the proposed amended regulatory text. 

Consensus among the negotiators was reached on 34 CFR Part 30-Debt Collection (Section 

30.91) Subpart G – Waiver of Federal Student Loan Debts.

Public Comment

The Committee provided a ninety (90), instead of sixty (60) minutes, opportunity for public 

comment period during Session 4 day 1 to allow for additional comments as the committee had 

additional time prior to the scheduled comment period. The committee felt it was important to 

garner as many public comments as possible on the topic of hardship. There was no public 

comment on the second day of the session.

Closing

The Department of Education will provide final proposed regulatory text on consensus and nonconsensus language for this Negotiated Rulemaking. This Session concluded the negotiations part 

of the negotiated rulemaking on Student Loan Debt Relief.