PUBLIC SERVICE 

LOAN 

FORGIVENESS 

Education Needs 

to Provide Better 

Information for the 

Loan Servicer and 

Borrowers 

Report to Congressional Requesters

September 2018

GAO-18-547

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-547, a report to 

congressional requesters

September 2018

PUBLIC SERVICE LOAN FORGIVENESS

Education Needs to Provide Better Information for the 

Loan Servicer and Borrowers

What GAO Found

As of April 2018, over a million borrowers had taken steps to pursue Public Loan 

Service Forgiveness (PSLF) from the Department of Education (Education), but 

few borrowers have been granted loan forgiveness to date. The PSLF program, 

established by statute in 2007, forgives borrowers’ federal student loans after 

they make at least 10 years of qualifying payments while working for certain 

public service employers and meeting other requirements. Over 890,000 

borrowers have passed a first step towards potentially qualifying for PSLF by 

voluntarily having their employment and loans certified as eligible for PSLF as of 

April 2018, according to data from Education’s PSLF loan servicer. While 

borrowers first became eligible to apply for loan forgiveness in September 2017, 

few applicants had met all requirements as of April 2018, with 55 borrowers 

having received loan forgiveness (see figure). Education has used various 

outreach methods to inform borrowers about PSLF, but the large number of 

denied borrowers suggests that many are still confused by the program 

requirements. A recently enacted law requires Education to conduct additional 

outreach to help borrowers understand how to meet program requirements.

PSLF Certification Requests and Forgiveness Applications, as of April 2018 

Education does not provide key information to the PSLF servicer and borrowers.

• Guidance and instructions: Education provides piecemeal guidance and 

instructions to the PSLF servicer it contracts with to process certification 

requests and loan forgiveness applications. This information is fragmented 

across the servicing contract, contract updates, and hundreds of emails. As a 

result, PSLF servicer officials said their staff are sometimes unaware of 

important policy clarifications. Education officials said they plan to create a 

comprehensive PSLF servicing manual but have no timeline for doing so.

• Qualifying employers: Education has not provided the PSLF servicer and 

borrowers with a definitive source of information for determining which 

employers qualify a borrower for loan forgiveness, making it difficult for the 

servicer to determine whether certain employers qualify and for borrowers to 

make informed employment decisions.

• Qualifying loan payments: Education does not ensure the PSLF servicer 

receives consistent information on borrowers’ prior loan payments from the 

eight other federal loan servicers, which could increase the risk of miscounting 

qualifying payments. Borrowers also lack sufficiently detailed information to 

easily identify potential payment counting errors that could affect their 

eligibility for loan forgiveness.

These weaknesses are contrary to federal internal control standards for using 

and communicating quality information, creating uncertainty for borrowers and 

raising the risk some may be improperly granted or denied loan forgiveness.

View GAO-18-547. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov. 

Why GAO Did This Study

Starting in September 2017, the first 

borrowers became eligible and began 

applying to have their loans forgiven

through the PSLF program. GAO was 

asked to review the PSLF program.

This report examines the (1) number of 

borrowers pursuing PSLF and the 

extent to which Education has 

conducted outreach to increase 

borrower awareness of program

eligibility requirements, and (2) extent 

to which Education has provided key 

information to the PSLF servicer and 

borrowers. GAO analyzed data from 

the PSLF servicer on employment and 

loan certifications and loan forgiveness 

applications as of April 2018; reviewed 

Education’s guidance and instructions

for the PSLF servicer; assessed the 

information used by Education and the 

PSLF servicer and communicated to

borrowers against federal internal 

control standards; and interviewed 

officials from Education and the four 

largest loan servicers, including the 

PSLF servicer.

What GAO Recommends

GAO recommends that Education (1) 

develop a timeline for issuing a 

comprehensive guidance and 

instructions document for the PSLF 

servicer, (2) provide the PSLF servicer 

and borrowers with additional

information about qualifying employers, 

(3) standardize payment information 

other loan servicers provide to the 

PSLF servicer, and (4) ensure 

borrowers receive sufficiently detailed 

information to help identify potential 

payment counting errors. Education 

agreed with GAO’s recommendations.
Page i GAO-18-547 Public Service Loan Forgiveness

Letter 1

Background 3

Many Borrowers Are Pursuing Public Service Loan Forgiveness, 

and Recent Legislation Requires Education to Conduct 

Additional Outreach to Borrowers 9

Education Could Provide More Comprehensive Information to 

Improve Program Administration and Qualifying Employment 

and Loan Payment Determinations 16

Conclusions 24

Recommendations for Executive Action 25

Agency Comments and Our Evaluation 26

Appendix I Comments from the U.S. Department of Education 27

Appendix II GAO Contact and Staff Acknowledgments 29

Figures

Figure 1: Education’s Voluntary Process for Certifying 

Employment and Loans as Eligible for PSLF 6

Figure 2: PSLF Application Process 8

Figure 3: PSLF Certification Requests: Selected Outcomes for 

Borrowers Who Requested to Have Their Employment 

and Loans Certified as Eligible for Loan Forgiveness, as 

of April 2018 10

Figure 4: Cumulative Number of Borrowers Who Had Their 

Employment and Loans Certified as Eligible for PSLF, 

January 2012 to April 2018, by Quarter 10

Figure 5: Loan Forgiveness Applications: Selected Outcomes for 

Borrowers Who Applied for Loan Forgiveness, as of April 

2018 11

Figure 6: Certification and Denial Outcomes for Borrowers Who 

Requested to Have Their Employment and Loans 

Certified as Eligible for Loan Forgiveness, as of April 

2018 13

Figure 7: Hypothetical Example of the PSLF Servicer’s Payment 

Counting Process and Information Shared with Borrowers 23

Contents
Page ii GAO-18-547 Public Service Loan Forgiveness

Abbreviations

Direct Loan William D. Ford Federal Direct Loan

Education U.S. Department of Education

PSLF Public Service Loan Forgiveness

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-18-547 Public Service Loan Forgiveness

441 G St. N.W.

Washington, DC 20548

September 5, 2018

The Honorable Robert C. “Bobby” Scott

Ranking Member

Committee on Education and the Workforce

House of Representatives

The Honorable Susan A. Davis

Ranking Member

Subcommittee on Higher Education and Workforce Development

Committee on Education and the Workforce

House of Representatives

Starting in September 2017, borrowers began applying to have their 

federal student loans forgiven through the Public Service Loan 

Forgiveness (PSLF) program. This program, established by law in 2007, 

is intended to encourage individuals to enter and continue careers in 

public service by forgiving borrowers’ remaining federal student loan 

balances after they have made at least 10 years of loan payments while 

working in public service and meeting other requirements.1 Only loans 

provided through the William D. Ford Federal Direct Loan (Direct Loan) 

program qualify for forgiveness. The Department of Education 

(Education) manages the PSLF program and contracts with a single loan 

servicer to handle day-to-day activities associated with the program, 

which include responding to borrower inquiries, making preliminary 

determinations about whether borrowers’ employment and loans qualify 

for PSLF, and processing loan forgiveness applications.2

Although borrowers are now applying for loan forgiveness through the 

program, little is known about the processes for assessing borrower 

eligibility and whether these processes ensure consistent services to 

borrowers and safeguard taxpayer funds. In light of these issues, you 

asked us to review the PSLF program.

 1 The PSLF program was established by the College Cost Reduction and Access Act, 

Pub. L. No. 110-84, § 401, 121 Stat. 784, 800 (2007), as amended by the Higher 

Education Opportunity Act, Pub. L. No. 110-315, § 451(b), 122 Stat. 3078, 3262 (2008) 

(codified at 20 U.S.C. § 1087e(m)).

2 The Pennsylvania Higher Education Assistance Agency’s FedLoan Servicing unit is the 

exclusive servicer for borrowers pursuing PSLF.

Letter
Page 2 GAO-18-547 Public Service Loan Forgiveness

This report examines (1) the number of borrowers pursuing PSLF and the 

extent to which Education has conducted outreach to increase borrower 

awareness of program eligibility requirements, and (2) the extent to which 

Education has provided key information to the PSLF servicer and 

borrowers.

To address these questions, we conducted our review of the PSLF 

program using the following approaches:

• To examine the number of borrowers pursuing PSLF, we analyzed the 

most recent available data from the PSLF servicer on the volume of 

borrower requests to have their employment and loans certified as 

eligible and loan forgiveness applications, including approvals, going 

back to when these processes were established by Education. 

Specifically, we analyzed data on employment and loan certification 

requests from January 2012 through April 2018, and data on loan 

forgiveness applications from September 2017 through April 2018. 

We also analyzed data on the reasons why borrowers were denied 

certification and loan forgiveness. We assessed the reliability of these 

data by reviewing data system documentation from the PSLF servicer 

and interviewing knowledgeable officials, and we determined that the 

data were sufficiently reliable for our reporting purposes. To assess 

Education’s outreach to borrowers about eligibility requirements, we 

reviewed the program documents and information that Education and 

the PSLF servicer provide to borrowers, and interviewed Education 

officials. To identify common questions borrowers have about these 

requirements, we interviewed officials from the four largest federal 

student loan servicers, including officials and frontline staff from the 

PSLF servicer. We examined a 2017 Consumer Financial Protection 

Bureau report on borrower complaints, including those related to the 

PSLF program. We assessed Education’s outreach efforts against the 

department’s objective in its strategic plan for fiscal years 2018 

through 2022 to improve the quality of service for customers across 

the entire student aid life cycle.

• To examine key information Education has provided to the PSLF 

servicer and borrowers, we reviewed Education’s processes for 

providing and sharing information and assessed them against federal 

internal control standards for communicating with external parties and 

using quality information. We reviewed the various methods 

Education uses to provide guidance and instructions to the PSLF 

servicer, including the servicing contract, contract updates, and 

emails. We examined the main information sources used by the 

servicer to evaluate employer eligibility and reviewed its process for 
Page 3 GAO-18-547 Public Service Loan Forgiveness

obtaining prior loan payment information from other loan servicers. 

We also reviewed the information that Education and the PSLF 

servicer provided to borrowers about qualifying employers and 

payments. We interviewed Education officials and the PSLF loan 

servicer’s management and frontline staff. We reviewed Education’s 

monitoring reports on the PSLF servicer’s operations and the PSLF 

servicer’s internal handbook for processing employment and loan 

certifications and forgiveness applications.

For both objectives, we also reviewed relevant federal laws and 

regulations. In addition, at the time of our review, there was ongoing state 

and federal litigation related to the administration of the PSLF program.3

Therefore, we scoped our study to minimize overlap with issues pending 

in litigation. For example, we did not assess any individual borrower 

eligibility determinations or qualifying loan payment counts made by the 

PSLF servicer. As a result of this approach, our findings do not draw any 

conclusions about how individual borrowers or employers may have been 

affected by any of the program administration issues addressed in this 

report.

We conducted this performance audit from August 2017 to September 

2018 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Education administers federal student aid programs, including the Direct 

Loan program, through the Office of Federal Student Aid. Under the 

Direct Loan program, Education issues and oversees the loans while 

contractors service them. Education currently contracts with nine loan 

servicers that each handle the billing and other services for a portion of 

the over $1 trillion in outstanding student loans provided through the 

 3 Among others, see Commonwealth v. Pa. Higher Educ. Assistance Agency, No. 1784-

2682 (Mass. Super. Ct. filed Aug. 23, 2017); Am. Bar Ass’n v. U.S. Dep’t of Educ., No. 16-

2476 (D.D.C. filed Mar. 23, 2017); Morris v. Pa. Higher Educ. Assistance Agency, No. 18-

31 (E.D. Pa. filed Jan. 8, 2018). These lawsuits were still pending as of August 15, 2018. 

Background
Page 4 GAO-18-547 Public Service Loan Forgiveness

Direct Loan program.4 These servicers track and manage day-to-day 

servicing activities, and they report key information on the status of each 

loan to Education’s central student loan database. In 2011, Education 

contracted with one of its existing loan servicers to become the single 

servicer for borrowers pursuing PSLF. The PSLF servicer is responsible 

for processing certification requests and forgiveness applications, as well 

as servicing the loans of borrowers who have met basic PSLF eligibility 

requirements.

The PSLF program provides eligible borrowers with forgiveness on the 

remaining balance of their Direct Loans after they have met program 

requirements.5 To receive forgiveness for a loan, borrowers are required 

to be employed by a qualifying employer when making 120 qualifying 

payments, at the time they apply for forgiveness, and at the time they 

receive forgiveness for their loans.6 Specifically, borrowers are required 

to:

• Work full-time for a public service organization, such as7

• a government organization, agency, or entity at any level (federal, 

state, local, or tribal);

• a nonprofit, tax exempt organization (under section 501(c)(3) of 

the Internal Revenue Code); or

 4 Prior to 2009, Education used a single contractor to handle all loan servicing. This 

company is no longer servicing federal loans, and its loan portfolio has been redistributed 

among the current loan servicers.

5 All types of Direct Loans are eligible for forgiveness, including Direct Subsidized Loans, 

Direct Unsubsidized Loans, Direct Graduate PLUS Loans, and Direct Consolidation 

Loans. Parent PLUS Loans are also eligible for forgiveness, but cannot be repaid under 

any of the income-driven repayment plans unless these loans are consolidated into a new 

Direct Consolidation Loan. Borrowers may also consolidate certain federal loans that are 

not eligible for PSLF, such as loans under the Federal Family Education Loan program 

and Perkins loans, into a single Direct Consolidation Loan to qualify for PSLF. However, 

only the post-consolidation payments count toward the 120 payments required for PSLF. 

6 See 34 C.F.R. § 685.219 for the regulations governing the PSLF program.

7 For purposes of this report, we refer to these organizations as “qualifying employers” or 

“qualifying employment.” Serving in a full-time AmeriCorps or Peace Corps position also 

counts as qualifying employment for the PSLF program. Certain types of employment are 

not eligible for PSLF; for example, work as a member of Congress, work for labor unions, 

work for partisan political organizations, and some activities performed for religious 

organizations. Borrowers working part-time for more than one qualifying employer at the 

same time are considered full-time for PSLF purposes as long as their combined work 

hours average at least 30 hours per week. 
Page 5 GAO-18-547 Public Service Loan Forgiveness

• another private nonprofit organization that provides certain public 

services.

• Not be in default and be repaying their loans through an incomedriven repayment plan (in which borrowers’ monthly payments are 

based on their income and family size); the 10-year Standard 

repayment plan; or another plan if the monthly payment amounts 

equal or exceed the amount the borrower would have paid under the 

10-year Standard repayment plan.8 Although the 10-year Standard 

repayment plan qualifies for PSLF, borrowers in this plan will pay off 

their loans before they are eligible for forgiveness unless they change 

to an income-driven repayment plan that leaves them with a balance 

remaining to be forgiven after 120 payments.9

• Make 120 on-time monthly loan payments for the full amount due on 

their bill after October 1, 2007. These monthly payments do not need 

to be consecutive.

In January 2012, Education began offering a voluntary process to certify 

borrowers’ public service employment and loans as eligible for PSLF. 

Borrowers can request to have their employment and loans certified at 

any time to make sure they are meeting basic program requirements and 

are on track towards qualifying for loan forgiveness (see fig. 1). Once a 

borrower submits a request, the PSLF servicer reviews the borrower’s 

employment and loans to determine if they qualify, and if so, counts how 

many qualifying payments the borrower has made.10

 8 Education offers five income-driven repayment plans to eligible borrowers: Pay As You 

Earn, Revised Pay As You Earn, two Income-Based Repayment plans, and IncomeContingent Repayment.

9 Borrowers who make 120 monthly payments under the 10-year Standard repayment 

plan will have completely paid off their loans, and therefore would have no remaining 

balance left to be forgiven under PSLF. However, a borrower that was initially in a 10-year 

Standard repayment plan and later changed to an income-driven repayment plan would 

be able to count payments made under the Standard plan towards their 120 required 

monthly payments.

10 Education recommends that borrowers submit new requests to certify their employment 

and loans both annually and when they switch employers.
Page 6 GAO-18-547 Public Service Loan Forgiveness

Figure 1: Education’s Voluntary Process for Certifying Employment and Loans as 

Eligible for PSLF

In September 2017, 10 years after the PSLF program was established, 

Education began accepting loan forgiveness applications from borrowers. 

The application is similar to the form borrowers use to request certification 

of their employment and loans for PSLF, but is intended for borrowers 

that have already made 120 qualifying payments (see fig. 2). The PSLF 

servicer reviews a borrower’s application and incorporates information 

from any previously approved certification forms to determine if the 

borrower’s employment and loans qualify and if they have made 120 

qualifying payments. If the borrower meets all of these requirements, the 
Page 7 GAO-18-547 Public Service Loan Forgiveness

PSLF servicer forwards the application to Education for final review.11 If 

Education determines the borrower has met all eligibility requirements, it 

directs the PSLF servicer to forgive the remaining balance on the 

borrower’s loans.

 11 Unless a borrower requests otherwise on their application, the PSLF servicer places 

eligible loans in forbearance while the application is being reviewed by Education. 

However, if Education determines that the borrower is not eligible for forgiveness, the

forbearance ends and any unpaid interest that accrued during this period may be added to 

the loan principal balance.
Page 8 GAO-18-547 Public Service Loan Forgiveness

Figure 2: PSLF Application Process
Page 9 GAO-18-547 Public Service Loan Forgiveness

Over 890,000 borrowers have taken an initial step towards qualifying for 

the PSLF program by voluntarily having their employment and loans 

certified as eligible for PSLF, according to data from the PSLF servicer as 

of April 2018.12 Of these, over 520,000 borrowers had recorded at least 

one qualifying payment that counted towards the 120 required to be 

eligible for loan forgiveness (see fig. 3). In total, almost 1.2 million 

borrowers requested to have their employment and loans certified but 

over 280,000 were denied, primarily due to missing information on the 

form, or because they did not have qualifying federal loans or work for a 

qualifying employer, according to data from the PSLF servicer.

 12 For the purposes of this report, we consider borrowers to have certified employment 

and loans when they have submitted at least one approved certification form.

Many Borrowers Are 

Pursuing Public 

Service Loan 

Forgiveness, and 

Recent Legislation 

Requires Education 

to Conduct Additional 

Outreach to 

Borrowers

Over 890,000 Borrowers 

Took an Initial Step 

Towards Qualifying for 

PSLF by Having Their 

Employment and Loans 

Certified, and 55 Have 

Received Loan 

Forgiveness
Page 10 GAO-18-547 Public Service Loan Forgiveness

Figure 3: PSLF Certification Requests: Selected Outcomes for Borrowers Who 

Requested to Have Their Employment and Loans Certified as Eligible for Loan 

Forgiveness, as of April 2018

Note: Of borrowers that had their employment and loans certified as eligible for PSLF, 58 percent had 

recorded at least one qualifying payment.

The number of new borrowers whose employment and loans have been 

certified as eligible for PSLF has increased in each of the past 6 years, 

according to PSLF servicer data (see fig. 4). Officials with the PSLF 

servicer said they anticipated that the volume would continue to increase 

as the program gains visibility.

Figure 4: Cumulative Number of Borrowers Who Had Their Employment and Loans Certified as Eligible for PSLF, January 

2012 to April 2018, by Quarter

Note: These borrowers voluntarily had their employment and loans certified as eligible for PSLF as an 

initial step towards applying for loan forgiveness.
Page 11 GAO-18-547 Public Service Loan Forgiveness

In the first 8 months that borrowers were able to apply for loan 

forgiveness (September 2017 through April 2018), Education had 

approved 55 borrowers and forgiven a total of almost $3.2 million in 

outstanding student loan balances, an average of almost $58,000 per 

borrower. The amount of loan forgiveness for individual borrowers ranged 

from almost $800 to almost $290,000. Over 19,300 borrowers had 

submitted loan forgiveness applications as of April 2018 (see fig. 5). Of 

the almost 17,000 borrowers with applications that had been processed, 

over 40 percent had qualifying loans and employment but were denied 

because they had not yet made 120 qualifying payments. The other most 

common reasons borrowers were denied included missing information on 

the application or because the borrower did not have qualifying federal 

loans. Education officials estimated that about 700 borrowers will be 

approved for loan forgiveness by September 30, 2018.

Figure 5: Loan Forgiveness Applications: Selected Outcomes for Borrowers Who 

Applied for Loan Forgiveness, as of April 2018

a

One hundred twenty-nine of these borrowers were still awaiting final approval from Education as of 

April 30, 2018. Education had not denied any of the applications recommended for approval by the 

PSLF servicer, according to PSLF servicer officials.

Although Education has conducted some outreach to communicate PSLF 

program requirements to borrowers, the large number of borrowers 

whose certification requests and forgiveness applications were denied 

suggests that many borrowers do not understand or are not aware of 

these requirements. For example, over half of borrowers that requested to 

have their employment and loans certified as of April 2018 either did not 

meet basic eligibility requirements or had yet to make any qualifying loan 

payments. This includes over 150,000 borrowers who requested to have 

their employment and loans certified despite not having qualifying federal 

loans, which suggests these borrowers either did not know which types of 

Borrower Confusion about 

PSLF Requirements 

Persists, and Recent 

Legislation Requires 

Education to Conduct 

Additional Outreach
Page 12 GAO-18-547 Public Service Loan Forgiveness

loans they had or which types qualified for the program.13 Borrowers who 

had qualifying loans also may have been confused about requirements 

related to making qualifying payments. Over 370,000 borrowers that had 

their employment and loans certified as of April 2018 had not made any 

qualifying payments at the time of certification because they were not on 

qualifying repayment plans, had loans in a deferment or forbearance, 

were still in the grace period before starting repayment, or had recently 

consolidated their loans, among other reasons, according to PSLF 

servicer data (see fig. 6).14 Although some of these borrowers may have 

understood how prior choices they made regarding repayment of their 

loans would affect their ability to make qualifying payments, other 

borrowers may not have.

 13 Similarly, many borrowers submitting forgiveness applications also did not meet certain 

eligibility requirements, suggesting they may not have understood or were not aware of 

these requirements. For example, about 20 percent of borrowers who applied for loan 

forgiveness did not have any qualifying federal loans.

14 Because the number of borrowers’ qualifying payments is calculated based on the 

information included on their certification request forms, it is possible that some additional 

borrowers have made payments that will be counted as qualifying payments once they 

submit new certification forms. Deferment and forbearance allow borrowers to temporarily 

stop making loan payments or temporarily reduce the payment amount under certain 

circumstances, but any payments made while in deferment or forbearance status do not 

count towards PSLF. When borrowers consolidate loans, their qualifying payment count 

resets to zero, and any prior payments they made no longer qualify towards the required 

120 payments. The grace period is a set period of time after borrowers graduate, leave 

school, or drop below half-time enrollment before they must begin repaying certain federal 

loans. Payments made during the grace period do not count towards PSLF.
Page 13 GAO-18-547 Public Service Loan Forgiveness

Figure 6: Certification and Denial Outcomes for Borrowers Who Requested to Have 

Their Employment and Loans Certified as Eligible for Loan Forgiveness, as of April 

2018

Note: Other reasons for denial include borrowers who submitted incomplete information on the form 

or did not have qualifying employment, according to PSLF servicer officials.

Officials with the PSLF servicer said borrowers were frequently confused 

by program requirements related to qualifying loans, employment, 

repayment plans, and payments. For example, PSLF servicer officials 

said that borrowers were sometimes unaware that they were not on a 

qualifying repayment plan or that forbearance, deferment, and loan 

consolidation would affect their qualifying payments. PSLF servicer 

frontline customer service staff also said they frequently received calls 

from borrowers who were confused about whether their loans qualified for 

PSLF and other program requirements. Two other loan servicers we 

spoke to identified the same general areas of confusion among borrowers 

who call with questions about PSLF. In addition, borrower complaints 

reported by the Consumer Financial Protection Bureau indicate confusion 

with PSLF requirements related to qualifying loans and payments.15

Education uses several methods to conduct outreach to inform borrowers 

about PSLF requirements, but denial data suggest and PSLF servicer 

officials confirmed that borrower confusion persists. Education currently 

provides information on its website about PSLF requirements and links to 

an online portal where borrowers can check what types of loans they 

have and identify their loan servicer.16 When the PSLF servicer notifies 

 15 Consumer Financial Protection Bureau, Staying on Track While Giving Back: The Cost 

of Student Loan Servicing Breakdowns for People Serving Their Communities

(Washington, D.C.: June 2017).

16 See https://studentaid.ed.gov/sa/repay-loans/forgiveness-cancellation/public-service.
Page 14 GAO-18-547 Public Service Loan Forgiveness

borrowers that their certification requests or forgiveness applications were 

denied, the notification letter includes information on program 

requirements and explains why the borrower did not qualify for the 

program. Education has also adopted other methods to raise awareness 

of the program among borrowers, such as webinars and outreach to 

schools, in response to a recommendation in our previous report.17

Education also instructs borrowers who have additional questions about 

PSLF to contact the PSLF servicer. However, officials with the PSLF 

servicer said they can provide more details about the program but cannot 

answer certain eligibility questions, such as whether a particular borrower 

has qualifying employment or is on a qualifying repayment plan, until the 

borrower submits a form to request certification.18 Officials with three 

other loan servicers we spoke with also said it is their general policy not 

to answer specific questions about an individual borrower’s eligibility for 

PSLF due to the complexity of program requirements, and they instead 

direct the borrower to contact the PSLF servicer. Although this approach 

may help avoid the risk of other servicers providing borrowers with 

incorrect advice, it highlights the need for Education to provide borrowers 

with clear and sufficient information about how to qualify for the program. 

It is essential for borrowers to understand eligibility requirements because 

the retrospective nature of the program requires borrowers to make 

decisions about their loans and employment months or years before they 

submit a PSLF certification request or apply for loan forgiveness. For 

example, the Consumer Financial Protection Bureau reported that 

borrowers have complained of spending years making payments, 

believing they were making progress towards PSLF loan forgiveness, and 

then learning that they were not eligible.19

Recent legislation requires Education to conduct additional outreach. The 

consolidated appropriations act enacted in March 2018 appropriated $350 

 17 GAO, Federal Student Loans: Education Could Do More to Help Ensure Borrowers Are 

Aware of Repayment and Forgiveness Options, GAO-15-663 (Washington, D.C.: August 

25, 2015). In addition, Education officials said they developed toolkits for employers and 

schools and required student loan servicers to provide borrowers with information about 

PSLF when they expressed interest in the program.

18 In some cases, this is because another loan servicer is servicing the borrower’s loans, 

and the PSLF servicer cannot access information about the borrower until it processes the 

certification request form. 

19 Consumer Financial Protection Bureau, Staying on Track While Giving Back: The Cost 

of Student Loan Servicing Breakdowns for People Serving Their Communities

(Washington, D.C.: June 2017).
Page 15 GAO-18-547 Public Service Loan Forgiveness

million to forgive the loans of borrowers who otherwise would qualify for 

PSLF had they not selected a non-qualifying repayment plan.20 In addition 

to these funds, the act directed that $2.3 million of Education’s 

appropriation for administering student aid be used to conduct outreach to 

borrowers about PSLF, to help ensure borrowers are meeting program 

requirements.21 The act specifically requires Education to communicate 

PSLF program requirements to all Direct Loan borrowers and improve 

PSLF outreach and information through calls, electronic communications, 

and other methods. Once implemented, these provisions could reduce 

confusion about PSLF requirements and help Education provide better 

service to borrowers.

 20 Consolidated Appropriations Act, 2018, Pub. L. No. 115-141, § 315, 132 Stat. 348. The 

funds are available until expended, on a first-come, first-serve basis, to forgive the loans 

of borrowers who were repaying their Direct Loans through certain non-qualifying 

repayment plans, such as Graduated or Extended repayment plans, provided they meet 

certain additional requirements. According to Education, this temporarily expanded 

opportunity for loan forgiveness is only available to borrowers who previously submitted a 

PSLF application that was denied solely because some or all payments were not made 

under a qualifying repayment plan, who have at least 10 years of qualifying employment, 

and who have made 120 qualifying payments under the requirements for the temporary 

program. 

21 Pub. L. No. 115-141, § 316, 132 Stat. 348.
Page 16 GAO-18-547 Public Service Loan Forgiveness

Education does not have a comprehensive document or manual to 

provide the PSLF servicer guidance and instructions, which PSLF 

servicer officials said makes it difficult to effectively administer the 

program and provide consistent service to borrowers. Instead, 

Education’s guidance and instructions to the PSLF servicer are dispersed 

in a piecemeal manner across multiple documents, including Education’s 

original contract with the servicer, multiple updates to the contract, and 

hundreds of emails. According to PSLF servicer officials, administering 

the program based on this fragmented collection of guidance and 

instructions creates a risk that relevant information may be overlooked.

Education’s use of email to communicate key guidance and instructions 

to the PSLF servicer is particularly problematic because this important 

information is not disseminated to relevant individuals at Education and 

the PSLF servicer in the same standard fashion as official changes to the 

servicing contract. Various individuals at Education have sent emails with 

guidance and instructions to different staff at the PSLF servicer. As a 

result, all the relevant parties may not be aware of important policy 

changes or clarifications provided in these emails, according to PSLF 

servicer officials and Education’s monitoring reports. In one instance, for 

example, Education staff incorrectly identified what they thought was an 

error in how the servicer was certifying borrowers that were employed 

part-time because they were not aware of the most recent guidance that 

other staff at Education had emailed the servicer on the topic. Similarly, 

PSLF servicer officials said their staff are sometimes unaware of relevant 

Education Could 

Provide More 

Comprehensive 

Information to 

Improve Program 

Administration and 

Qualifying 

Employment and 

Loan Payment 

Determinations

Education’s Piecemeal 

Guidance and Instructions 

to the PSLF Loan Servicer 

Create Challenges for 

Program Administration
Page 17 GAO-18-547 Public Service Loan Forgiveness

guidance and instructions in emails provided by Education, which creates 

a risk that some policy updates will be overlooked and not consistently 

implemented. Education has also used email to communicate certain 

policy clarifications involving employer eligibility and payment counting 

that, according to the PSLF servicer, have affected hundreds of 

borrowers and set precedents for future eligibility decisions.

Gaps in Education’s guidance and instructions have also left the PSLF 

servicer uncertain about how to administer key aspects of the program. 

For example, PSLF servicer officials said that from 2016 to 2018 they 

were awaiting additional clarifications from Education about how to 

account for loan payments when borrowers pay more than the amount 

due or submit a payment several weeks before the due date. How 

overpayments and prepayments are accounted for can affect whether the 

borrower’s subsequent payments qualify for PSLF because borrowers 

can only receive credit for one payment per month and only when a 

payment is due. While Education provided a clarification about how to 

address this issue in May 2018, current guidance from Education on other 

topics is still unclear or incomplete, according to PSLF servicer officials.

The absence of a central, authoritative source of PSLF guidance and 

instructions creates a risk of differing interpretations and inconsistent 

implementation. The PSLF servicer has developed its own internal 

processing handbook based on Education’s guidance and instructions, 

which PSLF servicer officials said is useful for helping staff process 

certifications and forgiveness applications. However, Education has 

reviewed sections of this processing handbook and identified places 

where the handbook does not accurately reflect PSLF requirements and 

could result in borrowers’ certification requests being improperly approved 

or denied. The PSLF servicer has made updates to its processing 

handbook to address certain issues that Education identified, but 

Education has not conducted a comprehensive review of this handbook. 

As a result, there is a risk that the PSLF servicer may still be applying 

Education’s guidance and instructions differently from how the agency 

intended. PSLF servicer officials said it would be helpful if Education 

created a centralized manual of PSLF guidance and instructions. The lack 

of a central guidance document also makes it difficult to maintain program 

continuity in the event of staff turnover or if Education decides to contract 

with a new servicer to administer the PSLF program. Federal internal 

control standards state that agencies should communicate information to 

those who need it, in a form that enables them to carry out their 
Page 18 GAO-18-547 Public Service Loan Forgiveness

responsibilities.22 Education has recently taken some steps to provide 

clearer guidance and instructions, such as holding meetings with PSLF 

servicer officials every 2 weeks to discuss any administrative issues. 

Education officials also told us they plan to develop a comprehensive 

PSLF servicing manual, but they do not have a timeline for completing it. 

They are currently drafting an initial section of the manual focusing on 

payment counting. The current lack of a definitive and comprehensive 

source of guidance and instructions for the PSLF servicer creates the risk 

of inconsistent interpretations that could potentially result in borrowers 

being improperly denied loan forgiveness since Education does not 

currently review loan forgiveness applications that are denied by the 

PSLF servicer.

Education has provided the PSLF servicer and borrowers with limited 

information that could help them determine which employers qualify for 

PSLF, creating uncertainty for borrowers and increasing the risk that the 

PSLF servicer may improperly certify or deny certification to some 

borrowers. Education has not provided the PSLF servicer with a definitive 

source of information for determining which employers qualify a borrower 

for loan forgiveness. Instead, Education has identified some data sources 

the PSLF servicer can use to determine whether borrowers are working 

for qualifying employers. However, these sources are not comprehensive, 

and PSLF servicer officials said they sometimes have to consult other 

sources that have significant limitations. For example, Education directs 

the PSLF servicer to review the Internal Revenue Service’s public list of 

501(c)(3) organizations to identify qualifying nonprofit employers. Since 

this list does not capture all potentially qualifying nonprofits, the PSLF 

servicer supplements this with other sources that have not been fully 

reviewed or assessed for accuracy by Education. For example, PSLF 

servicer officials told us they use an online directory of nursing home 

facilities to help determine if certain nursing homes are nonprofit 

employers. However, this website explicitly states that it does not 

guarantee that the information it provides is accurate or current. PSLF 

servicer officials also said they sometimes use state government websites 

to research organizations’ nonprofit status, but they only have access to 

the relevant information from states that provide it for free. For assessing 

government employers, Education directs the servicer to www.usa.gov, 

 22 GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 10, 2014).

Additional Information 

from Education Could 

Improve the PSLF 

Servicer’s and Borrowers’ 

Ability to Determine 

Whether Borrowers’ 

Employment Qualifies for 

Loan Forgiveness
Page 19 GAO-18-547 Public Service Loan Forgiveness

an official federal government website that describes government 

agencies and services, but this source provides limited information on 

state and local government employers. In addition, PSLF servicer officials 

said it is particularly difficult to assess certain types of employers, such as 

quasi-governmental entities and charter schools. PSLF servicer officials 

said that when they are uncertain whether an employer qualifies, they 

elevate the assessment to Education, but they generally try to resolve as 

many employer determinations as possible by using supplemental

sources to research employers.23 However, the reliability of some of these 

supplemental sources is unclear.

PSLF servicer officials said that having additional information would help 

them assess employers more quickly and minimize the risk of inaccurate 

decisions. One way to provide this information would be for Education to 

develop an official, comprehensive list of qualifying employers, which 

would help the PSLF servicer assess employers and help borrowers 

determine whether they are eligible for PSLF, according to PSLF servicer 

officials. Education officials said they are considering creating their own 

list of qualifying employers and are investigating how to leverage 

information from other federal government agencies that could be useful 

for categorizing employers. In particular, Education officials said they 

have reached out to the Internal Revenue Service to explore the 

feasibility of obtaining relevant data on employers. Education could also 

expand and improve on a database that the PSLF servicer created based 

on its prior assessments of employers. Education staff that conducted a 

spot check on the PSLF servicer’s database expressed concerns about 

using it as a sole source for assessing employers, according to an 

Education monitoring report, but Education officials said it could provide a 

foundation for Education to build on.

Borrowers would also benefit from additional information about qualifying 

employers, according to PSLF servicer officials. Education currently 

provides borrowers with basic information on the types of employers that 

qualify for PSLF, but not sufficient details to reliably determine whether 

specific employers qualify. When borrowers contact their loan servicer 

with questions about their employer’s eligibility, officials with the PSLF 

servicer and other loan servicers we spoke with said they generally do not 

provide borrowers with information about whether a specific employer 

 23 With the exception of employment decisions the PSLF servicer elevates, Education 

generally does not asses the PSLF servicer’s employment determinations until borrowers 

are approaching final loan forgiveness, according to Education officials.
Page 20 GAO-18-547 Public Service Loan Forgiveness

qualifies, due to the complexities involved in assessing qualifying 

employers. Instead, borrowers are encouraged to submit an employment 

certification form once they are working for an employer in order to find 

out if the employer qualifies. PSLF servicer officials said that providing 

borrowers with access to additional information about qualifying 

employers, such as an official list, would reduce uncertainty for borrowers 

and reduce the number of borrowers who submit certification requests 

and forgiveness applications despite working for non-qualifying 

employers.24 In addition, making this information readily available to 

borrowers could help them to make better informed employment 

decisions rather than having to wait to submit a certification request after 

they have started a job to find out if their employer qualifies.

Federal internal control standards state that agencies should 

communicate the necessary quality information to those who need it in 

order to achieve the agencies’ objectives.25 Unless Education provides 

additional information to help the PSLF servicer make employer 

assessments, it will remain difficult to determine whether employers 

qualify for the program, raising the risk that borrowers’ certification 

requests will be improperly approved or denied. Moreover, without access 

to sufficient information about qualifying employers, borrowers will not be 

able to reliably determine whether certain employers qualify for PSLF. 

This creates uncertainty for borrowers as to which jobs and careers to 

pursue and leaves them to make important employment decisions without 

knowing until after the fact how these decisions affect their future 

eligibility for PSLF.

 24 Out of over 1 million borrowers who submitted PSLF certification requests as of January 

2018, almost 84,000 borrowers had at least one request denied for having non-qualifying 

employment. 

25 GAO-14-704G.
Page 21 GAO-18-547 Public Service Loan Forgiveness

Education does not ensure the PSLF servicer receives consistent 

information on borrowers’ prior loan payments from other loan servicers, 

which could raise the risk of qualifying payments being miscounted. In 

order to process certification requests and loan forgiveness applications, 

the PSLF servicer has to examine the borrower’s prior loan payment 

information to determine which prior payments count towards the 120 

needed to qualify for loan forgiveness. This is relatively easy in cases 

where the PSLF servicer was servicing the borrower’s loans during the 

entire period he or she was pursuing PSLF because the servicer already 

has the necessary information on their prior payments, according to PSLF 

servicer officials. However, the PSLF servicer does not have the same 

information readily available for loans that are serviced by one of 

Education’s eight other loan servicers. For these loans, Education 

established a process for servicers to use in transferring loan and prior 

payment information to the PSLF servicer.26 The servicers transfer most 

information through standardized templates that Education developed. 

However, despite the use of standardized templates, the PSLF servicer 

does not receive consistent and reliable information from other servicers, 

according to PSLF servicer officials. For example, PSLF servicer officials 

said the lack of standard definitions and terminology among loan 

servicers leads servicers to interpret some data fields differently, resulting 

in inconsistencies in the data other loan servicers report to the PSLF 

servicer. Comparable data and standardized terminology is particularly 

important given the need for loan servicers with different systems and 

practices to communicate key payment information with one another. 

PSLF servicer officials said inconsistencies in the information provided by 

 26 PSLF servicer officials said they request the transfer of loans and prior payment 

information from other servicers after the borrower has submitted a certification request or 

loan forgiveness application and the PSLF servicer has determined that the borrower’s 

loans and employment qualify as eligible for PSLF. 

Education Could Improve 

the Information Provided 

to the PSLF Servicer and 

Borrowers about Whether 

Borrowers’ Payments 

Qualify for Loan 

Forgiveness

Collecting Consistent Payment 

Information
Page 22 GAO-18-547 Public Service Loan Forgiveness

other loan servicers make it challenging to determine whether borrowers 

are on qualifying repayment plans or making qualifying payments. For 

example, when a borrower has multiple loans, PSLF servicer officials said 

they assess PSLF eligibility and payments separately for each individual 

loan. Officials added that some servicers only report total monthly 

payments for the borrower’s combined loans, and not how these 

payments were allocated among each loan. This makes it difficult for the 

PSLF servicer to determine whether the borrower paid the full monthly 

payment amount due on each loan, which it needs to know in order to 

determine whether the payment qualifies for PSLF.

Officials with Education and the PSLF servicer said that inconsistencies in 

the information obtained from other loan servicers increase the risk of 

miscounting qualifying payments. Education officials said they have 

started to track these data consistency problems and coordinate 

discussions among the PSLF servicer and the three other loan servicers 

that together provide the data systems used by all nine servicers. 

However, these efforts are in the early stages. Federal internal control 

standards state that agencies should use quality information to achieve

their objectives.27 Standardizing the prior payment information transferred 

among servicers could improve the PSLF servicer’s ability to determine 

qualifying payment counts for borrowers transferring from other servicers.

Although Education and PSLF servicer officials acknowledge the risk of 

miscounting qualifying payments, the PSLF servicer does not provide 

borrowers with sufficient information to easily catch errors. In addition to 

the risks caused by inconsistent prior payment information from other 

loan servicers, the payment counting process is also vulnerable to errors 

in instances when the PSLF servicer has to manually review payment 

information from other servicers, according to PSLF servicer officials and 

an Education monitoring report.28 Borrowers whose loans were 

transferred to the PSLF servicer from other loan servicers have 

complained about inaccurate qualifying payment counts, according to a 

 27 GAO-14-704G.

28 For example, when a borrower’s prior loan servicer is no longer servicing Direct Loans, 

or if the borrower has had more than one prior loan servicer, the borrower’s payment 

history is provided to the PSLF servicer in a series of original loan servicing documents 

rather than the standard templates. The PSLF servicer has to review these documents to 

manually identify relevant payment information. In some cases, PSLF servicer officials 

said they must review dozens, or even hundreds of pages of loan servicing documents, 

and reconcile conflicting payment information as needed.

Communicating Information to 

Borrowers
Page 23 GAO-18-547 Public Service Loan Forgiveness

Consumer Financial Protection Bureau report.29 Officials with the PSLF 

servicer said they rely on borrowers to catch any payment counting errors

resulting from issues with information provided by other loan servicers. 

However, the PSLF servicer provides borrowers with aggregate counts of 

qualifying payments, which are useful for helping borrowers track their 

progress, but do not provide borrowers with enough detail to check the 

servicer’s counts and identify prior payments that the servicer may have 

missed (see fig. 7). Borrowers have several options for disputing payment 

counts or other aspects of the eligibility determination process, including 

contacting the PSLF servicer or filing an official complaint with 

Education’s Federal Student Aid Ombudsman Group or through the 

Federal Student Aid Feedback System.30 However, the lack of detailed 

information on qualifying payment counts makes it difficult for borrowers 

to determine whether the count is correct or not.

Figure 7: Hypothetical Example of the PSLF Servicer’s Payment Counting Process and Information Shared with Borrowers

 29 Consumer Financial Protection Bureau, Staying on Track While Giving Back: The Cost 

of Student Loan Servicing Breakdowns for People Serving Their Communities

(Washington, D.C.: June 2017).

30 Education’s Federal Student Aid Ombudsman Group is dedicated to helping resolve 

disputes related to the federal student aid programs. Education’s Federal Student Aid 

Feedback System is an online portal that allows federal student aid customers to submit 

complaints, provide positive feedback, and report allegations of suspicious activity 

regarding their experience with federal student aid programs.
Page 24 GAO-18-547 Public Service Loan Forgiveness

Education officials said they have not considered requiring the PSLF 

servicer to provide more detailed information to borrowers on which prior 

payments were approved or denied. Officials noted that there would be a 

cost associated with providing this information to borrowers, although 

they have not produced a cost estimate. Also, officials said that providing 

too much information may confuse borrowers, and they must consider 

how to meet borrowers’ need for detailed information without 

overwhelming borrowers with payment counting complexities. Officials 

with the PSLF servicer said providing this information to borrowers could 

be helpful but would require time to confirm the information was correct

and would only be done at the direction of Education. Federal internal 

control standards state that agencies should communicate necessary 

quality information to external parties.31 While providing too much 

information could prove counterproductive, borrowers could benefit from 

receiving greater detail about their qualifying payments beyond the 

aggregate counts of qualifying payments that they currently receive. 

Without clearer and more detailed information on qualifying payments, 

borrowers may not detect any errors in payment counts, which could 

ultimately affect borrowers’ eligibility for loan forgiveness.

Education is responsible for establishing the administrative structure 

necessary to fulfill the PSLF program’s goal of encouraging individuals to 

enter and continue in public service employment by providing loan 

forgiveness to eligible borrowers who meet program requirements.

However, Education has not provided the PSLF servicer with a 

comprehensive source of guidance and instructions on how to operate 

the program, raising the risk that the PSLF servicer may improperly 

approve or deny borrowers’ certification requests and forgiveness 

applications. Education officials told us they have plans for creating a 

comprehensive PSLF servicing manual, but no timeline for doing so.

Working for a qualifying employer is one of the key requirements of the 

PSLF program; however, Education has not provided the PSLF servicer 

and borrowers with sufficient information for determining whether 

employers qualify. This makes the PSLF servicer’s employer 

assessments vulnerable to inconsistencies and fosters uncertainty for 

borrowers as to whether or not their employment will eventually qualify 

them for loan forgiveness.

 31 GAO-14-704G.

Conclusions
Page 25 GAO-18-547 Public Service Loan Forgiveness

Similarly, inconsistencies in the information used for counting borrowers’ 

qualifying loan payments raise the risk of errors. Borrowers should be 

confident that their loan payments will be accurately counted regardless 

of who their servicer is. However, Education has not ensured the PSLF 

servicer is receiving consistent loan payment history information from 

other loan servicers, increasing the risk of inaccurate qualifying payment 

counts. The chance that these and any other payment counting errors will 

go undetected is compounded by the fact that Education does not require 

the PSLF servicer to provide borrowers with details on which payments 

qualified and which did not. This makes it difficult for borrowers to detect 

erroneous counts that could ultimately affect their eligibility for loan 

forgiveness. Consequently, some borrowers may be required to make 

more payments than necessary before receiving loan forgiveness, while 

others may be improperly approved for forgiveness.

We are making the following four recommendations to Education’s Office 

of Federal Student Aid:

The Chief Operating Officer of the Office of Federal Student Aid should 

develop a timeline for issuing a comprehensive guidance and instructions 

document for PSLF servicing. This could involve developing a new 

servicing manual or expanding upon the PSLF servicer’s existing 

processing handbook. (Recommendation 1)

The Chief Operating Officer of the Office of Federal Student Aid should 

provide additional information to the PSLF servicer and borrowers to 

enhance their ability to determine which employers qualify for PSLF. This 

could involve Education developing an authoritative list of qualifying 

employers or improving the PSLF servicer’s existing database, and 

making this information available to borrowers. (Recommendation 2)

The Chief Operating Officer of the Office of Federal Student Aid should 

standardize the information the PSLF servicer receives from other loan 

servicers to ensure the PSLF servicer obtains more consistent and 

accurate payment information for borrowers pursuing PSLF. 

(Recommendation 3)

The Chief Operating Officer of the Office of Federal Student Aid should 

ensure that borrowers receive sufficiently detailed information from the 

PSLF servicer to be able to identify any errors in the servicer’s counts of 

qualifying payments, including information on whether or not each 

payment qualified toward forgiveness. (Recommendation 4)

Recommendations for 

Executive Action
Page 26 GAO-18-547 Public Service Loan Forgiveness

We provided a draft of this report to Education for its review and 

comment. In its comments, reproduced in appendix I, Education 

concurred with each of our recommendations and identified steps it plans 

to take to implement them. To improve guidance and instructions for 

PSLF servicing, Education stated it is documenting PSLF requirements 

and guidelines and plans to incorporate them into a comprehensive 

guide. Regarding our recommendation to provide additional information 

on qualifying employers to the PSLF servicer and borrowers, Education 

stated that it is reviewing options for developing an online help tool that 

would be expanded to incorporate qualifying employer information. To 

standardize the information other loan servicers provide to the PSLF 

servicer, Education stated it will continue its efforts to address data 

definition issues related to the data exchanged between servicers. To 

ensure borrowers receive sufficiently detailed information on counts of 

qualifying payments, Education stated it will review the letters the PSLF 

servicer sends to borrowers to determine how to better communicate 

regarding qualifying payment counts, program requirements, and 

employer eligibility. We also provided relevant report sections to the PSLF 

servicer and the three other loan servicers included in our review for 

technical comments. The PSLF servicer provided technical comments, 

which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate

congressional committees, the Secretary of Education, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (617) 788-0534 or emreyarrasm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix II.

Melissa Emrey-Arras, Director

Education, Workforce, and Income Security

Agency Comments 

and Our Evaluation
Appendix I: Comments from the U.S. 

Department of Education

Page 27 GAO-18-547 Public Service Loan Forgiveness

Appendix I: Comments from the U.S. 

Department of Education
Appendix I: Comments from the U.S. 

Department of Education

Page 28 GAO-18-547 Public Service Loan Forgiveness
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 29 GAO-18-547 Public Service Loan Forgiveness

Melissa Emrey-Arras, (617) 788-0534 or emreyarrasm@gao.gov

In addition to the contact named above, Debra Prescott (Assistant 

Director), William Colvin (Analyst-in-Charge), and Linda Collins made key 

contributions to this report. Additional assistance was provided by James 

Bennett, Deborah Bland, Alicia Cackley, Sarah Cornetto, Hedieh Fusfield, 

Kirsten Lauber, Sheila R. McCoy, Jeffrey G. Miller, Jessica Orr, Ellen 

Phelps Ranen, and Paul Wright.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102247)
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