On #PSLF: Public Statement to US #DoE on 30 hour rule

…guest post by Meg Feeley, originally posted to the adj-l listserv, Contingent Academics Mailing List, October 23, 2014

Please consider clicking through to the comments page for the U.S. Department of Education. Tell them you reject their '30 hour' rule for academics as outside the industry norm, and support a 'one class' rule: anyone who teaches one class (and is not employed full-time elsewhere) should be eligible for the Public Service Loan Forgiveness program. You may submit comments anonymously.

Spread the word! You have until Nov 4th to submit comments here (click the "comment now" button):

Here is the public comment I submitted which has not yet been published.

The language of Section 455(m)(3)(B)(ii) of the Higher Education Opportunity Act of 2008 (20 U.S.C. 1087e(m)(3)(B)(ii)) clearly indicates that the Secretary has broad  discretion to include borrowers in the Public Service Loan Forgiveness program. This language already specifies part-time faculty at community colleges in the definition of public service work. Senator Dick Durbin’s S.2712 (introduced) would include all part-time faculty in post-secondary education, so long as they are not employed full-time elsewhere. The Department of Education must make rules to facilitate this broad legislative intent or be held accountable through the provisions of the Administrative Procedures Act and/or litigation on behalf of otherwise-eligible faculty who are being excluded from participation in the Public Service Loan Forgiveness program. This “one course’ standard for post-secondary faculty as public service workers should be adopted now. 

All academic work is calculated on the basis of credit hours and semesters. Weekly workloads make no sense for academics. Faculty with one employer may teach 10 or 11 months a year and thus carry a ‘full-time’ 24-30 credit load which appears part-time when considered weekly over the 30-week academic year. Full-time teaching loads can vary from “2/1” (3 courses a year) for tenured faculty at Research 1 universities, to “5/5” (10 courses a year) at community colleges. Faculty may, over a ten year period, move from one campus to another – and have different employers even within the same University.  

Further, the words ‘part-time’ and ‘full-time’ are terms of art in the academic world. To certify someone with a title of adjunct lecturer or professor as ‘full-time’ would cross a number of boundaries (such as shared governance, for example, in which typically, only ‘full-timers’ may vote;, access to campus-wide email, copiers, and keys to department offices, etc). Although these distinctions are, of course, inequitable, they do exist and would prevent Human Resource personnel from erring on the side of accuracy when assessing the workload of a given employee. 

Recent changes in the ways in which academics work include remote teaching assignments; the practice of completing work assignments such as preparation and grading from home; the increasing use by universities of adjuncts and  “25 hour’ employees who work 5 hours per day 5 days per week (but are paid as “continuing education’ teachers); outsourcing of remedial coursework developed within colleges to community-based organizations;  the increasingly divergent pedagogies of differing disciplines, including class size, delivery method, lab hours, use of technology in classrooms, on-line and hybrid courses, MOOCs, field trips and travel; the practice of contact hours differing from credit hours; increasing responsibilities assumed by administrative staff, rather than faculty; reduced release time; additional paid hours for committee and service work at a ‘non-teaching’ rate which is not calculated as part of the weekly work of part-time or full-time faculty; scholarship by faculty which is unpaid, yet recognized through grants, travel awards, and promotions in rank; teaching separated from research; –all of these factors and others are, in practice, putting the goal of maximizing participation in this program at risk. 

Further, to whatever extent the legislative intent of the PSLF is to improve the talent available to public service employers, these complexities rob students and colleges of the benefits of the program. The Secretary should adopt rules reflecting this reality now.

Precarious Faculty welcomes the opportunity to publish public statements submitted to the DoE on this issue.