UUA Opposes Rule Change to Public Service Loan Forgiveness Program Regulation Amendments Would Threaten Religious Freedom

The UUA will zealously protect our rights and those of our churches and faith communities.

The Unitarian Universalist Association (UUA) has submitted public comment to the U.S. Department of Education (USDOE) opposing their proposed amendment s to the regulations governing the Public Service Loan Forgiveness (PSLF) program. The PSLF program offers student loan forgiveness for individuals who are employed by government agencies and not-for-profit organizations when qualified.

The amendments would authorize the USDOE to exclude a not-for-profit employer from the PSLF program if the USDOE unilaterally determined that the organization is engaged in a ”substantially illegal purpose”, which may be broadly interpreted by the USDOE to include activities that are not illegal but are merely not favored by the current Administration, potentially including advocacy and social justice work for immigrants or providing gender affirming care to minors. According to the National Council of Nonprofits, the rule change would “unlawfully limit which charitable nonprofits qualify as eligible employers.”

The UUA is opposing these changes due to First Amendment concerns regarding the free exercise of our religious faith:

The proposed amendment clearly uses an ideological, politicized framework to drive the government’s agenda which conflicts with our Constitutional rights. This amendment would undermine the fundamental protections that the UUA and its member congregations hold as a faith community, under the First Amendment and the Religious Freedom Restoration Act, for our free exercise of religion. USDOE has no authority to insert itself into our ecclesiastical decisions of our duly chosen religious leaders or our theological interpretation of our own religious tradition. The UUA will zealously protect our rights and those of our churches and faith communities.

“Unitarian Universalists have a deep, historic tradition of defending civil liberties and championing human rights, justice and equity for all,” said Rev. Dr. Sofía Betancourt, the UUA’s President in the comment letter. “We object to any characterization [by USDOE] of our ministries, which uphold values of love, justice and generosity. Our congregations welcome all people based on these shared religious values, and we are compelled by our faith to work towards a freer and more equitable world.”

Text of UUA Public Comment

Rev. Sofía Betancourt, Ph.D. 
Boston, MA
Unitarian Universalist Association, President
president@uua.org

Re: William D. Ford Federal Direct Loan (Direct Loan) Program Notice of Proposed Rulemaking [Docket ID ED-2025-OPE-0016]; Attn: Tamy Abernathy

Dear Ms. Abernathy,

Thank you for the opportunity to provide comments on the proposed rule to amend the regulations on the Public Service Loan Forgiveness (PSLF) program under 34 CFR 685.219.

My name is Rev. Sofía Betancourt, and I serve as President to the Unitarian Universalist Association. On behalf of the Unitarian Universalist Association (UUA), I submit the following comment in opposition to the proposed amendment to the regulations on the PSLF program of the US Department of Education (USDOE). The UUA is the central religious organization of the Unitarian Universalist liberal religious tradition in the United States. We are recognized by the IRS as a 501(c)3 organization. Our 1000+ member congregations and communities, located across all 50 states and the District of Columbia, covenant to embrace shared religious values and practices. Many of our congregations have been worshipping since before the American Revolution, dating to the founding of this country. Unitarian Universalists have a deep, historic tradition of defending civil liberties and championing human rights, justice and equity for all. Our forebearer Unitarians and Universalists like Horace Greeley were some of the earliest advocates for public funding of education in the United States, as well.

The UUA unequivocally opposes the proposed amendments. They would seek to strip benefits from staff who work with organizations with whom the USDOE disagrees or dislikes, under the guise of a “substantial illegal purpose” with effectively no due process. These amendments are an improper attempt by the USDOE to coerce the actions of independent 501(c)3 organizations and give the Secretary unfettered authority to inappropriately adjudicate the activities of nonprofits.

The proposed amendments could affect not only the staff of the UUA, but also the eligibility of the thousands of religious professionals who work for our congregations and related UU organizations. Many of these staff have participated in the PSLF in the past, as they are entitled to do. It is a key program that makes religious leadership financially viable for many, who often took out loans to prepare for religious training with a fair expectation of loan forgiveness in exchange for public service. The politicization of the PSLF program, to potentially target a religious organization that the USDOE had unilaterally determined is no longer eligible, both violates the religious organization’s freedoms and could be financially catastrophic for countless religious employees.

Additionally, these amendments are in violation of the statute authorizing the PSLFs, which entitles staff who work at any 501(c)3 nonprofit organization recognized by the IRS to qualify for this benefit. The responsibility to ensure nonprofit organizations comply with the law, for the purpose of receiving Federal recognition and eligibility for programs including PSLF, in fact rests with the Internal Revenue Service. The IRS already has the authority to investigate illegal activity and revoke nonprofit status through a defined process with safeguards. The proposed amendments would run afoul of the court precedent and IRS requirements for recognition of churches. This would be contrary to IRS policy, which seeks to limit the administrative burden it imposes on churches as typically small and volunteer-heavy organizations, affirming these religious communities’ Constitutionally protected role in American civic life.

Most damagingly, the proposed amendment clearly uses an ideological, politicized framework to drive the government’s agenda which conflicts with our Constitutional rights. This amendment would undermine the fundamental protections that the UUA and its member congregations hold as a faith community, under the First Amendment and the Religious Freedom Restoration Act, for our free exercise of religion. USDOE has no authority to insert itself into our ecclesiastical decisions of our duly chosen religious leaders or our theological interpretation of our own religious tradition. The UUA will zealously protect our rights and those of our churches and faith communities.

We object to any characterization of our ministries, which uphold values of love, justice and generosity. Our congregations welcome all people based on these shared religious values, and we are compelled by our faith to work towards a freer and more equitable world.

In closing, we reiterate our opposition to this proposed amendment in the strongest possible terms.

Respectfully,

Rev. Sofía Betancourt, Ph.D. 
UUA President

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