Are clergy and teachers of religious faith/thought public servants? Is their work on par with that of others who work for 501c3 non-for-profit groups and for government agencies? It used to be, but as of January 31st, the federal government has changed its mind about that.
Although not known to most people, the federal government maintains a program called Public Service Loan Forgiveness. According to that program, after ten years of public service work, any remaining federal student loans remaining for that worker would be forgiven. But what counts as public service?
Until the end of January, the government definition was clear and inclusive. It read as follows:
“Qualifying employment is any employment with a federal, state, or local government agency, entity, or organization or a non-profit organization that has been designated as tax-exempt by the Internal Revenue Service (IRS) under Section 501(c)(3) of the Internal Revenue Code (IRC). The type or nature of employment with the organization does not matter for PSLF purposes. Additionally, the type of services that these public service organizations provide does not matter for PSLF purposes.”
Now though, the rules have changed. At the end of the description of who qualifies for this program, a new paragraph appears and it’s striking not only in that it re-defines things, but that it does so in a way that seems purposefully disingenuous.
“Generally, the type or nature of employment with the organization does not matter for PSLF purposes. However, if you work for a non-profit organization, your employment will not qualify for PSLF if your job duties are related to religious instruction, worship services, or any form of proselytizing.”
So after telling us that pretty much everything qualifies, even going out of its way to highlight that neither the type of work nor nature of the organizations matters, the government slips in the fact that if faith or worship are part of your work, you don’t qualify. What?!
Is faith really so threatening that it merits this singular exception? Well, perhaps it does. The careful separation of church and state is not simply a nice idea. It is a crucial part of our democracy, and a commitment based on the historic abuse of church-state entanglement. But as framed, this policy puts all of the weight of that question on those who can least afford to shoulder the burden – students carrying loans.
If the government wants to re-visit making loans to those who study for religious careers, fine. I would oppose any change there, but I get it. Likewise, if the government wanted to revisit the tax-exempt status of religious institutions, I would get that as well. I would also oppose that, but I would understand it. But taking this out on those who can least afford it is simply wrong.
It would also be reasonable for the government to revisit the entire loan forgiveness program for all professions — that I actually could imagine supporting. After all, why is public service more valuable that service through the private sector?
The argument that public service work pays less, is not necessarily the case, especially in today’s economy. The argument that public sector and government employees somehow contribute more to the overall social good is equally wrong. In fact, when either sector suffers, all sectors suffer, so in light of that interdependence, the program makes limited sense, however well-intentioned it may be.
Perhaps the forgiveness program should be based on overall earnings, as opposed to public-/private or for-profit /not-for- profit distinctions. But as long as those are the distinctions being made, excluding those who work in the religious sector is misguided and counter-productive.
Especially given the otherwise broad definition of public service according to this law, clergy and religious teachers should be considered public servants. On balance, there is no doubt about the public value of faith in America.
While religion can be abused in the most horrendous ways, it remains a source of enormous social good and unprecedented public service. The new regulation seems to uphold only one of those truths, and in doing so, is actually taking a position on faith (dare is say, “establishing” one?) – a hostile one.
While church-separation is a wise and necessary policy, separation is not about discrimination against, or hostility towards, religion. The regulation, as newly reformulated is clumsy at best, insensitive for certain, and may even be illegally hostile to religion. This one needs to change.