The "sweeping changes" that were proposed yesterday to expand student loan cancellation for defrauded students, disabled students and public service employees fall woefully short of creating meaningful pathways to debt cancellation and further underscore the unwillingness of this administration to address the scope of the 1.8T student debt crisis in a way that comprehensively addresses this problem and how we got here as a nation. We as a nation call on Secretary of Education Miguel Cardona and Under secretary of Education James Kvaal to implement the following changes to the negotiated rulemaking proposal that if adapted, will provide a more equitable and transparent path to debt cancellation for the aforementioned groups of borrowers:

1) Reduce the number of qualifying payments to receive public service loan forgiveness from 120 to 60 payments. Given the discrepancy of public sector vs private sector salaries, halving the years from 10 to 5 years of dedicated public service will allow for greater recruitment into fields that experience chronic shortages such as, but not limited to, teachers, librarians and social workers. Further, the skyrocketing cost of housing renders it virtually impossible for public service workers to enter the housing market and keeps them stuck in a state of perpetual renting further disenfranchising them from building wealth over the span of their careers in the public sector.

2) Public service student loan suspension: A truly meaningful addition to the PSLF process would be to suspend all student loan payments at zero interest for the entire duration of one's tenure in public service. The regressive nature of both low pay and crippling student loan debt prevents public sector workers from homeownership, saving for retirement and even having children. There is no justifiable reason why public sector workers should pay on student loan debt while they are contributing daily to the advancement of public welfare.

3) Setting all interest at zero for the aforementioned existing programs designed to provide loan cancellation. There are two tiers of education in the United States-one for the wealthy who can afford to pay out of pocket and one for those who are forced to borrow. The latter winds up paying exponentially more over time for the same education due to interest capitalization resulting in creating negative generational wealth. The government should not be making money off students' education. 

4) Applying all previous interest payments to go to the principle loan amount so that borrowers are not stuck owing far more than they had originally borrowed.

5) Restore bankruptcy and consumer protection provisions to student loan debt. The removal of bankruptcy protections in 2005 led directly to runaway tuition and student debt burdens creating the 1.8T crisis that we see today.