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Frequently Asked Questions (FAQs) and Clarifications
Application
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Can a participant be added to the group of FY24 participants (Cohort 1) now? In not, will the districts get a chance to apply again at some later time with new participants?
Cohort 1, or participants from Fiscal Year (FY) 24, has now “closed” on GEMS/MARS, meaning that no changes can be made to the lists of eligible participants that the districts submitted with their original applications. An FY25 application is currently in development and will exist on an online portal that is currently being designed by a third party. All individuals who wish to be an FY25 participant will have the ability to apply for the Student Loan Repayment Program. Please check the main page of the Student Loan Repayment Program for updates and links.
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Does the district apply on behalf of the educator to be included, or can individuals apply on their own?
For FY25, the online portal will allow individuals to apply, uploading loan documentation for verification of eligibility. Districts will supply employment details necessary to complete the eligibility confirmation. More information on application instructions will be made available to the public by the third party responsible for the development of the online portal and on the main page of the Student Loan Repayment Program.
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Is there a limit to the number of educators who can access the new online portal?
No. As a reminder, only individuals who meet the eligibility criteria for this program will be granted payments, and an incomplete or inaccurate application will not be processed for payment.
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Would it be acceptable to ask my local educator association for assistance in completing my FY25 application?
Yes, it is allowed under statute (MCL 388.1627k). One caveat is to remember that the Student Loan Repayment Program is available to any school employee who works closely with pre-K to grade 12 students for 50% or more of their working time (per examples listed in MCL 388.1627k) and that not all of these types of educators are represented by associations, and not in all districts.
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Will you provide a list of eligible PSLF loan types?
Yes, this is currently listed on the Federal Public Service Loan Forgiveness webpage and our Student Loan Repayment Program webpage, under “Information for Applicants.”
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How can I get updates about the Student Loan Repayment Program?
Besides making regular updates to the Student Loan Repayment Program webpage, we will also feature developments about the Student Loan Repayment Program through our Educationally Speaking newsletter. If you have not already signed up, you can use the MDE newsletter sign-up link. Be sure to select the “Educationally Speaking” newsletter under the listings for the “Educator Excellence” when prompted to select from a list of options. In addition, please follow the MDE’s Office of Educator Excellence on Facebook.
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I have applied for the Income Driven Repayment Plan some weeks ago but has not been approved. If I receive approval prior to applying for the grant, would I qualify?
The requirements governing participant participation set forth in MCL 388.1627k must be true at the time of application. So, if you are approved at the time you make the application on the portal, and this is an eligible payment plan listed on our Student Loan Repayment Program site, then you would be considered approved.
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If I am in the federal student loan forgiveness program, but do not currently have a payment due (or have a $0 payment), do I still qualify for this program? Should I make an FY25 application if I think my payment may increase later?
Yes, because a current $0 payment does not ensure that it will not increase at some later point. As long as the district verifies that your submitted documentation about your current loans fall within an eligible loan type and are enrolled in the federal Public Service Loan Forgiveness Program (see www.studentaid.gov/pslf), then you can be included in anticipation that your monthly loan payment may be greater that $0 at a later date. The portal will accept a loan payment amount of zero.
Please note that a loan payment of $0 would result in the staff member receiving $0 under this program, because the amount of the payment to the participant cannot exceed their current payment. If and when the payment increases, the participant is responsible for communicating this with their district, following any verification procedures the district has in place. The district would then be responsible for reporting this in the portal.
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Will receiving money through this Student Loan Repayment Program impact my ability to receive student loans in the future?
No. MCL 388.1627k states that eligible district staff members will remain eligible for other student loans when receiving funds under this program.
Eligibility
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Who qualifies for the Student Loan Repayment Program?
Eligibility of participants is determined using the following criteria:
- participating in a federal student loan forgiveness program as described in subsection (3) of MCL 388.1627k, also found on the Student Loan Repayment Program webpage;
- meeting federal loan and payment plan requirements as described in subsection (3) of MCL 388.1627k;
- working 32 hours or more per week at a district or intermediate district; and
- at least 50% of that working time is spend in direct contact with those students.
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Are there examples of definitions of “working directly with pre-K to grade 12 students?”
Yes, there are examples listed in MCL 388.1627k, and on the Student Loan Repayment Program webpage. It depends on whether the district categorizes that employee’s position or work assignment as having at least 50% spent in direct contact with pre-K to grade 12 students. All applicants for FY25 will be referred to their own employers for those definitions.
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I’m an employee of a Michigan public school and I have at least 50% spent in direct contact with preK-12 learners, but I’m not allowed to enroll in one of the federal forgiveness plans listed on the website, since my school is not identified as an eligible employer for Public Service Loan Forgiveness. How do I participate?
Unfortunately, you cannot. A clear requirement of the program is that the participant is currently enrolled in one of the federal loan forgiveness programs listed on the Student Loan Repayment Program webpage, and educators who are not able to join these loan forgiveness programs are simply not eligible to be participants.
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Is a participant hired from a third-party company like EduStaff eligible for the program, if they work directly with students?
According to the wording provided by MCL 388.1627k, the law does not restrict individuals from participating as a contracted employee if they meet the other requirements listed in Section (3)(a). However, a clear requirement in this section is enrollment in the PSLF program. While we cannot provide guidance on qualifying employment for PSLF, we recommend that individuals review the Federal Student Aid Public Service Loan Forgiveness website for information about eligibility for the program. Note that if the individual is not working directly for a qualifying employer to be eligible for PSLF, they cannot receive funds through this section.
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Would educators working with students aged 18-26, or ages 0-3, be eligible?
Per section 27k, the statute does not specify the age of the students. The statute requires that, for a teacher to be eligible, they must have at least 50% spent in direct contact with students in a PreK-12 program. This includes Early On programs.
For students between the ages of 18-26, if the district records these students as 12th grade students, following special education and pupil accounting policies, then educators working directly with these students would meet the description found in paragraph (8)(b) in MCL 388.1627k. Residential- and institution-based programs do not qualify.
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Who makes the final determination on whether an educator is eligible or not (based on the listed requirements)?
Ultimately, the responsibility of verifying all employment data submitted for the application rests on the district. Since this is a program funded from a budget allocation appearing in state law (MCL 388.1627k), it is subject to the same rules for monitoring and auditing like any other official work project that provides funds to schools. Subdivisions (3)(a) through (3)(f) are the best and most authoritative guides for participant criteria.
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I’m a school employee who works an hourly rate, and I work at least 32 hours during the school year with 50% or more of their time in direct contact with students. However, from June through August I do not work. Would I still be eligible?
There is no expectation within the 32-hour minimum per week requirement that it include summer vacation or summer school programming, unless the district is year-round or balanced calendar in nature. For those districts that are not on these calendars, those school staff members should only use the regular school year as a gauge in determining the 32 hour per week minimum.
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I meet all of the requirements and I am currently working full-time, with over 50% of my time in direct contact with students. However, later this school year, I will be reduced to part-time work in order to pursue another degree. Should I not apply?
At the time of application, if that staff member is working 32 hours or more, this would conform to the eligibility component mentioned in MCL 388.1627k.
However, note that elsewhere in the law, it is the responsibility of the district to ensure that all participants conform to the employment-related eligibility requirements, including that “an eligible participant must only receive funding through the program if the eligible participant continues to meet the criteria of an eligible participant.” In other words, once this participant is no longer working 32 hours a week or more, the participant is no longer eligible for the Student Loan Repayment Program. See the FAQ above that mentions educators who stop working at least 32 hours a week.
Finally, note that this also means that participants will drop from eligibility if their work assignments change so that less than 50% of their working time is spent in direct contact with students. (See FAQ below.)
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What if a participant in the Student Loan Repayment Program leaves employment in the district, or their work hours are reduced to less than 32 hours per week, or if their assignments change so that they are working less than 50% of their time in direct contact with students?
If the employment status of a program participant changes in such a way that the participant is no longer working at least 32 hours per week at their district, then the Student Loan Repayment Program monthly payments that are made to the educator must immediately stop.
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What happens if I am receiving payments from the Student Loan Repayment Program, but I have a leave of absence that I have to take?
Most leaves of absence would have no impact on an applicant’s student loan repayment program. However, an interruption of employment would impact eligibility. To determine if an applicant is on a type of leave that is not considered an interruption to employment, please work with your HR department. A policy should be in place to determine if there is an interruption to employment versus an eligible leave of absence.
Financial Procedures for Districts
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What if we made a payment for FY25 to a participant from FY24 funds after 9/30/24, since we had money left over from FY24?
First, please make no additional payments to these participants from FY24 funding sources for months after September 2024. Then send an e-mail to MDE-EdWorkforceGrants@michigan.gov, simply stating that FY25 payments were made to participants utilizing FY24 funds. You do not need to include any names or amounts in your message. MDE is currently developing a reconciliation report for Cohort 1 and will include a way for you to report this information for accurate processing of Student Loan Repayment Program grant funds for Cohort 2 (FY25).
VERY IMPORTANT: If your district made a payment to an FY24 participant dated after 9/30/24 but it was for a September loan payment, this would be allowable and necessary under the FY24 Grant Award Notification (GAN). Similarly, back payments owed from months between October 2023 and September 2024 can be paid from FY24 funds provided in Grant Award Notifications (GANs) that were sent to the district at a time later than 9/30/24; see below.
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We just received our Amendment 2 Grant Award Notification (GAN) in early November to adjust the numbers of payments participants were entitled to since 10/1/23. However, the GAN still says that the end date is 9/30/24. Is it too late to provide these payments to participants?
No, and in fact this is exactly the purpose of the Amendment 2 GANs. The dates on your GAN reflect the FY24 allocations for funds for this program. Even though it is now past September 30, 2024, you are authorized to recognize this revenue for the purposes of paying correct back payments to your eligible participants, since adjustments were necessary arising from the incorrect spreadsheet template used in your original application submission in April. Please record this revenue under Major Class 312, Suffix 0000, and expenditures spread across the Functions of employees receiving the reimbursement, Object 2390, and Grant Code 273 data review, award approval, and GAN production processes, all of which could not be shortened.
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Is an indirect cost available on this grant to cover the expenses of administration?
Unfortunately, no, due to the restrictions in MCL 388.1627k. It is expected that districts would include a payment method to the participant that works on existing payroll procedures, or which does not significantly impact the workload of financial office staff. In addition, the online portal is an example of a system that has been created to lessen the workload burden on districts.
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Are payments made under the Student Loan Repayment Program considered taxable income?
While the MDE cannot provide tax-related advice, it recommends that school districts stay in touch with qualified professionals to get the final word on tax implications arising from grant reimbursements. This includes understanding how publicly available sources such as IRS Publication 970 relate to their local fiscal policies.
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What if my district is designated as a band 6 district or intermediate district in the opportunity index, as described in section 31a, during the time I completed the application, but its status changed the following year?
After award amounts are determined and distributed based on the criteria listed in the grant application, the award amount will remain the same for the duration of the program. This calculation can change from year to year, and more information is available from the Office of State Aid and School Finance.
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Whose responsibility is it to verify the accuracy of employment of the participant? What would the district do if they find the participant is not an employee?
Each district should verify the employment of the participant. If the district finds that the participant is not an employee, they should report that using the online portal.
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Who is responsible for reporting and reconciliation?
Each district that has an eligible participant in the student loan report program shall report distributions to the Michigan Department of Education (MDE) annually. That report and or reconciliation shall include but is not limited to the amount disbursed to eligible participants.
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Who is responsible for the accuracy of the submitted data?
Ultimately, the participant is responsible for submitting accurate, appropriate, and factual data utilizing the online portal. If it is found that inaccurate data was provided the participant will be denied during the application process.
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Will these payments be reportable to the Office of Retirement Services (ORS) and count towards their Final Average Compensation (FAC)?
No. These payments are considered reimbursements for student loan debt and are not reported to ORS. Accordingly, they are not eligible to be included in an FAC, and the employer should not report it on DTL2 Wage and Service or DTL4 Defined Contributions records. Please contact ORS with questions.
Please see ORS Public School Reporting Units for more information. Reportability of additional educational funding.
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What will happen to the eligible participants monthly payments if the full allocation is exceeded?
The total amount of allocation for this program, provided by MCL 388.1627k. If at any time the total amounts of payments exhaust this limit, payments to approved participants will be pro-rated equally.
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What happens if a participant is granted total loan forgiveness at some point when the district is providing payments?
In this case, the participant would report this on the online portal, and it would notify both the district and MDE to cease payments starting with the month after the payoff.
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Are Parent Plus loans eligible?
We’re sorry to say that they are not—if they are the traditional Parent Plus loans and are not otherwise consolidated into the Direct Consolidation Loans (which do qualify, according to the Student Loan Repayment Program website, under “Information for Applicants”). This is because unconsolidated Parent Plus loans represent the assistance that was given to another member of the household and are thus not eligible for federal loan forgiveness programs. Accordingly, they would not fit under the requirements of this program.
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Do payments only go back to October 2024 for those participants who have been employed with that specific district back through October 2024?
Participation in the Student Loan Repayment Program supersedes a participant’s employment date range. As long as the participant met the requirements. Thus, the participant should report back payments extending back to October 1, 2024, but should omit payments for months where the participant was not meeting one or more of the eligibility requirements.