The bill amends the Higher Education Act (section 455(m)(3), 20 U.S.C. 1087e(m)(3)) to treat certain volunteer firefighters and volunteer emergency medical technicians as performing public service for purposes of the Public Service Loan Forgiveness (PSLF) Program. It adds statutory definitions for “qualified volunteer firefighter” and “qualified volunteer emergency medical technician,” and directs the Secretary of Education to establish a minimum volunteer-time threshold and verification procedures.
This change would make people who provide qualifying unpaid emergency-response work eligible for federal student-loan forgiveness under PSLF, subject to the program’s other requirements. That raises recruitment and retention implications for volunteer-dependent fire and EMS units, while imposing new administrative and recordkeeping responsibilities on the Education Department, loan servicers, and local public-safety organizations.
At a Glance
What It Does
The bill inserts volunteer firefighting and volunteer EMS service into the PSLF statute by adding a new clause to section 455(m)(3) of the Higher Education Act and detailed statutory definitions. It authorizes the Secretary of Education to set the minimum volunteer hours that will count as “full-time” public service for PSLF and to create rules for tracking and verifying that time.
Who It Affects
Directly affected parties include volunteer firefighters and volunteer EMTs who otherwise meet PSLF payment requirements; state, local, and tribal public-safety organizations that must verify service; the Department of Education and loan servicers responsible for implementing eligibility determinations; and communities that rely on volunteer emergency responders.
Why It Matters
This is a substantive expansion of PSLF’s covered workforce to include unpaid emergency responders, potentially increasing forgiveness claims and changing how the department and local organizations document qualifying service. It also sets a federal standard that will interact with diverse state and local volunteer definitions and practices.
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What This Bill Actually Does
The bill changes the Public Service Loan Forgiveness statute by adding volunteer emergency responders to the list of qualifying public-service jobs. Rather than relying on existing employer-based eligibility only, the statutory text creates explicit categories — “qualified volunteer firefighter” and “qualified volunteer emergency medical technician” — each described by a short list of conditions to be met before the service can count toward PSLF.
A qualified volunteer firefighter must provide firefighting, fire prevention, emergency medical, or related emergency-response services for a legally recognized fire department or public safety organization and must not be employed full time by that same organization. A qualified volunteer EMT must hold the appropriate training, certification, license, or legal authorization under state or local law, perform pre-hospital or ambulance services on behalf of an ambulance service, fire department, healthcare facility, or public safety organization, and likewise must not be employed full time by that organization.
These definitions are functional: they tie eligibility to the nature of the work, the legal recognition of the organization, and the volunteer (non–full-time-employee) relationship.The Secretary of Education gets two concrete tasks. First, the Secretary must determine the minimum amount of volunteer time that will be treated as the equivalent of full-time employment for the purposes of PSLF.
Second, that minimum cannot be lower than whatever volunteer time the relevant organization itself requires for an individual to be considered an “active member.” The bill also requires the Secretary to write regulations — after consulting firefighter and emergency-responder groups and other public-safety organizations — establishing the minimum-hours rules and a process for tracking and verifying volunteer time.Practically, the law would leave several operational questions to regulation. The Department will need to design forms or electronic mechanisms for organizations to certify hours, decide whether volunteers can self-certify in the interim, set standards for acceptable documentation, and coordinate with loan servicers to align payment-counting and employer-certification procedures.
Because the statute ties the minimum volunteer time to each organization’s active-member standard, implementation will require the Department to map a chaotic patchwork of state and local volunteer norms into a federal eligibility framework, and to decide whether and how to audit or reconcile conflicting records.
The Five Things You Need to Know
The bill amends section 455(m)(3) of the Higher Education Act (20 U.S.C. 1087e(m)(3)) to add volunteer firefighting and volunteer EMS work as qualifying public service for PSLF.
A “qualified volunteer firefighter” must provide firefighting or related emergency response through a legally recognized fire department or public-safety organization and not be employed full time by that same organization.
A “qualified volunteer emergency medical technician” must be trained, certified, licensed, or legally authorized under state or local law, perform pre-hospital or ambulance services for a qualifying organization, and not be employed full time by that organization.
The Secretary of Education must set a minimum volunteer-time threshold that will count as the statutory equivalent of full-time employment and ensure that threshold is no lower than the organization’s own active-member requirement.
The bill requires the Secretary to promulgate regulations after consulting public-safety organizations and to adopt processes for tracking and verifying volunteer service hours.
Section-by-Section Breakdown
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Short title: HEROES Act
A single sentence gives the Act its short name, the “Helping Emergency Responders Overcome Student Debt Act” or “HEROES Act.” This is strictly a caption provision with no operational effect, but the short title will be how stakeholders refer to the measure in guidance and outreach.
Adds volunteer responders to the list of qualifying public-service jobs
This subsection inserts a new clause (iii) into subparagraph (B) to make volunteer firefighting and volunteer EMT service an express category of qualifying public service for PSLF. Mechanically, that means qualifying volunteer service will be considered a type of employment for purposes of counting toward PSLF’s employment requirement, subject to the program’s existing rules about qualifying loans, qualifying payments, and total time served.
Defines ‘qualified volunteer’ roles and Secretary’s duties
The bill adds detailed statutory definitions for both “qualified volunteer firefighter” and “qualified volunteer emergency medical technician,” each with three elements (nature of services, organizational relationship, and non–full-time employment by that same organization). It also directs the Secretary to determine a minimum volunteer-time threshold that will count as full‑time for PSLF purposes and to ensure that threshold is not below the volunteering organization’s own active-member requirement. These definitions shape eligibility and create a legal hook for later regulation.
Defines ‘public safety organization’
The bill adds a short definition of “public safety organization” to include state, local, and tribal governmental agencies or nonprofit organizations whose principal purpose is protecting life, health, or property. That catch-all definition signals coverage beyond municipal fire departments to certain nonprofits and tribal entities, which raises questions about which nonprofit structures qualify and how the Department will verify an organization’s status.
Regulatory authority: consultation, minimum time, and verification
Section 3 instructs the Secretary to promulgate implementing regulations after consulting public-safety organizations, specifically calling out firefighter and emergency-responder groups. The regulations must address the minimum volunteer time that will count as full-time and the processes for tracking and verifying volunteer hours. That gives the Department broad discretion on verification standards and enforcement mechanisms, subject to the statutory floor tying minimum hours to organizations’ active-member requirements.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Volunteer firefighters and volunteer EMTs who meet the bill’s definitions: They gain a new pathway to have time spent performing unpaid emergency response counted as qualifying public service toward PSLF, potentially shortening their path to loan forgiveness if they also meet the program’s payment requirements.
- Student-loan borrowers who split paid employment and volunteer emergency service: Borrowers who do paid qualifying public service elsewhere or make qualifying payments can now stack volunteer emergency-response service to secure PSLF eligibility where they previously could not.
- Rural, tribal, and small-town public-safety organizations: Expanding federal loan-forgiveness eligibility to volunteers strengthens a recruitment and retention tool for agencies that depend heavily on unpaid responders.
- Communities reliant on volunteer EMS and fire services: If the measure helps stabilize volunteer ranks, communities with thin budgets or distant paid services could see public-safety resilience benefits.
Who Bears the Cost
- U.S. Department of Education: The Department must write rules, design verification systems, update servicer processes, and adjudicate new eligibility claims — all requiring staff time and budget.
- Local fire departments, ambulance services, and public-safety nonprofits: These organizations will need to document volunteer hours, respond to verification requests, and possibly change internal recordkeeping, which creates administrative burdens for often under-resourced entities.
- Loan servicers and PSLF administrators: Servicers must incorporate a new category of qualifying service into existing employer-certification and payment-counting processes and handle appeals or disputes tied to volunteer status.
- Taxpayers / federal budget: If significant numbers of volunteers claim PSLF, the federal cost of loan forgiveness could rise. That cost is not detailed in the bill and would depend on participation levels and timing.
Key Issues
The Core Tension
The bill balances two legitimate goals — expanding relief to unpaid emergency responders to support community safety, and protecting the integrity and budgetary sustainability of PSLF — but it gives the Department of Education the hard job of translating a diverse, locally governed volunteer ecosystem into a standardized federal eligibility regime; making that translation will require trade-offs between accessibility and verifiability.
The bill leaves several important operational choices to the Department of Education, which creates implementation risk. Tying the minimum volunteer-time threshold to each organization’s “active member” requirement imports local variation into a federal program: some volunteer units consider minimal engagement sufficient for active membership, while others demand substantial time.
Unless the Department standardizes how those local requirements are evaluated, identical volunteer activity could count in one jurisdiction and not in another, producing inequitable outcomes and administrative disputes.
Verification poses a second, practical challenge. The statute requires the Secretary to adopt a process for tracking and verifying volunteer time but does not specify who bears primary responsibility for recordkeeping or what documentary standard will suffice.
Requiring detailed timesheets and employer certifications would protect program integrity but could overwhelm small volunteer organizations; allowing self-certification would ease burdens but increase fraud risk. The law is also silent on retroactivity, the interaction between volunteer service and the PSLF program’s 120 qualifying payments rule, and how partial-year or seasonal volunteering will be pro-rated, leaving open contested regulatory choices that could materially affect who benefits.
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