Canada Gazette, Part I, Volume 159, Number 7: Regulations Amending the Canada Student Loans Regulations and the Canada Student Financial Assistance Regulations

February 15, 2025

Statutory authorities
Canada Student Loans Act
Canada Student Financial Assistance Act

Sponsoring department
Department of Employment and Social Development

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

General Comment

Executive summary

Issues

Canada is facing a long-standing and persistent crisis related to shortages of essential workers, especially in health care. To address this issue, the Canada Student Loan forgiveness benefit (the loan forgiveness benefit) was put in place by the Government of Canada in 2013. The goal of this benefit is to incentivize family physicians, including family medicine residents, nurses, and nurse practitioners to work in eligible under-served rural or remote communities by forgiving part of their federal student loans. While the loan forgiveness benefit has helped many of these communities across Canada with the recruitment and retention of these essential workers, it does not address the lack of access to other important health care and social service professionals in these communities.

Background

Canada Student Financial Assistance Program

The Canada Student Financial Assistance Program (the Program) provides eligible students with Canada Student Grants (grants), as well as Canada Student Loans (loans), to help them pay for post-secondary education at a designated college, university, or other post-secondary institutions. Grants provide non-repayable funding to full- and part-time students from low- and middle-income families, to students with disabilities, and to those with dependants. Loans are available to eligible students who still have a financial need after being allocated grants and who are enrolled in a degree, diploma, or certificate program at a designated post-secondary institution in Canada or abroad. Since April 1, 2021, loans no longer accrue interest, though borrowers remain liable to pay any interest that may have accrued prior to the elimination of interest accrual.

Grants and loans are available to students from nine participating provinces and one territory: British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, New Brunswick, Nova Scotia, Newfoundland and Labrador, Prince Edward Island, and the Yukon. In these jurisdictions, students receive both federal and provincial/territorial (PT) student aid. Meanwhile, Quebec, Nunavut and the Northwest Territories have opted out of the Program and receive alternative payments from the Government of Canada to administer their own student financial assistance programs.

The Government of Canada currently offers loan forgiveness to family physicians, nurses, and nurse practitioners who work in an under-served rural or remote community. This measure was implemented in 2013 as a way to complement existing federal and PT efforts to address the complex issue of health care worker shortages in rural or remote communities.

The eligibility conditions for the loan forgiveness benefit are prescribed under section 29 of the Canada Student Financial Assistance Regulations ^{footnote 1} and section 19 of the Canada Student Loans Regulations. ^{footnote 2} To receive the loan forgiveness benefit, a borrower must have worked in an “under-served rural or remote community” as a family physician or nurse during the previous year and must have applied for the loan forgiveness benefit no later than 90 days after the end of that year. From April 1, 2013, to November 2, 2023, loan forgiveness for eligible family physicians could reach $8,000 per year, up to a maximum of $40,000 over five years. In addition, loan forgiveness for nurses and nurse practitioners could reach $4,000 per year, up to a maximum of $20,000 over five years.

Over the last few years, the Government of Canada has made commitments to enhance the loan forgiveness benefit. These enhancements were intended to address the shortage of family physicians and nurses in rural and remote communities by bringing more health care workers to communities that needed them most. Firstly, as announced in Budget 2022 and implemented on November 3, 2023, the Government increased the maximum amount of loan forgiveness by 50%. This means that over five years, loan forgiveness for family physicians working in under-served rural or remote communities can reach $60,000, and for nurses, $30,000. Secondly, as announced in Budget 2023, the Government committed to expanding the reach of the loan forgiveness benefit starting in 2024–2025, to include all communities with a population of no more than 30 000. This change came into effect on November 6, 2024. Thirdly, as announced in Budget 2024, the Government committed to expanding the loan forgiveness benefit to 10 new occupations in health care and social services.

Objective

The objective of this regulatory proposal is to expand eligibility for the loan forgiveness benefit to 10 additional health care and social service occupations in under-served rural or remote communities. This is expected to incentivize workers in specified health care and social service occupations to relocate to and work in these communities, which, in turn, is expected to result in better access to health care and social services for residents.

Description

The proposed regulatory amendments would expand the current list of occupations (family physicians, nurses, and nurse practitioners) eligible for the loan forgiveness benefit to the following 10 additional occupations: early childhood educators, dentists, dental hygienists, pharmacists, midwives, teachers, social workers, personal support workers, physiotherapists, and psychologists.

The current benefit scheme includes two groups based on loan forgiveness amounts (group 1 for family physicians and group 2 for nurses). The proposed regulatory amendments would add new professions to the existing groups and create a third group to ensure that the appropriate amount of loan forgiveness is allotted to each new occupation and that it is aligned with the different education requirements, costs, and expected student debt. The three different groups of loan forgiveness would be based on the most common post-secondary educational requirements for each occupation.

The first group would include borrowers working as a family physician, dentist, psychologist, or pharmacist who would have completed either a four-year professional degree after obtaining an undergraduate degree or an advanced graduate degree. Borrowers in this group would have typically attended post-secondary education for seven years or longer and would be eligible for up to $60,000 in loan forgiveness over a five-year period. The second group would include borrowers working as a nurse practitioner, registered nurse, licensed practical nurse, midwife, teacher, social worker, or physiotherapist who would have typically completed four to six years of study at a university. Borrowers in this group would be eligible for up to $30,000 in loan forgiveness over a five-year period. The third group would include borrowers working as an early childhood educator, dental hygienist, or personal support worker who would have typically attended post-secondary education for three years or less. Borrowers in this group would be eligible for up to $15,000 in loan forgiveness over a five-year period.

The table below shows the various eligible occupations, the proposed groups, and the loan forgiveness amount for which each group would be eligible over a five-year period.

Table 1: Occupations by group and corresponding loan forgiveness amounts

	Group 1	Group 2	Group 3
Eligible occupations	Family physicians (including residents in family medicine), dentists, psychologists, pharmacists	Nurse (including nurse practitioners, registered nurses and registered/licenced practical nurses), midwives, teachers, social workers, physiotherapists	Early childhood educators, dental hygienists, personal support workers
Annual forgiveness amount	Year 1: $8,000 Year 2: $10,000 Year 3: $12,000 Year 4: $14,000 Year 5: $16,000	Year 1: $4,000 Year 2: $5,000 Year 3: $6,000 Year 4: $7,000 Year 5: $8,000	Year 1: $2,000 Year 2: $2,500 Year 3: $3,000 Year 4: $3,500 Year 5: $4,000
Maximum forgiveness over five years table a1 note a	$60,000	$30,000	$15,000
Table a1 note(s) Table a1 note a Total if a borrower works all five years in the same group. Totals will vary if a borrower changes occupations resulting in a change in groups over their five years of eligibility. Return to table a1 note a referrer

For the purposes of eligibility, this proposal would also define many of the newly added occupations in a manner that is consistent with how “family physician,” “nurse,” and “nurse practitioner” are currently defined in the Canada Student Financial Assistance Regulations and the Canada Student Loans Regulations.

Where provinces and territories define an occupation for the purpose of regulating its practice, the proposed regulations defer to those definitions. For example, the current definition of “nurse practitioner” in the Canada Student Financial Assistance Regulations includes those who are “entitled under the laws of a province to practise as a nurse practitioner and who is so practising.” However, not every newly eligible occupation is regulated and defined in every province and territory. Specifically, not every province and territory regulates and defines early childhood educators, social workers, physiotherapists, or psychologists. In these cases, the proposed regulations would require the applicant to meet a legal definition in another province or territory. Personal support workers, however, are not defined in any jurisdiction. To address this, the proposed regulations introduce a definition which includes the work undertaken by personal support workers in health care and home care settings.

Regulated occupations

All provinces and territories regulate dentists, dental hygienists, midwives, pharmacists, and teachers. For these occupations, an eligible applicant would be defined as a person who is entitled to practise in that occupation under the laws of the province or territory in which they are working.

Early childhood educators, physiotherapists, psychologists and social workers are regulated in most provinces and territories. An eligible applicant working in a province or territory where the occupation is regulated would be defined as a person who is entitled to practise in that occupation under the laws of the province or territory in which they are working.

Occupations that are unregulated in some provinces and territories

• Early childhood educator — this occupation is unregulated in New Brunswick, Nunavut and the Northwest Territories.
• Physiotherapist / physical therapist — this occupation is unregulated in the Northwest Territories and Nunavut.
• Psychologist — this occupation is unregulated in Yukon.
• Social worker — this occupation is unregulated in Yukon and Nunavut.

An eligible applicant working in one of the above occupations in a province or territory where the occupation is unregulated would be defined as a person who meets the definition of the occupation in the laws of any province or territory.

Unregulated occupations in all provinces and territories

Currently, no province or territory regulates personal support workers. Therefore, the proposed regulations include a definition for this occupation. An eligible applicant in this occupation would need to meet the following definition: a person who, in accordance with the laws of the province or territory in which they work, provides one-on-one care and essential support to optimize and maintain an individual’s health, well-being, safety, autonomy and comfort consistent with that individual’s health care needs as directed by a regulated health care professional or a provincial/territorial or community health organization.

The proposal introduces a requirement for applicants in all occupations, including those newly added, to provide at least 400 hours of in-person services in the previous year. If the applicant is prevented from completing the required hours due to medical or caregiving reasons, they may still be eligible for the loan forgiveness benefit. This requirement and the exemption criteria were previously outlined in the Program policy. They would now be published in the regulations for additional clarity. Consistent with the current requirements for family physicians and nurses, once applicants have completed their period of employment in an under-served rural or remote community, they would have 90 days to apply for the loan forgiveness benefit.

The proposed regulations would change the way of calculating the total number of years someone can receive the loan forgiveness benefit. Currently, each profession is capped at five years. This means a borrower could receive two years of loan forgiveness as a nurse, and then a further five years of loan forgiveness as a doctor. The proposed regulations cap loan forgiveness at five years total per borrower. This means, for example, that if a borrower has received the forgiveness benefit for two years while working as a personal support worker and is now working as a registered nurse, they would only be eligible for three additional years of the loan forgiveness benefit at the registered nurse level. In this case, the borrower would be eligible to receive the loan forgiveness as a registered nurse beginning at the third-year amount ($6,000) and would not return to the year-one forgiveness amount, to maintain a consistent, ongoing year counter for each borrower.

The definition of an eligible rural or remote community for the loan forgiveness benefit was changed by regulations that came into force on November 6, 2024. An eligible community is now defined as a population centre with a population of no more than 30 000, or a rural area. This definition will apply to the additional proposed occupations. However, the definition change also included a provision to maintain the eligibility of certain legacy communities (i.e. communities that were eligible under the previous definition but not under the new definition) until approximately six months after the 2026 Census population is published — likely in 2027–2028. This provision is meant to ensure that these communities have time to adjust their recruitment strategies for family physicians and nurses before losing eligibility for the loan forgiveness benefit. Therefore, legacy communities will not be considered eligible locations of work for the 10 additional occupations proposed to be eligible for the loan forgiveness benefit under these regulations.

Applicants may, in accordance with the Program policy, work in more than one under-served rural or remote community during their 12-month period of employment to obtain the required hours.

Regulatory development

Consultation

The Program regularly engages with stakeholders, including student associations, student financial aid administrators, and PT representatives through the National Advisory Group on Student Financial Assistance (NAGSFA) and the Intergovernmental Consultative Committee on Student Financial Assistance (ICCSFA). In addition, for this measure, the Program also consulted

• PT health ministries with the support of Health Canada and their federal-provincial/territorial (F-PT) Committee on Health Workforce;
• the Extended Healthcare Professionals Coalition;
• health-oriented Indigenous stakeholders;
• remote community educational institutions; and
• other professional associations.

On May 17, 2022, the Program met with the National Association of Career Colleges, Colleges and Institutes Canada, and the Canadian Association of Student Financial Aid Administrators, which are all NAGSFA members. These groups suggested that specific occupations, such as early childhood assistants, paramedics, and lab technicians, should be included in the expansion of the forgiveness benefit.

On May 18, 2022, the Program met with PT members of the Policy Development Committee, which is an ICCSFA subcommittee serving as a forum for members to co-develop evidence-based policy advice on issues of shared interest and for provinces and territories to review and provide input on federal student financial assistance policy proposals. During this meeting, Saskatchewan representatives requested that the Program consider veterinarians and veterinary technicians as potential eligible occupations should the forgiveness benefit extend beyond family physicians and nurses.

On May 31, 2022, the Program met with PT health ministries through the F-PT Committee on Health Workforce, a standing committee that reports to the Conference of Deputy Ministers. It was established in 2002 by the F-PT Conference on Deputy Ministers of Health, and membership consists of federal and provincial co-chairs plus one senior-level delegate from each F-PT ministry of health.

During this meeting, representatives from British Columbia advocated that physiotherapists, medical lab technicians, social workers, and occupational therapists be eligible for the loan forgiveness benefit, while Manitoba advocated the same for personal support workers and occupational therapists.

In fall 2022 an engagement package was shared with 102 stakeholder groups and partners. These groups were encouraged to circulate the engagement package to other organizations in their networks. This package included a discussion paper outlining the purpose and intent of the loan forgiveness benefit, a Program description, and a questionnaire.

The questionnaire sought feedback from stakeholders on Budget 2022 announcements and a variety of subjects relating to potential enhancements to the loan forgiveness benefit. For example, stakeholders were asked about the following current requirements: minimum service threshold of 400 hours, full year of employment (12 consecutive months), and the five-year loan forgiveness benefit maximum.

They were also asked to identify up to five health care occupations in order of priority, beyond family physicians, nurses, and nurse practitioners, that are most urgently needed in rural and remote communities with a rationale and evidence for their selections and prioritization. In addition, stakeholders were able to indicate whether there were shortages in professions outside of health care (e.g. social services, education).

Stakeholder feedback from the 2022 questionnaire

The Program received 29 responses (a 28% response rate) from the following stakeholder groups in fall 2022: professional associations in health care and other essential services, PT health ministries, organizations representing the communal interests of rural and remote communities, Indigenous stakeholders, and NAGSFA and ICCSFA members.

In response to the question on potential changes to the required minimum service threshold of 400 hours, 10 stakeholders, the majority of whom represented health care advocacy groups, indicated that the minimum service requirement for eligibility for the loan forgiveness benefit was appropriate and should not be changed. One of the stakeholders noted that while they are comfortable with the current minimum service threshold, if a change was to be made, they would recommend an increase to the current hours.

On the same question, four other stakeholders indicated that they would like the hours increased. They suggested that increasing the threshold would mean increased service provision to rural or remote communities, which would enable professionals to establish connections in the communities. Four additional stakeholder groups advocated for the hours to be decreased to further incentivize professionals to work in rural or remote communities.

Questionnaire results also showed that 14 stakeholders believed that increasing the one-year (12 consecutive months) commitment period would benefit communities by encouraging professionals to properly establish themselves during the period in which they would benefit from loan forgiveness, encouraging long-term retention of professionals.

Regarding the current five-year maximum loan forgiveness cap per profession, the questionnaire responses were varied. Some stakeholders indicated that the current forgiveness period was appropriate and should not be changed, while others suggested the period should be extended to provide greater incentive for graduates to remain in rural or remote communities.

In response to the question relating to shortages in professions outside of health care and to identify urgently needed additional health care professions in order of priority, 44 professions not currently eligible for the forgiveness benefit were recommended and ranked. Respondents recommended social worker, psychologist, physiotherapist, dentist, and dental hygienist as the top five occupations to become eligible for the forgiveness benefit. Other professions outside of health care and social services such as electricians, plumbers, and carpenters were also recommended.

Pre-budget 2022, 2023, and 2024 consultations

As part of the annual budget process, the House of Commons Standing Committee on Finance (the Committee) led pre-budget consultations for Budget 2022, 2023, and 2024. Annual pre-budget consultations led by the Committee are comprehensive and national in scope. Over the course of those years, 11 professional associations representing both health care and social services occupations submitted pre-budget briefs. Each group advocated for the list of eligible occupations to include those they respectively represent.

Modern treaty obligations and Indigenous engagement and consultation

The proposed regulatory amendments are not expected to have differential impacts on Indigenous peoples or negative implications for modern treaties, according to the Government of Canada obligations in relation to rights protected by section 35 of the Constitution Act, 1982. The proposed regulatory amendments were assessed for modern treaty implications following the Cabinet Directive on the Federal Approach to Modern Treaty Implementation. The assessment found no immediate impacts on modern treaty obligations. Indigenous communities are expected to benefit from this regulatory proposal.

While engaging on the suite of proposed amendments to the forgiveness benefit in 2022, the Department of Employment and Social Development consulted the Indigenous Physicians Association of Canada (IPAC). IPAC recommended that while financial incentives would encourage people to work in rural and remote areas, the focus should be on building the community’s capacity, such as training local residents who are more likely to stay in their home communities over the long term. In addition, IPAC recommended that resources may be better put toward reducing barriers for people from rural areas from getting into medical school and subsidizing their training and residency in their home areas.

Post-secondary education admission policies and the curriculum for education and training are outside the purview of the federal government. Nevertheless, the Program particularly supports Indigenous learners by exempting them from the required annual fixed student contribution toward education costs. Needs assessments for Indigenous learners also exempt funding received through the Post-Secondary Student Support Program (as well as through the Métis Nation and Inuit post-secondary education strategies) when determining a student’s resources.

Indigenous peoples are expected to be positively impacted by the proposed expansion to the loan forgiveness benefit. In 2020, the Organisation for Economic Co-operation and Development identified roughly 60% of Canada’s Indigenous peoples as living in predominantly rural areas, which is approximately 30% more than the non-Indigenous population.^{footnote 3} The 2021 census estimates that there are 1 807 250 Indigenous people living in Canada.^{footnote 4} These figures were used as proxies to identify the potential population of Indigenous peoples living in rural or remote regions. It is estimated that there are approximately one million Indigenous individuals being impacted by these regulatory amendments. According to the 2020 Indigenous Services Canada (ISC) Annual Report to Parliament, Indigenous peoples also make up the largest proportion of the population in Nunavut (86%), the Northwest Territories (51%) and the Yukon (23%).^{footnote 5}

Instrument choice

The proposed regulatory amendments can only be addressed by regulatory amendments. The Canada Student Financial Assistance Act ^{footnote 6} (CSFAA) and the Canada Student Loans Act ^{footnote 7} (CSLA) only provide the authorities for the loan forgiveness benefit with the conditions to be prescribed by the related regulations. As a result, non-regulatory options were not considered.

Regulatory analysis

Benefits and costs

The stakeholders that would be most directly affected by the proposed regulatory amendments are the residents of under-served rural or remote communities, borrowers with outstanding student loans who work in newly eligible occupations, and the Government of Canada.

This cost-benefit analysis^{footnote 8} assessed the incremental impacts to stakeholders of expanding the reach of the loan forgiveness benefit to early childhood educators, dentists, dental hygienists, pharmacists, midwives, teachers, social workers, personal support workers, physiotherapists, and psychologists who choose to work in a designated under-served rural or remote community, compared to a baseline scenario in which these regulatory amendments are not made.

The net monetized benefit of implementing the proposed regulatory amendments would be $290.3 million in net present value, over the next 10 years, for a benefit-to-cost ratio of 1.4:1.

Annually, it is anticipated that the proposed regulatory amendments would directly benefit about 7 968 federal student loan borrowers in the first year of implementation (2025–2026) and up to about 19 025 borrowers per year by 2034–2035. Among these beneficiaries, it is estimated that in 2025–2026, about 2 841 will have relocated to these under-served rural or remote areas specifically because of the forgiveness benefit, increasing to about 3 024 by 2034–2035, for a total of 27 822 over 10 years. Additional early childhood educators in rural and remote areas are expected to increase the labour force participation rates of parents with young children in those areas as more child care spaces become available. This would in turn increase family income in rural and remote areas and provide additional tax revenue to the Government. The number of people residing in an area eligible for the loan forgiveness benefit is estimated at 11.2 million, which represents approximately 30% of the Canadian population. The proposed regulatory amendments would also increase the costs to the Government of Canada through additional loan forgiveness. These costs are equivalent to the expanded loan forgiveness benefit that would be provided to borrowers. A larger volume of loan forgiveness applications is expected to increase the costs payable by the Government to the private sector service provider to process and verify these applications, along with costs for modernizing the application process. The benefit-to-cost ratio excludes significant additional qualitative benefits to Canadians living in rural or remote communities and Canadian society, such as improved access to health/social services and the associated benefits. Consequently, this study concludes that the benefits of implementing these regulatory amendments outweigh the costs.

Regarding distributional analysis, the proposed regulatory amendments are expected to impact affected stakeholders based on attributes such as region, gender, income, and age. People living in rural and remote communities often have lower incomes and are slightly older than the Canadian population.^{footnote 9,footnote 10} Both rural men and women face health disparities and have worse health outcomes compared to the general population.^{footnote 11} The regulatory amendments would positively impact rural and remote communities by providing increased access to health care and social service providers, which in turn may result in improved health and social outcomes for the rural population. Research demonstrates that financial incentives contribute to the recruitment and retention of various health care and social service providers to work in rural and remote communities.^{footnote 12} In particular, loan forgiveness programs are an important source of financial assistance for those who choose to work in rural or remote areas and result in a higher rate of retention even when one no longer qualifies for loan forgiveness.^{footnote 13,footnote 14}

Cost-benefit statement

• Number of years: 10 (2025–2026 to 2034–2035)
• Price-level year: 2025
• Present value base year: 2025
• Discount rate: 7%

Monetized benefits

The proposed regulatory amendments would provide an incentive for specified health care and social service professionals to work in eligible rural and remote communities. These benefits were monetized by attributing the equivalent estimated costs carried by the Government for loan forgiveness as a benefit to the borrowers. Additional early childhood educators in rural and remote areas are expected to increase the labour force participation rates of parents with young children in those areas as more child care spaces become available. This would in turn increase family income in rural and remote areas and provide additional tax revenue to the Government, which are monetized benefits.

Table 2: Monetized benefits of expanding eligibility of the loan forgiveness benefit to 10 additional health care and social service occupations in under-served rural or remote communities

Impacted stakeholder	Description of benefit	First year (2025–2026)	Second year (2026–2027)	Fifth year (2029–2030)	Final year (2034–2035)	Total (present value)	Annualized value
Program borrowers	Loan forgiveness to Program borrowers employed in occupations newly eligible for the benefit	$45.5M	$62.0M	$97.4M	$108.6M	$644.8M	$91.8M
Canadians	Additional net income for Canadians joining the workforce due to additional child care spaces from early childhood educators who are motivated to work in rural or remote areas because of loan forgiveness	$8.7M	$13.4M	$31.9M	$74.2M	$254.4M	$36.2M
Federal government	Additional tax revenue from increasing the workforce in rural areas due to additional child care spaces from early childhood educators who were motivated by the loan forgiveness benefit to work in rural areas	$1.5M	$2.4M	$5.6M	$13.1M	$44.9M	$6.4M
All stakeholders	Total benefits	$55.7M	$77.8M	$134.9M	$195.9M	$944.1M	$134.4M

Monetized costs

The cost to the Government of Canada for providing loan forgiveness is based on estimates using the Census 2021 population by National Occupational Classification and the Program administrative data. The monetized costs include the loan forgiveness amounts paid to beneficiaries, the digitization of the application process, the processing and verification of applications, and the costs related to filling out the application form. The total monetized costs are estimated at $653.8M (present value) over the next 10 years.

Table 3: Monetized costs of expanding eligibility of the loan forgiveness benefit to 10 additional health care and social service occupations in under-served rural or remote communities

Impacted stakeholder	Description of cost	First year (2025–2026)	Second year (2026–2027)	Fifth year (2029–2030)	Final year (2034–2035)	Total (present value)	Annualized value
Federal government	Additional loan forgiveness to Program borrowers employed in occupations that are becoming eligible for loan forgiveness	$50.1M	$62.2M	$97.7M	$109.0M	$651.5M	$92.8M
Program borrower	Cost of filling the application	$0.1M	$0.2M	$0.3M	$0.4M	$2.3M	$0.3M
All stakeholders	Total costs	$50.2M	$62.4M	$98.1M	$109.4M	$653.8M	$93.1M

Table 4: Summary of monetized costs and benefits

Impacts	First year (2025–2026)	Second year (2026–2027)	Fifth year (2029–2030)	Final year (2034–2035)	Total (present value)	Annualized value
Total benefits	$55.7M	$77.8M	$134.9M	$195.9M	$944.1M	$134.4M
Total costs	$50.2M	$62.4M	$98.1M	$109.4M	$653.8M	$93.1M
NET IMPACT	$5.5M	$15.4M	$36.9M	$86.5M	$290.3M	$41.3M

Quantified impacts (in non-$)

Table 5: Incremental number of professionals incentivized to work in rural or remote areas because of the loan forgiveness benefit

Impacts	First year (2025–2026)	Second year (2026–2027)	Fifth year (2029–2030)	Final year (2034–2035)	Total
Dentists	99	89	95	106	974
Pharmacists	182	162	173	193	1 778
Psychologists	84	75	80	89	819
Physiotherapists	72	64	69	77	705
Midwives	6	5	6	7	60
Dental hygienists	44	39	42	46	428
Personal support workers	559	500	533	595	5 474
Teachers	1 252	1 120	1 195	1 333	12 264
Social workers	178	159	170	190	1 747
Early childhood educators	365	326	348	388	3 573
Total	2 841	2 539	2 711	3 024	27 822

Qualitative impacts

Increasing the number of health care and social service providers working in rural or remote communities is expected to help improve access to health care and social services, such as child care and social work.^{footnote 15} Access to a regular primary health care provider is generally associated with better health outcomes and providing local access to health care and social service providers helps address the health and social well-being of the local population.^{footnote 16}

Small business lens

Analysis under the small business lens concluded that the proposed regulatory amendments would not impact Canadian small businesses.

One-for-one rule

The one-for-one rule does not apply to these proposed regulatory amendments as there would be no change in the administrative burden on businesses.

Regulatory cooperation and alignment

The regulatory proposal is not related to any commitment under a formal regulatory cooperation forum. While the ICCSFA is a F-PT body, it does not focus on regulatory cooperation. In addition, there is no international agreement with respect to designated international educational institutions.

The Department of Employment and Social Development has consulted with PT stakeholders, which have been supportive of the measures. In addition, although Quebec, Nunavut, and the Northwest Territories do not currently participate in the Program, they are still eligible for the loan forgiveness benefit for family physicians and nurses including the proposed expansion. Eligible health professionals who received a student loan in a participating province or territory are still permitted to benefit from loan forgiveness if they worked in an under-served rural or remote community in Quebec, Nunavut or the Northwest Territories.

The proposal is aligned with PT strategies to increase health care capacity in rural and remote communities. In their 2024 provincial budgets, Alberta^{footnote 17} and Saskatchewan^{footnote 18} each committed to making significant investments in the recruitment and retention of health care workers in rural and remote areas. At a meeting with the Department of Employment and Social Development in November 2023, representatives from Alberta indicated that they have targeted initiatives to address acute labour shortages in the aviation field and advocated for the federal government to include aviation professionals to the list of occupations for the federal loan forgiveness benefit.

In addition, Saskatchewan and British Columbia have loan forgiveness programs in place that target health professions. Manitoba, Ontario, and Newfoundland and Labrador have the following grant and bursary programs aimed at health care graduates:

• Under Saskatchewan’s loan forgiveness program, nurses, nurse practitioners, veterinarians, and veterinary technologists can have up to 20% of their outstanding provincial student loan debt forgiven (up to $4,000 annually), for up to five years to a maximum of $20,000. To be eligible, applicants must have been employed for 12 consecutive months in a designated community and have provided a minimum of 400 hours of services.^{footnote 19}
• British Columbia’s loan forgiveness program forgives student loan debt for designated professionals working in an eligible under-served community to a maximum of 20% of the provincial portion of a Canada-British Columbia integrated student loan, for up to five years. Under British Columbia’s program, eligible occupations are nurses, physicians, midwives, medical technologists, speech pathologists, occupational therapists, audiologists, physiotherapists, and respiratory therapists. In addition, loan forgiveness is available to certain occupations that work with children, regardless of where they work in the province. These professions are speech pathologists, occupational therapists, audiologists, school psychologists, and teachers of the deaf, hard of hearing or visually impaired. The amount of loan forgiveness granted depends on the number of hours worked, up to a maximum of 20% of annual loan debt forgiven for 400 or more annual hours of in-person service.^{footnote 20} At a meeting with the Program in November 2023, British Columbia representatives expressed interest in expanding their current Pacific Leaders B.C. Loan Forgiveness Program. This expansion would include the addition of 14 occupations in health care, 4 in education, and large animal veterinarians.
• Manitoba’s Grant for Nursing Graduates provides $4,000 (or $8,000 if working in a care home) to eligible graduates of a Manitoba nursing program who agree to work in a permanent or temporary position for at least 12 months in any community in that province outside of Winnipeg or Brandon.^{footnote 21}
• Ontario’s Learn and Stay grant provides free tuition for students in eligible programs, including undergraduate and post-graduate degree programs in nursing, and diploma programs in practical nursing, paramedic, and medical laboratory science. Such students must commit to fulfilling a service agreement to work in the same region in which they studied after graduation, for at least six months for every full year of study.^{footnote 22}
• Newfoundland and Labrador’s Medical Resident Bursary provides a one-time funding amount to medical students, medical residents, nursing students, and other health professionals practising in designated areas of need in the province. The list of eligible health professionals includes personal care attendants, pharmacy technicians, clinical dietitians, respiratory therapists, and clinical psychologists. Applicants must agree to practise for 12 to 36 months in a full-time position at a specific location upon finishing their program of study. Bursary amounts increase for more rural and difficult-to-fill positions, from a minimum of $3,000 to a maximum of $90,000.^{footnote 23}

Meanwhile, several provinces and territories, such as Nova Scotia, Prince Edward Island, Quebec, Nunavut, and the Northwest Territories, also offer broad loan forgiveness programs not targeted to specific occupations.

Effects on the environment

In accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment, a preliminary scan concluded that a strategic environmental assessment is not required.

Gender-based analysis plus

The proposed regulatory amendments would support eligible borrowers and, in a broader sense, the greater Canadian population by increasing the number of health and supporting services professionals in under-served rural areas. The gender-based analysis plus did not identify any unintended adverse impacts resulting from the proposed regulatory amendments.

While this measure does not directly target women, in 2022, many health care and supporting services workers were women. Regarding the proposed regulatory amendments, about 83% of people working in occupations eligible for the loan forgiveness benefit would be women.^{footnote 24} Furthermore, despite the health care sector being predominantly female, women are less likely to hold supervisory positions and are facing a 24% gender wage gap.^{footnote 25} As a result, the expanded loan forgiveness benefit would represent a greater financial benefit for eligible women.

Regarding the impacts of these regulatory changes by age group, Program data indicates that loan forgiveness beneficiaries are typically between the ages of 18 and 29. Furthermore, 74% of individuals with outstanding Canada Student Loans are under 35 years of age. Therefore, the proposed regulatory amendments are expected to benefit more borrowers under the age of 35 compared to other age groups, as these beneficiaries are more likely to be repaying their loans and more likely to be influenced by financial incentives.

Rural and remote areas face historical barriers to health care and social services. In conjunction with other initiatives to increase health care and social service capacity in rural and remote communities, the proposed regulatory amendments are expected to help support increased access to health care and social services in these communities. Compared to the urban population, rural residents are more likely to experience detrimental health outcomes such as injuries, chronic conditions, obesity, and shorter life expectancy.^{footnote 26,footnote 27} Higher preventable and treatable mortality rates in the remote areas could be attributed to geographic barriers, limited health care services, and unmet health care needs. By improving access to health care providers and social services in rural and remote communities, these regulatory amendments would help address the health disparities that exist between the urban and rural populations. Furthermore, people living in rural and remote communities often have lower incomes, and low-income women in particular experience social, economic, and institutional exclusions, which women with higher income do not face.^{footnote 28} These barriers pose serious consequences to their overall health and well-being. Additionally, child care availability, or lack thereof, often primarily affects a mother’s decision to return to work, which results in greater income loss for women when compared to men.^{footnote 29} However, increasing the availability of child care through the increase in early childhood educators would enable women to more easily participate in the rural labour force.

Implementation, compliance and enforcement, and service standards

Implementation

The proposed regulatory amendments are intended to come into force in fall 2025.

The intention is that qualifying borrowers in the newly eligible occupations would be able to access the loan forgiveness benefit immediately upon the coming into force of the proposed regulatory amendments. In other words, newly eligible professionals would be able to access the loan forgiveness benefit for work they completed up to one year before the implementation date even if the profession was not eligible when they started working. For example, a dentist who starts working in an eligible under-served rural or remote community on November 15, 2024, would be able to apply for the loan forgiveness benefit as of November 15, 2025, if they have completed a year of work in that community and the regulations are in force by that date.

Existing F-PT and stakeholder fora would be used to notify all stakeholders of the changes.

The Program is delivered in collaboration with nine participating provinces, one territory, and a private sector service provider. As this benefit only applies to federal loans, the service provider is exclusively responsible for implementing this measure. This measure would involve the service provider implementing operational system changes and require the development of a new, automated application system and verification model to manage the expected increase in application volume.

The enhancements to the loan forgiveness benefit would be incorporated into existing performance measurement and evaluation mechanisms. The Department of Employment and Social Development Evaluation Directorate recently completed an evaluation of the Program in March 2021^{footnote 30} and an evaluation of this forgiveness benefit, released on January 22, 2024.^{footnote 31} The general evaluation found that the majority (66%) of borrowers were aware that the federal government provides student loans and grants. However, few (17%) were aware of the importance of the federal government in the total financial support they received. The evaluation of the loan forgiveness benefit found that even though the Program undertook extensive consultations prior to launching the loan forgiveness benefit and provided detailed information about eligibility and the application process on the Government of Canada website, beneficiaries mostly learned about the benefit from different sources. Since the launch of the benefit, awareness creation has not been a key component. Therefore, word of mouth has been the most common means of communication about the loan forgiveness benefit among students and professionals. The Evaluation Directorate recommended that the Program should explore outreach opportunities to increase awareness of the benefit among key stakeholders, especially among intended beneficiaries.

Compliance and enforcement

The CSFAA requires that an actuarial report about the Program be tabled in Parliament at least once every three years. This report provides an estimate of Program costs and revenues, a 25-year forecast of future Program costs and revenues, and an explanation of the methodology and actuarial and economic assumptions used to produce the figures presented in the report. The CSFAA also requires an annual report on the Program to be tabled in Parliament. The annual report provides detailed Program statistics (including the value of the portfolio) and outlines key objectives, initiatives, and accomplishments achieved over a given academic year, and the integrity policies.^{footnote 32}

The CSFAA provides authority for the Program to ensure that federal grants and loans are not provided to students who are not eligible. Subsection 17(1) of this act provides for a fine of up to $1,000 for students who knowingly provide any false or misleading information, including by omission, in an application or other document. Also, section 17.1 allows for any such student to be denied additional federal financial assistance as well as certain other Program benefits, such as repayment assistance.

Contact

Erin Hetherington
Director
Learning Branch
Canada Student Financial Assistance Program
Employment and Social Development Canada
Email: EDSC.DGA.PCAFE.MCPP-SEC.CSFAP.LB.ESDC@hrsdc-rhdcc.gc.ca

PROPOSED REGULATORY TEXT

Notice is given that the Governor in Council proposes to make the annexed Regulations Amending the Canada Student Loans Regulations and the Canada Student Financial Assistance Regulations under section 17^{footnote a} of the Canada Student Loans Act ^{footnote b} and subsection 15(1)^{footnote c} of the Canada Student Financial Assistance Act ^{footnote d}.

Interested persons may make representations concerning the proposed Regulations within 30 days after the date of publication of this notice. They are strongly encouraged to use the online commenting feature that is available on the Canada Gazette website but if they use email, mail or any other means, the representations should cite the Canada Gazette, Part I, and the date of publication of this notice, and be sent to Erin Hetherington, Director, Learning Branch, Department of Employment and Social Development, 200 Montcalm Street, Gatineau, Quebec J8Y 3B5 (email: EDSC.DGA.PCAFE.MCPP-SEC.CSFAP.LB.ESDC@hrsdc-rhdcc.gc.ca).

Ottawa, January 30, 2025

Wendy Nixon
Assistant Clerk of the Privy Council

Regulations Amending the Canada Student Loans Regulations and the Canada Student Financial Assistance Regulations

Canada Student Loans Act

Canada Student Loans Regulations

1 Subsection 2(1) of the Canada Student Loans Regulations ^{footnote 33} is amended by adding the following in alphabetical order:

dental hygienist

means a person, other than a dental therapist, who is entitled to work as a dental hygienist under the laws of the province in which they are so working; (hygiéniste dentaire)

dentist

means a person who is entitled to work as a dentist under the laws of a province in which they are so working; (dentiste)

early childhood educator

means a person, other than an early childhood educator assistant or a teacher, who

• (a) in the case of a person who works as an early childhood educator in New Brunswick, the Northwest Territories or Nunavut, meets the definition of an early childhood educator in the laws of any province; or
• (b) in the case of a person who works as an early childhood educator in any other province, is entitled to work as an early childhood educator under the laws of that province; (éducateur de la petite enfance)

midwife

means a person who is entitled to work as a midwife under the laws of a province in which they are so working; (sage-femme)

personal support worker

means a person who, in accordance with the laws of the province in which they work, provides one-on-one care and essential support to optimize and maintain an individual’s health, well-being, safety, autonomy and comfort consistent with that individual’s health care needs as directed by a regulated health care professional or a provincial or community health organization; (préposé aux services de soutien à la personne)

pharmacist

means a person who is entitled to work as a pharmacist under the laws of the province in which they are so working; (pharmacien)

physiotherapist

means a person who

• (a) in the case of a person who works as a physiotherapist in the Northwest Territories or Nunavut, meets the definition of a physiotherapist or physical therapist in the laws of any province; or
• (b) in the case of a person who works as a physiotherapist in any other province, is entitled to work as a physiotherapist or physical therapist under the laws of that province; (physiothérapeute)

psychologist

means a person, other than a psychotherapist, who

• (a) in the case of a person who works as a psychologist in Yukon, meets the definition of a psychologist in the laws of any province; or
• (b) in the case of a person who works as a psychologist in any other province, is entitled to work as a psychologist under the laws of that province; (psychologue)

social worker

means a person, other than a social service worker, who

• (a) in the case of a person who works as a social worker in Yukon or Nunavut, meets the definition of a social worker in the laws of any province; or
• (b) in the case of a person who works as a social worker in any other province, is entitled to work as a social worker under the laws of that province; (travailleur social)

teacher

means a person who is entitled to teach at an elementary or secondary school under the laws of the province in which they are so teaching; (enseignant)

2 The heading “Loan Forgiveness for Family Physicians, Nurses and Nurse Practitioners” before section 17 of the Regulations is replaced by the following:

Loan Forgiveness — Under-Served Rural or Remote Communities

3 (1) Paragraphs 18(1)(a) to (e) of the Regulations are replaced by the following:

• (a) for the first year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $8,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $4,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $2,000 in the case of an early childhood educator, dental hygienist or personal support worker;
• (b) for the second year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $10,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $5,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $2,500 in the case of an early childhood educator, dental hygienist or personal support worker;
• (c) for the third year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $12,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $6,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $3,000 in the case of an early childhood educator, dental hygienist or personal support worker;
• (d) for the fourth year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $14,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $7,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $3,500 in the case of an early childhood educator, dental hygienist or personal support worker; and
• (e) for the fifth year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $16,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $8,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $4,000 in the case of an early childhood educator, dental hygienist or personal support worker.

(2) Subsection 18(2) of the Regulations is replaced by the following:

(2) The maximum number of years in respect of which an amount may be forgiven in respect of a guaranteed student loan is five minus the number of years in respect of which an amount has been forgiven under subsection (1) in respect of a previous guaranteed student loan or under subsection 28(1) of the Canada Student Financial Assistance Regulations.

4 (1) The portion of subsection 19(1) of the Regulations before paragraph (b) is replaced by the following:

19 (1) For the purposes of subsection 11.1(1) of the Act, to qualify for forgiveness for a year, the borrower must

• (a) either
  • (i) have begun to work during the year by providing in-person services as a family physician, dentist, pharmacist, psychologist, nurse, nurse practitioner, midwife, teacher, social worker, physiotherapist, early childhood educator, dental hygienist or personal support worker in an under-served rural or remote community, or
  • (ii) have continued to work during the year by providing in-person services as a family physician, dentist, pharmacist, psychologist, nurse, nurse practitioner, midwife, teacher, social worker, physiotherapist, early childhood educator, dental hygienist or personal support worker in a community in respect of which the borrower qualified for loan forgiveness for the previous year;
• (a.1) subject to subsection (4), have worked at least 400 hours; and

(2) Section 19 of the Regulations is amended by adding the following after subsection (3):

(4) The Minister may decide that a borrower who worked less than 400 hours but at least one hour during the year still qualifies for loan forgiveness for the year if the Minister is of the opinion that the borrower was unable to work because they were

• (a) suffering from illness, disability or bodily injury or were quarantined;
• (b) providing care or support to a family member who was suffering from illness, disability or bodily injury or who was quarantined;
• (c) pregnant or gave birth; or
• (d) caring for their newborn or newly adopted child.

Canada Student Financial Assistance Act

Canada Student Financial Assistance Regulations

5 Subsection 2(1) of the Canada Student Financial Assistance Regulations ^{footnote 34} is amended by adding the following in alphabetical order:

dental hygienist

means a person, other than a dental therapist, who is entitled to work as a dental hygienist under the laws of the province in which they are so working; (hygiéniste dentaire)

dentist

means a person who is entitled to work as a dentist under the laws of a province in which they are so working; (dentiste)

early childhood educator

means a person, other than an early childhood educator assistant or a teacher, who

• (a) in the case of a person who works as an early childhood educator in New Brunswick, the Northwest Territories or Nunavut, meets the definition of an early childhood educator in the laws of any province; or
• (b) in the case of a person who works as an early childhood educator in any other province, is entitled to work as an early childhood educator under the laws of that province; (éducateur de la petite enfance)

midwife

means a person who is entitled to work as a midwife under the laws of a province in which they are so working; (sage-femme)

personal support worker

means a person who, in accordance with the laws of the province in which they work, provides one-on-one care and essential support to optimize and maintain an individual’s health, well-being, safety, autonomy and comfort consistent with that individual’s health care needs as directed by a regulated health care professional or a provincial or community health organization; (préposé aux services de soutien à la personne)

pharmacist

means a person who is entitled to work as a pharmacist under the laws of the province in which they are so working; (pharmacien)

physiotherapist

means a person who

• (a) in the case of a person who works as a physiotherapist in the Northwest Territories or Nunavut, meets the definition of a physiotherapist or physical therapist in the laws of any province; or
• (b) in the case of a person who works as a physiotherapist in any other province, is entitled to work as a physiotherapist or physical therapist under the laws of that province; (physiothérapeute)

psychologist

means a person, other than a psychotherapist, who

• (a) in the case of a person who works as a psychologist in Yukon, meets the definition of a psychologist in the laws of any province; or
• (b) in the case of a person who works as a psychologist in any other province, is entitled to work as a psychologist under the laws of that province; (psychologue)

social worker

means a person, other than a social service worker, who

• (a) in the case of a person who works as a social worker in Yukon or Nunavut, meets the definition of a social worker in the laws of any province; or
• (b) in the case of a person who works as a social worker in any other province, is entitled to work as a social worker under the laws of that province; (travailleur social)

teacher

means a person who is entitled to teach at an elementary or secondary school under the laws of the province in which they are so teaching; (enseignant)

6 The heading of Part V.1 of the Regulations is replaced by the following:

Loan Forgiveness — Under-Served Rural or Remote Communities

7 (1) Paragraphs 28(1)(a) to (e) of the Regulations are replaced by the following:

• (a) for the first year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $8,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $4,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $2,000 in the case of an early childhood educator, dental hygienist or personal support worker;
• (b) for the second year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $10,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $5,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $2,500 in the case of an early childhood educator, dental hygienist or personal support worker;
• (c) for the third year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $12,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $6,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $3,000 in the case of an early childhood educator, dental hygienist or personal support worker;
• (d) for the fourth year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $14,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $7,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $3,500 in the case of an early childhood educator, dental hygienist or personal support worker; and
• (e) for the fifth year in respect of which the borrower qualifies for loan forgiveness,
  • (i) $16,000 in the case of a family physician, dentist, pharmacist or psychologist,
  • (ii) $8,000 in the case of a nurse, nurse practitioner, midwife, teacher, social worker or physiotherapist, or
  • (iii) $4,000 in the case of an early childhood educator, dental hygienist or personal support worker.

(2) Subsection 28(2) of the Regulations is replaced by the following:

(2) The maximum number of years in respect of which an amount may be forgiven in respect of a student loan is five minus the number of years in respect of which an amount has been forgiven under subsection (1) in respect of a previous student loan.

8 (1) The portion of subsection 29(1) of the Regulations before paragraph (b) is replaced by the following:

29 (1) For the purposes of subsection 9.2(1) of the Act, to qualify for loan forgiveness for a year, the borrower must

• (a) either
  • (i) have begun to work during the year by providing in-person services as a family physician, dentist, pharmacist, psychologist, nurse, nurse practitioner, midwife, teacher, social worker, physiotherapist, early childhood educator, dental hygienist or personal support worker in an under-served rural or remote community, or
  • (ii) have continued to work during the year by providing in-person services as a family physician, dentist, pharmacist, psychologist, nurse, nurse practitioner, midwife, teacher, social worker, physiotherapist, early childhood educator, dental hygienist or personal support worker in a community in respect of which the borrower qualified for loan forgiveness for the previous year;
• (a.1) subject to subsection (4), have worked at least 400 hours; and

(2) Section 29 of the Regulations is amended by adding the following after subsection (3):

(4) The Minister may decide that a borrower who worked less than 400 hours but at least one hour during the year still qualifies for loan forgiveness for the year if the Minister is of the opinion that the borrower was unable to work because they were

• (a) suffering from illness, disability or bodily injury or were quarantined;
• (b) providing care or support to a family member who was suffering from illness, disability or bodily injury or who was quarantined;
• (c) pregnant or gave birth; or
• (d) caring for their newborn or newly adopted child.

Coming into Force

9 These Regulations come into force on November 1, 2025.

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