Open Comment Period on Proposed Professional Degree Programs

The Department of Education has opened its public comment period, about changes to federal student loans and proposed narrow definition of professional programs(opens in a new tab). These changes could have significant implications for counseling students and programs. ACES joined our affiliate partners in January 2026 at a Congressional Briefing hotsted to educate congressional staffers on the importance of Counselors, MFTs , and SW’s having the Professional Degree designation.

Under this proposed rule, Counseling programs would be considered graduate programs (rather than professional programs), subjecting them to lower federal loan limits. While professional programs can borrow $50,000 a year ($200,000 in aggregate), graduate programs can only borrow $20,500 a year ($100,000 in aggregate). The change may impede the number of individuals who can pursue graduate counselor education which in turn will reduce the number of MH providers.

We are calling on the counseling community to let the Department of Education know that counselors are professionals and deserve equal access to federal student loans. Please review the ACES website(opens in a new tab) for access to a document supporting counseling as a professional degree. The document may be helpful in forming your comments.

Help advocate for the counseling community:

• Templates for use as you prepare your comments will be available soon with versions for professionals and students.
• Review the comment portal(opens in a new tab) in advance of submitting your comments so that you know what questions are being asked and have the chance to formulate your responses.