NAP Submits Comments on the U.S. Department of Education’s
Proposed Changes to the Definition of “Professional” Programs

Introduction and Organizational Interest
The National Academies of Practice (NAP) is a non-profit organization representing distinguished practitioners and scholars across 17 U.S. health professions including athletic training, audiology, nursing, nutrition and dietetics, occupational therapy, optometry, oral health, pharmacy, physical therapy, physicians, podiatric medicine, psychology, public health, respiratory care, social work, speech-language pathology, and veterinary medicine.

Founded in 1981, the National Academies of Practice is a non-profit, interprofessional organization that advises governmental bodies on the nation’s health care system. As an interprofessional alliance, NAP is unique in bringing together expert practitioners and scholars from 17 health professions to support collaboration, excellence in practice, and policies that promote high-quality, person-centered care. As an organization dedicated to advising policymakers on health workforce and education issues, NAP has a strong interest in federal regulations that affect health professions education, workforce development, and access to care.

Background
NAP is concerned that the Department of Education’s changes to student loan limits combined with the lack of inclusion of additional graduate-level health professional degrees in the designation of “professional” programs will exacerbate existing workforce shortages and impact Americans’ access to healthcare. While NAP recognizes the Department’s explicit addition of clinical psychology among recognized “professional” programs, this addition does not mitigate the broader consequences of excluding other graduate-level health professional degrees that require advanced education, accreditation, and licensure.

Analysis

Graduate-Prepared Health Professionals and Scope of Practice
Across health professions, graduate-prepared professionals deliver services that require advanced training, expanded scope of practice, and higher levels of clinical, leadership, and systems responsibility compared to baccalaureate-prepared roles. These distinctions are well established through accreditation standards, licensure requirements, and scope-of-practice regulations.

Graduate-level professional degree programs are also inherently more costly to deliver due to necessary supervised clinical training, lower faculty-to-student ratios, graduate-prepared preceptor-based education, and extended experiential learning in real-world practice settings.

These requirements are essential to ensuring practitioner competency and public safety, but they significantly increase educational costs for institutions and students alike. Excluding graduate-level professional degrees from the definition of “professional” programs that qualify for higher student loan limits fails to recognize these established differences in preparation, responsibility, and cost.

Impact on Health Professions Education and Workforce Supply
Financial access to health professions education is a public health issue, not merely a fiscal policy consideration. Limiting access to federal student loan programs, loan repayment options, and other financial supports that make advanced health professions education feasible will have a significant impact on the availability of qualified healthcare providers and exacerbate existing healthcare workforce shortages.

Students in graduate-level health professional degree programs already face substantial financial burdens. Reduced federal borrowing limits force increased reliance on high-interest private loans, delay program completion, or push students out of required training pathways altogether. These barriers will deter qualified applicants, constrict the pipeline into essential health professions, and deepen shortages across care settings—particularly in rural and underserved areas. 

Implications for Patient Access to Care
Graduate-prepared health professionals play critical roles across primary, secondary, and tertiary prevention, including chronic disease management, rehabilitation, behavioral health, oral health, communication support, social care, and preventive services. Reduced workforce entry—driven by diminished access to adequate federal financial aid—will directly limit patient access to essential health services nationwide.

Failure to recognize additional graduate-level health professional degrees within the “professional” program designation is fundamentally misaligned with federal investments and priorities aimed at expanding access to care, strengthening the healthcare workforce, and addressing population health needs.

Impact on Communities
Communities -- particularly rural, frontier, and underserved populations -- will experience the most significant consequences of these changes. Reduced workforce supply will result in diminished service availability, longer wait times, and decreased access to preventive, primary, specialty, and rehabilitative care, further widening existing health disparities.

Recommendations
NAP respectfully recommends that the Department of Education:

1. Consider including additional graduate-level health professional degrees that meet the designation of “professional” programs so individuals may access the higher loan limits required to adequately prepare for careers in healthcare professions.

2. Ensure regulatory language reflects advanced preparation, licensure, and supervised clinical training required for graduate-level health professions education.

3. Evaluate workforce, access, and community-level impacts of excluding graduate-level health professional education degree programs, including financial barriers faced by students and access to care barriers faced by communities.

4. Engage health professions stakeholders, including national professional and interprofessional organizations representing NAP’s member academies, to inform final rulemaking and ensure alignment with national health workforce and public health priorities.

Conclusion
Changes to student loan limits combined with the lack of inclusion of additional graduate-level health professional degrees in the designation of “professional” programs risks unintended and far-reaching consequences for health professions education, workforce capacity, patient access to care, and community health. An inclusive, evidence-informed approach is necessary to align federal education policy with the realities of health professions preparation and the needs of the U.S. healthcare system.

Thank you for the opportunity to submit this comment.

Respectfully submitted,
Anthony Breitbach, PhD, ATC, FASAHP, FNAP
National Academies of Practice
President 2025-2027