In late October, the American Academy of Audiology (AAA) and the American Speech-Language-Hearing Association (ASHA) joined a broad coalition of healthcare organizations in calling for a more inclusive definition of “professional degree program” as the U.S. Department of Education continues its rulemaking process under the One Big Beautiful Bill Act (H.R. 1).
The request was formalized in a letter submitted by the Patient Access to Responsible Care Alliance (PARCA), a coalition representing more than four million non-physician Medicare-recognized health and mental health providers across the United States.1
The letter, addressed to leaders within the Department of Education and the Reimagining and Improving Student Education (RISE) rulemaking committee, argues that current federal definitions do not fully reflect the range of health professions that require advanced education, clinical training, and licensure—putting students in certain disciplines at risk of reduced access to federal financial aid.
Background: Federal Rulemaking Under H.R. 1
The One Big Beautiful Bill Act (H.R. 1) includes several provisions governing student financial aid, including limits on federal student loans for certain graduate and professional programs. As the Department of Education works to implement the law, the RISE Committee is charged with developing regulatory language defining what qualifies as a “professional degree program.”
Federal regulations currently reference degrees such as medicine, dentistry, pharmacy, chiropractic, and law. While some PARCA-represented professions appear in the existing language, many others—including audiology—are not explicitly named. The coalition argues that these omissions create ambiguity and risk significant unintended consequences.
According to the letter, degrees required for audiologists, speech-language pathologists, advanced practice nurses, occupational therapists, and other licensed providers meet the same criteria as those already classified as professional degree programs: they require post-baccalaureate education, extensive clinical or fieldwork training, and state licensure or certification to practice.1
Concerns Over Loan Limits and Workforce Impacts
A central issue raised by PARCA is the potential impact on federal loan limits for students entering health fields that are not explicitly included in the definition of a professional degree program. If a discipline is not recognized, students may face lower borrowing caps, limiting their ability to pay for graduate-level education.
The letter states that unequal loan limits could deter qualified students from pursuing careers in high-demand fields, worsening existing provider shortages—particularly in rural and underserved regions where non-physician clinicians play a critical role.1
The coalition warns that inconsistent treatment across professions could decrease patient access and choice, as students gravitate toward fields with more supportive financial aid options.
The Academy and its partner organizations stress that health professions relying on post-baccalaureate degrees should not be disadvantaged simply because they are not explicitly listed in older federal definitions.
Key Recommendations From the PARCA Letter
The letter outlines several recommendations for the RISE Committee as it finalizes regulatory language:
- Establish a clear and inclusive definition of “professional degree program” covering any master’s or doctoral degree generally required for licensure or certification in a health profession.
- Use Classification of Instructional Programs (CIP) codes to identify eligible programs, creating consistency across disciplines.
- Ensure equal treatment in loan eligibility, borrowing limits, and repayment programs for all health professions requiring advanced degrees.
- Align definitions with state and federal licensure pathways, ensuring that programs preparing students for regulated practice are recognized.1
The letter emphasizes that ambiguity in defining eligible programs could jeopardize access to financing for future health profession students, ultimately straining the national workforce at a time when demand for care continues to grow.1
RISE Committee Reaches Consensus on Proposed Language
Following four days of negotiations in November, the RISE Committee moved to a final vote on the proposed regulatory language. All negotiators approved the draft, with the exception of the representative for military veterans, who abstained. Because consensus was reached, the Department of Education will adopt the negotiated language in the proposed rule.
The Department expects to release the official proposed rule in early 2026, followed by a 30-day public comment period. Members of the public—including professional associations, academic institutions, and individual practitioners—will have the opportunity to express support, raise concerns, or recommend alternative approaches.
The final rule is slated to take effect on July 1, 2026, unless otherwise adjusted by H.R. 1.
Next Steps for Audiology and Other Health Professions
The American Academy of Audiology plans to monitor the proposed rule closely and will submit comments during the public comment period. The Academy’s participation in PARCA underscores its commitment to ensuring that audiology students have equitable access to federal resources and that future audiologists are not disadvantaged by inconsistencies in federal definitions.
If adopted, the recommended changes would help ensure that audiology—and other essential health professions—are fully recognized as professional programs requiring advanced training and licensure. Advocates argue that doing so is necessary to sustain a robust pipeline of providers and protect patient access to high-quality care in communities nationwide.
Reference
1. Patient Access to Responsible Care Alliance (PARCA). Letter on Professional Degree Programs for H.R. 1 Implementation. October 30, 2025.
Source: AAA
