02/17/2026
From National Association of Multicultural Rehabilitation Concerns (NAMRC)
Attention Colleagues,
The U.S. Department of Education (ED) is accepting public comments on a proposed rule that would revise how certain graduate programs are classified as “professional degree programs” for federal student loan purposes. If adopted in its current form, the proposal could limit access to higher federal Direct Loan borrowing for students in counseling-related pathways, making graduate education less affordable and potentially constraining the pipeline into the behavioral health workforce.
The comment period is open through March 2, 2026. NAMRC encourages rehabilitation counseling professionals, educators, students, and allies to submit comments describing the real-world impact of these changes on access, training, and workforce capacity.
Submit comments here (Regulations.gov):
https://www.regulations.gov/commenton/ED-2025-OPE-0944-0001
Why this matters for NAMRC and rehabilitation counseling
Counseling and rehabilitation counseling are licensed, clinically intensive professions that require graduate-level education, supervised training, and ongoing professional accountability. Reclassifying these programs in ways that reduce loan availability would likely:
• Increase financial barriers for future counselors and rehabilitation counselors
• Reduce entry into the profession, particularly for students from underserved and underrepresented communities
• Exacerbate behavioral health workforce shortages, including capacity to serve individuals with disabilities and complex support needs
Tips for submitting an effective comment
When writing your comment, consider including:
• Your role and perspective (e.g., rehabilitation counselor, counselor educator, graduate student, supervisor, administrator, employer)
• Professional training and licensure realities: highlight required graduate preparation, supervised clinical hours, credentialing, and scope of responsibility
• Concrete impact: how reduced federal borrowing would affect students’ ability to enroll/complete training, programs’ ability to recruit/retain students, and service access for the communities you serve
• Specificity matters: individualized, experience-based comments are typically more persuasive than generic form language
• Privacy reminder: avoid including sensitive personal information in public submissions