✯ Professional designations from the US Department of Education ✯

Dear Michigan Counselors,

We want to provide clarity about the recent concerns circulating online regarding the U.S. Department of Education’s (DOE) proposal to redefine “professional degree” programs as part of implementing the One Big Beautiful Bill Act (OBBBA).

The DOE Proposal:

• Does NOT affect state licensure, nor will it put counselors out of business
• Does NOT change scope of practice of counselors
• Does NOT de-legitimize counseling work
• Does NOT affect Medicare, TriCARE, Medicaid, or private insurance reimbursements

What Is Happening

OBBBA, passed in July 2025, eliminated the Grad PLUS loan program and replaced it with the Repayment Assistance Plan (RAP). Under RAP:

• Graduate students may borrow up to $20,500 per year and $100,000 total.
• Professional students may borrow up to $50,000 per year and $200,000 total.

The law requires DOE to define which programs qualify as “professional” and therefore qualify for the higher loan limits. Importantly, this designation is not related to whether a program leads to licensure or professional recognition—it only determines the amount of federal guaranteed student loans available to students while enrolled in the program.

On November 6, 2025, DOE released a proposed definition.

How DOE Defines “Professional Degree” Under the Proposal

A professional degree must:

• Be generally at the doctoral level
• Require six years of postsecondary study
• Require professional licensure
• Share a Classification of Instructional Programs (CIP) code with one of the following fields:
• Medicine (M.D., D.O.)
• Dentistry (D.D.S., D.M.D.)
• Law (J.D.)
• Pharmacy (Pharm.D.)
• Veterinary Medicine
• Chiropractic
• Optometry
• Podiatry
• Theology (M.Div.)
• Clinical Psychology (Ph.D. or Psy.D.)

Master’s-level mental health counseling programs do not meet this definition. As noted above, this rule only affects the amount of federal guaranteed student loans available ($20,500 per year, $100,000 maximum).

What This Means for Counseling Students

If finalized:

• Students in master’s-level counseling programs will be capped at $20,500 per year and $100,000 total in federal loans, regardless of program cost.
• This is not a reclassification of the profession itself—only a decision about federal loan eligibility categories.
• Students pursuing doctoral-level counseling psychology may qualify for the higher cap.

Why This Matters

Some counseling programs cost more than $20,500 per year. Students may need to seek private loans or other funding sources to cover remaining costs.

The Proposal Is Not Final

This proposal must go through a public comment process before final rules are issued (expected spring 2026). Comments influence DOE’s decisions and become part of the official record.

What You Can Do

• Submit a public comment when the portal opens
• Share your story about how federal loans supported your education
• Contact your federal and state lawmakers to express your perspective

Your voice matters. We will continue to advocate for our profession and keep members informed as updates become available.

Thank you for all you do for your clients, communities, and the mental health workforce.

If you are a current member of MMHCA, thank you! If you are not a current member of MMHCA, we ask that you consider becoming one by going HERE and joining. We are a volunteer run organization and membership dues allow us to have a lobbyist, advocate for counselors and provide other counselor benefits.

If you have questions please email us at MMHCABOARD@MMHCANOW.ORG.

With appreciation and warm wishes,

MMHCA’s Board of Directors

Christopher DeBoer, President

Krystin Sankey, Treasurer

Carol Berger, Secretary

Members at Large:

Dr. Stephanie Burns

Dr. Joy Creel

David Flowers

Dr. Katherine James

Dr. Larry Pfaff

Lauri Rowe

Amy Szaraz

Dr. Elizabeth Teklinski

Steve Wheeler

Links you may find useful:

Our website MMHCANOW.org

Counseling Compact Website

MMHCA’s LinkedIn group

MMHCA's YouTube channel

MMHCA's FaceBook page.

Please follow us!

FAQ

Q1. Did DOE say counseling is “not a professional degree”? No. The issue is about how DOE categorizes programs for loan limits under the new law.

Q2. Does this proposal change licensure, scope of practice, or professional standing? No. It does not affect:

• State licensure requirements
• Scope of practice
• Professional title
• Clinical authority
• Recognition under state law

Q3. Will this affect insurance reimbursement? No. Insurance reimbursement is determined by CMS, TriCARE, commercial insurers, and state laws—not DOE loan classifications.

Q4. Why is this change happening now? Because OBBBA eliminated Grad PLUS loans and created new borrowing caps. DOE must define who qualifies for the higher “professional” limits.

Q5. What counts as a “professional degree” under the proposal? Doctoral-level programs requiring six years of study, licensure, and CIP codes in fields such as medicine, law, pharmacy, theology, or clinical psychology.

Q6. What are the new borrowing limits?

• Graduate programs: $20,500/year (max $100,000)
• Professional programs: $50,000/year (max $200,000)

Q7. How would this affect counseling students? Master’s-level counseling students would be limited to $20,500/year in federal loans.

Q8. Is the proposal final? No. Final rules are expected spring 2026 after public comments.

Q9. Can public comments influence the outcome? Yes. DOE must review and respond to substantive feedback.

Q10. Does this affect current borrowers? No. It applies to new borrowing starting July 1, 2026.

Q11. Do counseling psychology doctorates qualify for the higher loan cap? Yes. Doctoral programs under CIP code 42.28 (clinical, counseling, and applied psychology) qualify.