Proposed Federal Rule Change Could Redefine Public Health Degrees and Limit Student Aid

The U.S. Department of Education has introduced a proposal that would significantly change how the federal government classifies “professional degrees,” a shift that could have major consequences for students pursuing careers in public health and other health-related fields. The draft regulation, released as part of a broader update to federal student aid policy, does not include Master of Public Health (MPH) or Doctor of Public Health (DrPH) programs in the revised definition of “professional” programs.

If adopted, the change could affect students’ access to federal borrowing levels and other benefits tied to professional degree status. Schools, students, and public health organizations are responding with concern, warning that the proposal could create new financial barriers at a time when the public health workforce is already strained.

What the Proposed Rule Would Change

Under the new proposal, the Department of Education would streamline and narrow the list of degree types categorized as “professional.” Historically, more than 2,000 degree types qualified; the new list includes fewer than 600.

Several health-related graduate programs are not included in the revised definition, including:

• Master of Public Health (MPH)

• Doctor of Public Health (DrPH)

• Master of Science in Nursing (MSN)

• Doctor of Nursing Practice (DNP)

• Master of Social Work (MSW)

• Doctor of Physical Therapy (DPT)

• Occupational Therapy degrees

• Audiology

• Speech-Language Pathology

Degrees excluded from the list would be subject to standard federal unsubsidized loan limits which is currently $20,500 per academic year. Many graduate programs in public health, nursing, and therapy exceed this cost, often ranging from $30,000 to more than $70,000 depending on the institution.

Without professional-degree borrowing levels, students could be forced to rely more heavily on private loans, which typically carry higher interest rates and fewer protections such as income-driven repayment or Public Service Loan Forgiveness (PSLF).

Why the Proposal Is Raising Concerns

Advocates say the change appears to undervalue fields that play a central role in community health, prevention, and health equity. The proposal arrives at a time when the public health workforce is still recovering from shortages, burnout, and high turnover linked to the COVID-19 pandemic. Many in the field worry that constraining financial aid would reduce the pipeline of future professionals.

The Department of Education argues that the revised definition is designed to clarify which programs prepare graduates for occupations requiring licensure or clearly codified professional competencies. Critics counter that public health, unlike medicine or law, is intentionally interdisciplinary and encompasses roles across government, community health, epidemiology, policy, environmental safety, and emergency response. The absence of a single licensing board does not reflect a lack of professionalization, they say, but rather the wide range of career paths within the field.

Public health leaders warn that the proposal sends an implicit message about the value of prevention. Although prevention work is less visible than clinical interventions, it remains central to controlling disease outbreaks, ensuring safe water and sanitation, reducing maternal and infant mortality, addressing environmental threats, and advancing health equity in underserved populations.

Implications for Students and the Workforce

Schools of public health, nursing, social work, and allied health programs could see broad effects if the rule is implemented. Experts point to four key areas of concern:

1. Financial Burden

Students may face funding gaps that federal loans no longer cover. While PSLF eligibility would continue for public service roles, students could need substantial private financing to complete their degrees.

2. Reduced Enrollment

Higher costs may deter students. particularly first-generation, low-income, and underrepresented minority students, from entering public health and related fields. This could worsen existing workforce shortages.

3. Impact on Workforce Capacity

Public health departments, community organizations, and government agencies rely on professionals with MPH and DrPH training. A decline in enrollment could limit recruitment for essential but historically lower-paid roles.

4. Symbolic Devaluation

Removing public health and similar degrees from the “professional” category could reinforce misconceptions that these fields are less critical to national health infrastructure.

Public health associations, university leaders, and workforce organizations are preparing formal responses during the federal comment period.

What Students and Professionals Can Do Now

Although the proposal is not final, students, faculty, and practitioners can take steps to understand its impact and make their perspectives heard.

1. Review Your Aid Eligibility

Current and prospective students should review their financial aid packages and understand how the proposed changes may affect federal loan access in the future.

2. Submit a Public Comment

The Department of Education is accepting public comments for a limited window. Individuals can submit feedback on Regulations.gov. Comments may include personal experiences, workforce concerns, and the importance of maintaining access to graduate education in public health.

3. Engage With Schools and Professional Organizations

Universities and public health organizations are preparing collective responses. Students and alumni can contact their department chairs, program directors, or deans to understand how their institution is addressing the issue.

4. Monitor Policy Updates

Final decisions may shift based on the volume and content of public comments. Following updates from schools of public health, workforce coalitions, and the Department of Education will help students stay informed.

Looking Ahead

The federal rule is still under review, and no final decision has been made. Public health leaders emphasize that the proposal underscores the continued need for advocacy around the value and visibility of the field. As national conversations around workforce shortages and health equity continue, stakeholders argue that supporting graduate training, not limiting it, is essential for building a resilient, prepared public health system.

BDOPro will continue monitoring developments and providing updates as the rule moves through the federal process.