Proposed Definition of "Professional Degree" Programs Would Exclude Audiology and Speech-Language Pathology

Update: December 2, 2025

Ensuring students can access the financial support they need is essential to maintaining a strong audiology and speech-language pathology workforce. ASHA continues to advocate for clear federal definitions that protect graduate student loan eligibility. Learn more in this recent article featuring ASHA’s advocacy.

November 21, 2025

To implement the student loan provisions in the One Big Beautiful Bill Act (OBBBA), the U.S. Department of Education (ED) has proposed a definition of a "professional degree" program that does not include audiology or speech-language pathology. This definition determines eligibility for student lifetime loan limits—$100,000 for graduate students versus $200,000 for "professional degree" students.

ASHA highlighted these new loan limits in our initial summary when OBBBA passed. Since then, we’ve been advocating for audiology and speech-language pathology to be included in the final regulations. Our efforts to date include:

• Educating ASHA members on key higher education provisions in OBBBA
• Leading and signing multiple coalition letters to ED
• Engaging career officials and political appointees within the Administration
• Meeting with key members of Congress and urging them to call on ED to include our professions
• Launching a targeted action alert to members of Congress
• Mobilizing more than 300 participants at ASHA’s Capitol Hill Day on November 19 to raise this issue during their congressional meetings.

ASHA remains committed to securing higher loan limits for audiology and speech-language pathology students and will continue to provide opportunities for ASHA members to take action. Our goal is clear: ensure these programs are explicitly recognized as "professional degrees" so that students have access to the financing they need to pursue their careers.

New Federal Student Loan System Under OBBBA

OBBBA made significant changes to the federal student loan program. Key changes include:

• Eliminating Graduate PLUS loans, which allow students to borrow up to the full cost of attendance
• Establishing new annual borrowing caps for undergraduate and graduate students
• Setting different lifetime loan limits for graduate students ($100,000) versus "professional degree" students ($200,000)

OBBBA did not define "professional degree." Instead, it referred to an existing regulatory definition that lists several health professions as examples and some law and theology programs. These examples did not include audiology or speech-language pathology.

After passage of OBBBA, ASHA joined a broad coalition of other providers—including the National Alliance of Specialized Instructional Support Personnel [PDF], the Patient Access to Responsible Care Alliance [PDF], and a broad coalition of organizations [PDF]—urging ED to adopt a more detailed and updated definition that explicitly includes audiology and speech-language pathology programs.

Regulatory Process

Because the new loan limits take effect on July 1, 2026, ED is moving quickly to develop new regulatory language, including a more precise definition of "professional degree" programs.

As part of the regulatory process, ED convened a "negotiated rulemaking" committee of stakeholders to develop draft regulations. ED’s initial proposal would have limited a "professional degree" to those already listed in the specified examples. Committee members raised significant concerns and, with ASHA’s input, proposed an expanded definition that would have included audiology and speech-language pathology.

Ultimately, the negotiated rulemaking committee reached consensus on a narrower definition that added programs that were most "closely related" to the existing examples but added clinical psychology programs. It excludes audiology, speech-language pathology programs, and many related professions—including occupational therapy and physical therapy.

Because the committee reached consensus, ED is legally required to formally propose this definition in its forthcoming rule. However, ED may modify the definition in the final regulation based on public comments.

How to Take Action

ED is expected to publish a Notice of Proposed Rulemaking in January. This will initiate a 30-day public comment period. During this comment period:

• ASHA will submit comments explaining why audiology and speech-language pathology degrees are closely aligned with programs included by the committee, making the case that these degrees warrant higher loan limits.
• ASHA members will have the opportunity to provide comments on this proposed regulation.

Public input will be critical. Following the comment period, ED may publish a final rule as written, revise the definition, or make updates and issue a new proposed rule for public comment.

Impact on Students

Under the proposed regulation:

• New loan limits will apply to loans borrowed for enrollment periods beginning on or after July 1, 2026.
• Students may continue borrowing under the existing Graduate PLUS program until that date.
• Current loan limits will remain in place for students who are enrolled in a program of study as of June 30, 2026, and are continuing in the same program.

The new loan limits apply only to federal student loans. They do not change eligibility for other federal financial aid programs, including grants or loan forgiveness opportunities. They also do not impact Medicare or Medicaid reimbursement policies, nor do they affect state licensure requirements.

Questions?

ASHA will continue to share updates as the regulatory process moves forward. For questions or additional information, email Eric Masten, ASHA’s director of federal affairs for education, at emasten@asha.org.