Professional Degree Designation Notice of Proposed Rulemaking Comment

WASHINGTON – The National Women’s Law Center, along with the Lawyers’ Committee for Civil Rights Under Law, the Legal Defense Fund (LDF), and 48 other partner organizations submitted a public comment urging the Department of Education to reject a proposed definition of which post-baccalaureate degrees qualify as “professional” for student loan limit purposes. 

The comment cites data from the U.S. Department of Education revealing that the professional degrees excluded from the Department of Education’s proposed definition of “professional” are predominantly held by women. For example, in 2021-2022, women held over 75 percent of master’s and doctorate degrees for registered nursing, social work, teaching, and public health, and held at least 90 percent of master’s degrees for audiology, occupational therapy, and dental hygiene. The comment emphasizes that Black students also will be especially harmed by the proposed definitions as they rely on student loans at disproportionately high rates due to systemic inequities.

“The Department’s proposal will ensure that fewer women and students of color, and particularly Black women, are able to pursue graduate study in these programs,” the NWLC and its partner organizations said in their comment. “The only option many students will have is taking out private loans, which often have less favorable terms and protections than federal loans, compounding the effects of the gender pay gap and race-based wealth disparities.”

“The Trump administration is offering tens of thousands in student loan forgiveness and sign-on bonuses to encourage individuals to work at ICE– an agency that terrorizes, kidnaps, attacks, and murders our neighbors. At the same time, they are working to make it more difficult for women and Black students to pay for their education,” said Shiwali Patel, senior director of education justice at NWLC. “This is a devastating reminder of just how little this administration values students who want to teach, nurse, and care for their communities after completing higher education.” 

“The Department’s proposed definition of professional degree is narrow, exclusionary, and would disproportionately harm Black students and communities,” said Ashley Harrington, Senior Policy Counsel at LDF. “Combined with new graduate loan limits, it would further restrict Black and low-income borrowers from entering fields like education, nursing, and social work at a time of severe workforce shortages and community need. Because many Black borrowers have long been discriminatorily excluded from private lending, federal loans are often their only pathways to these careers. These limits would deepen inequities, cut off social mobility, and weaken the pipeline of professionals serving Black communities.”

“Graduate education financing does not exist in a vacuum. Black students, women, and low-income communities have long faced discrimination in both education and lending,” said Chazz Robinson, Education Policy Advisor at Lawyers’ Committee for Civil Rights Under Law. “Policies that narrow access to federal loans risk entrenching historic inequities rather than dismantling them, particularly at a time when families and communities across the country are already struggling with rising costs. The Department of Education has both the opportunity and responsibility to implement these provisions in ways that protect access and advance equity.”

The comment period closes March 2.

Organizations that joined NWLC, LDF, and the Lawyers’ Committee for Civil Rights Under Law in signing onto the comment include:

AFL-CIO
AFT: Education, Healthcare, Public Services
American Association of University Women (AAUW)
American Atheists
American Civil Liberties Union
American-Arab Anti-Discrimination Committee (ADC)
Arizona Students’ Association
Center for Law and Social Policy (CLASP)
Clearinghouse on Women’s Issues
Coalition on Human Needs
Council of Parent Attorneys and Advocates (COPAA)
Delta Sigma Theta Sorority, Incorporated
ED-OCR Alumni Collective
End Rape On Campus
Equal Rights Advocates
Feminist Majority Foundation
Healthy Teen Network
Illinois Coalition Against Sexual Assault
Institute for Women’s Policy Research
International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW)
Japanese American Citizens League
Just Solutions
Labor Council for Latin American Advancement (LCLAA)
League of United Latin American Citizens (LULAC)
Legal Momentum, The Women’s Legal Defense and Education Fund
NAACP
National Action Network
National Alliance for Partnerships in Equity
National Association of Social Workers
National Black Justice Collective Institute
National Council of Asian Pacific Americans
National Down Syndrome Congress
National Education Association
National Employment Law Project
National Nurses United
National Organization for Women
National Urban League
National Women’s Political Caucus
Planned Parenthood Federation of America
PowHer New York
Protect Borrowers
Service Employees International Union
Southwest Women’s Law Center
The Center for Learner Equity
The Leadership Conference on Civil and Human Rights
UltraViolet Action
Women Employed
Women’s Law Project