February 18, 2026
The Department of Education issued a proposed rule that would define “professional student” for purposes of determining federal student loan amounts based on the type of program in which a student is enrolled.
Under the proposal, “professional students” would be those enrolled in one of 11 designated professional degree programs: pharmacy, dentistry, veterinary medicine, chiropractic, law, medicine, optometry, osteopathic medicine, podiatry, theology and clinical psychology. Students enrolled in these programs would qualify for up to $50,000 in federal loans per year, with a $200,000 aggregate limit. All other graduate students would be eligible only for up to $20,500 in federal student loans per year, with a $100,000 aggregate limit.
This narrow definition of “professional degree programs” leaves out art therapy as well as many other critical health professions, from nursing and physical therapy to social work. At a time when our nation is experiencing health care workforce shortages, this will further hinder access to care.
Art therapists and art therapy students have relied on federal loans to help pay for their graduate education. If these rules are finalized, art therapy students would not be able to borrow more than $100,000 through federal student loans beginning July 1, 2026.
Take Action
Here are some steps you can take to voice your concerns:
1. Take the survey about your experience with student loans. We will use the feedback form the survey for our advocacy efforts.
2. Write your own letter with your student loan experience to submit as a comment to the Department of Education. You can use the template below, but please personalize it. Regulations.gov, which receives the letters and posts them publicly, urges individuals to not submit templated “form” letters.
Once you’re on the regulations.gov webpage for “Reimagining and Improving Student Education,” click on the blue “Comment” button to submit your letter. Please keep in mind that these letters are publicly available and in the record. All comments are due March 2.
SAMPLE TEMPLATE
Dear Education Secretary McMahon:
Thank you for the opportunity to provide public comments on the Reimagining and Improving Student Education proposed rule (Docket ID ED-2025-OPE-0944).
I am an art therapist [OR ART THERAPY STUDENT] based in [STATE]. I am writing to my express concerns about how this proposed rule affects the art therapy profession, as well as other allied health fields. Student loans are essential for professionals entering these fields to attain a master’s or doctorate degree. Lower borrowing limits will discourage potential students from enrolling in art therapy programs, reducing the pipeline of future professionals, which will only reduce access to mental health care and patient choice, especially for rural and underserved communities.
Art therapists are mental health professionals who are required to obtain a master’s degree or higher, a credential (ATR or ATR-BC) from the Art Therapy Credentials Board, and 1,000 hours of clinical experience in order to be licensed to practice.
I relied on federal student loans in order to obtain my degree. [IN YOUR OWN WORDS, PLEASE EXPLAIN HOW FEDERAL STUDENT LOANS SUPPORTED YOUR PATH TOWARD EARNING YOUR DEGREE. IF THESE LOANS WEREN’T AVAILABLE, WHAT WOULD YOU HAVE DONE?]
At a time when we need more mental health professionals providing care to communities across the country, this proposed rule would harm our nation’s mental health and well-being. [DISCUSS WHERE YOU WORK, INCLUDING WORKPLACE SETTING OR WHICH COMMUNITIES YOU WORK WITH]
I strongly urge the Department of Education to update the final rule to include art therapists and other mental health professions in the list of fields in the professional degree definition.
Thank you for considering my comments.