SSWR Talking Points, Script and Call to Action: Protect Social Work as a Professional Degree
Background:
The Department of Education has updated its definition of “professional degrees,” a classification that determines federal student loan eligibility for graduate programs. Although social work has long been recognized as a professional degree, the proposed rule would exclude social work, limiting MSW students’ access to federal graduate loans. This change comes at a time of escalating demand for social workers across behavioral health, child welfare, education, and community-based services—fields already facing critical workforce shortages.
SSWR, in partnership with the Social Work Leadership Round Table, is advocating to ensure social work retains its professional degree status and continued access to federal financial aid.
Talking Points:
- Why This Matters: The proposed rule would reclassify social work and restrict MSW students’ access to federal loans. Reduced access to graduate education will worsen workforce shortages and limit access to essential services nationwide.
- Impact On Students: Many MSW students depend on federal loans to complete their education.
- On Communities: Social workers are the largest segment of the U.S. mental health workforce.
- On Public Systems: Workforce shortages increase recruitment and turnover costs for public agencies. Weakened service systems ultimately raise costs for taxpayers.
- What We Are Calling For: Retain social work in the Department of Education’s final definition of professional degrees. Preserve equitable access to federal student loans for MSW students. Strengthen, not restrict, pathways into social work education.
- Additional Policy Priorities: Expand federal grants, training programs, and loan repayment options. Protect and grow key funding streams, including Pell Grants, HRSA scholarship and loan repayment programs, and the Behavioral Health Workforce Education and Training (BHWET) Program.
- Bottom Line: Excluding social work from the professional degree definition will harm students, communities, and public systems. Recognizing social work as a professional degree is essential to meeting the nation’s mental health and social service needs.
Member Action: Submit Comments to the Department of Education
The final rule has been released and public comment is open until March 2, 2026. SSWR members are strongly encouraged to submit comments.
How to submit comments?
- Find the “Reimaging and Improving Student Education” proposed rule here.
- Click “Submit a Comment” and upload or paste your response.
What to include in your comment (sample script below):
- Review this document: Commenting Guidance: How You Can Effectively Participate in the Regulatory Process Through Public Comment
- Share personal or institutional experience (e.g., teaching, supervising students, practicing, or hiring social workers).
- Clearly state that social work must be included in the definition of professional degrees.
- Explain how reduced loan access would affect:
- MSW students and affordability
- Workforce shortages in mental and behavioral health
- Access to services in rural and underserved communities
Writing an Effective Public Comment
Public comments are most influential when they are clear, specific, and grounded in real-world experience. You do not need to be a policy expert. What matters most is explaining why the proposed rule matters and how it affects people, systems, and communities.
Strong comments often include the following elements:
- Who you are and why you’re commenting
Briefly introduce yourself and your connection to the issue. This might include your role (student, practitioner, educator, administrator), your field, or your experience with graduate education or the workforce. - What part of the rule you are addressing
Clearly identify the aspect of the proposed rule you are responding to (for example, changes to the definition of “professional degree” or new graduate loan limits). - How the rule affects people, programs, or services
Explain the real or anticipated impacts. This may include effects on students’ ability to enroll or complete degrees, workforce shortages, access to care, or unintended consequences the Department may not have fully considered. Citing research, workforce data, or professional standards strengthens your comment. - What you recommend instead
Offer concrete suggestions, such as revising definitions, maintaining specific loan programs, or aligning financing policy with workforce needs. Specific recommendations are especially helpful to agencies. - A brief closing summary
Restate your main concern and recommendation, and thank the Department for considering public input.
Tip: Comments are public and searchable. Use your own voice, be respectful, and cite sources where possible to increase credibility.
Purpose of These Comments
The goal of these comments is to ensure the Department of Education understands the implications of the RISE rule from the perspective of social workers and social work education. Your comment helps document how federal student loan policy directly affects the behavioral health workforce and access to essential services.
The example below is a template, not a script. Please adapt the language, add your own experience, and tailor it to reflect your perspective.
Sample Public Comment (Template)
Dear U.S. Department of Education,
Thank you for the opportunity to submit comments on the proposed revisions affecting which graduate programs are classified as “professional degrees” and the accompanying changes to federal graduate loan limits. I am writing as a (role/student status) to express serious concern about how these changes will affect social work education, workforce capacity, and access to behavioral health services.
Recommendation
I respectfully urge the Department of Education to reconsider the changes made in Section 81001(2) of the One Big Beautiful Bill Act, which amends Section 455(a) of the Higher Education Act and revises the definitions of professional student, professional degree, and length of study. Specifically, licensed, master’s-level social work programs should retain recognition as professional degrees for the purposes of federal graduate lending.
Social workers constitute the largest group of the behavioral and mental health workforce in the United States and play essential roles across health care, child welfare, aging services, schools, and community-based systems (Bureau of Labor Statistics [BLS], 2025; Health Resources and Services Administration [HRSA], 2023). While bachelor’s-level social work programs provide important entry points, most clinical and advanced practice roles require a Master of Social Work degree and state licensure, without which graduates are limited to entry-level positions with restricted scope of practice and earning potential (Council on Social Work Education [CSWE], 2025; NASW, 2021). Graduate education in social work is both intensive and costly due to specialized curricula and required field education, and restricting access to federal loan options will further deter prospective students from entering an already strained workforce pipeline (GAO, 2022; NASFAA, 2025).
Independent clinical social work licensure across states requires completion of an accredited MSW program and extensive supervised practice, commonly totaling approximately 1,000 hours (CSWE, 2025). These internships are frequently unpaid, limiting students’ ability to earn income while enrolled and increasing reliance on student loans to complete required training (Drechsler et al., 2023; Leslie, 2025). Reducing federal loan access under these conditions exacerbates financial barriers and underscores the need for expanded repayment and forgiveness options for students entering public-interest careers.
Social workers are indispensable to the health and well-being of individuals, families, and communities nationwide. Graduate-level training is a foundational requirement for professional practice and licensure. I urge the Department to maintain social work’s recognition as a professional degree, designate MSW students as professional students for federal lending purposes, and ensure that student loan policies support entry into this critical profession.
Conclusion
Social workers form a cornerstone of the nation’s behavioral health workforce, and a master’s degree is required for the licensure necessary to practice in clinical and advanced roles (BLS, 2025; HRSA, 2023). Reclassifying social work degrees and limiting graduate loan access will significantly constrain workforce entry and reduce access to essential services. Thank you for your time and consideration of this comment.
Sincerely,
[Your Name]
[City, State]
References
Bureau of Labor Statistics [BLS]. (2025, August 8). Social workers: Occupational outlook handbook. U.S. Department of Labor. https://www.bls.gov/ooh/community-and-social-service/social-workers.htm
Council on Social Work Education [CSWE]. (2025). Social work education in the U.S.: Annual survey of social work programs. https://www.cswe.org/research-statistics-0a2756984f2446870db6e935f0e44221/annual-survey-of-social-work-programs/
Drechsler, K., Beasley, C., & Singh, M. (2023). Critical conversations in compensating social work field education: A systematic review. International Journal of Social Work Values & Ethics, 20(2), 169–199. https://doi.org/10.55521/10-020-209
Government Accountability Office [GAO]. (2022). Behavioral health: Available workforce information and federal actions to help recruit and retain providers (GAO-23-105250). https://www.gao.gov/products/gao-23-105250
Health Resources and Services Administration [HRSA], National Center for Health Workforce Analysis. (2023). Behavioral health workforce brief. https://bhw.hrsa.gov/sites/default/files/bureau-health-workforce/Behavioral-Health-Workforce-Brief-2023.pdf
Leslie, A. F. (2025). Paid placements in social work: Addressing inequity and student well-being. Families in Society: The Journal of Contemporary Social Services. Advance online publication. https://doi.org/10.1177/10443894241310635
National Association of Student Financial Aid Administrators [NASFAA]. (2025). You have questions, we have answers: Making sense of the student loan changes from OBBBA’s RISE committee. https://www.nasfaa.org
National Association of Social Workers [NASW]. (2021). Blueprint of public policy priorities. https://www.socialworkers.org