The following public comment was submitted by the Society for Social Work and Research (SSWR) to the U.S. Department of Education in response to its proposed revisions to the definition of “professional degrees.” The Department is considering changes to this definition that would affect eligibility for federal student loan programs for graduate education. Social work has long been classified as a professional degree, which enables Master of Social Work (MSW) students to qualify for federal Direct Unsubsidized Loans and other essential forms of financial aid. However, under the proposed regulatory changes, social work would no longer satisfy the criteria for professional degree status, potentially limiting access to critical financial support for graduate students. These proposed changes arise at a time when the need for social workers is increasing across behavioral health, child welfare, schools, and community-based services, fields that are already experiencing substantial workforce shortages.
March 2, 2026
U.S. Secretary of Education Linda McMahon
U.S. Department of Education
Office of Postsecondary Education
400 Maryland Avenue SW, 5th floor
Washington, DC 20202
Re: Docket ID ED-2025-OPE-0944
Dear Secretary McMahon,
The United States is already experiencing significant behavioral health workforce shortages, and research shows these shortages translate directly into reduced access to care. National data show more than 810,000 social workers are currently employed nationwide across health, education, and community settings, providing over 60% of mental health treatment services in the United States.[1] Demand for behavioral health services continues to outpace workforce supply, contributing to delayed treatment, unmet need, and increased system costs. These impacts would be felt most acutely in rural communities, schools, hospitals, and safety-net systems already experiencing provider shortages.
Against this backdrop, the Society for Social Work and Research (SSWR) appreciates the Department of Education’s efforts to create clear and consistent criteria defining professional degrees. However, excluding the Master of Social Work (MSW) from the professional degree definition is inconsistent with empirical evidence, workforce realities, and public health needs.
SSWR represents researchers dedicated to generating and translating evidence that improves social, behavioral health, and policy outcomes. The proposed rule would significantly weaken the pipeline of graduate-trained social workers who are central to the nation’s behavioral health system and would ultimately reduce access to mental health care for millions of Americans.
Our comments address how the Department applied its professional degree definition and demonstrate that MSW degrees meet the Department’s three-part test. As the proposed regulation notes, “OBBB establishes a three-part test” for defining a “professional degree,”[2] and the comments below outline how the MSW degree satisfy each element, beginning with completion of academic requirements for entry into professional practice.
I. Master of Social Work Degree Meet the Statutory Tests for Professional Degrees
Research and labor market data demonstrate that the MSW degree meets all three elements of the professional degree test established by OBBB.
Completion of academic requirements for entry into professional practice
Clinical social work practice, which includes mental health diagnosis, psychotherapy, and independent treatment planning, requires graduate education. Federal labor data consistently recognize the master’s degree as the required credential for clinical social work practice.[3]
Further, social workers are not a peripheral component of behavioral health care. Social workers provide over 60% of mental health treatment services in the United States, across a range of settings (e.g., hospitals, schools, in partnership with law enforcement) making graduate-trained social workers essential to system capacity.[4]
Skills beyond the bachelor’s level
Workforce studies show that the scope and intensity of clinical service provision increases substantially with graduate training. For example, more than 61% of clinical social workers serve clients with mental health disorders, compared with lower shares at lower educational levels, and nearly 79% of clinical social workers serve as direct service providers delivering treatment.[5]
This demonstrates that graduate education is not simply additive; it fundamentally changes scope of practice, service intensity, and clinical responsibility.
Licensure and independent authorization to practice
Across all U.S. jurisdictions, independent clinical social work practice requires graduate education plus supervised post-degree training and licensure. The existence of bachelor’s-level licensure does not allow independent clinical practice and does not authorize diagnosis or psychotherapy in most states. Thus, the graduate degree is the functional entry point for independent professional practice for clinical social workers.
II. Excluding the MSW Degree Mischaracterizes Clinical Social Work as a “Specialization”
The proposed rule incorrectly characterizes clinical social work as a specialization rather than a distinct regulated professional authorization.
Research and regulatory evidence show that clinical social work functions as a distinct professional practice domain with separate licensure, scope, examinations, and federal provider recognition. Clinical social workers function as independent behavioral health providers across health care, schools, community mental health, and private practice settings.
This structure parallels other professions included in the rule (e.g., clinical psychology) in training intensity, supervision requirements, and independent treatment authority.
III. The Rule Would Reduce Mental Health Access and Worsen Workforce Shortages, Especially in Rural America
The United States is already experiencing significant behavioral health workforce shortages, and decades of workforce research demonstrate that provider supply is directly linked to access, wait times, and treatment continuity. Graduate-trained social workers comprise the largest segment of the nation’s behavioral health workforce and are essential to meeting growing mental health needs across health systems, schools, community agencies, and private practice.
In many regions of the country, particularly rural communities, licensed clinical social workers are the only independently practicing mental health providers available. Rural counties are disproportionately designated as Mental Health Professional Shortage Areas[6], and social workers often fill critical gaps where psychiatrists and psychologists are scarce. Reducing financial access to MSW education by limiting student loan access would constrict the pipeline of independently licensed providers, disproportionately affecting rural communities where workforce margins are already thin and recruitment challenges are significant. Fewer graduate-trained social workers would mean longer travel distances for care, increased wait times, greater reliance on emergency departments, and higher rates of untreated mental health conditions.
Evidence consistently shows that workforce shortages translate into delayed treatment, unmet need, and increased downstream health and social costs[7]. Policies that limit access to graduate social work education will therefore not only affect students but will measurably reduce service capacity in underserved communities.
At a time when national demand for mental health and substance use treatment continues to rise, restricting federal loan eligibility for MSW students risks exacerbating provider shortages and undermining access to care, particularly in rural, low-income, and historically underserved areas.
IV. Financial Barriers to Graduate Education Directly Affect Mental Health Access
Limiting federal loan eligibility by excluding MSW degrees from professional classification would reduce graduate enrollment and disproportionately affect low-income students and students of color, groups already more likely to rely on federal student loans to complete graduate social work education.
Because social workers provide the majority of mental health services in many community settings, reductions in the graduate training pipeline would translate into measurable reductions in service capacity and increased unmet need for treatment.
V. Public Health and Economic Implications
Reduced access to graduate social work education would:
- Decrease supply of independently licensed behavioral health providers
- Increase wait times for mental health services
- Reduce service availability in rural, school-based, and safety-net settings
- Increase downstream costs associated with untreated mental health conditions
Research demonstrates that social workers reduce hospital readmissions, improve community stability, and serve high-need populations across health and human service systems.[8]
VI. Recommendation
SSWR strongly urges the Department to:
- Include the Master of Social Work degree in the definition of professional degrees
- Maintain federal loan eligibility pathways that support entry into behavioral health professions
- Consider workforce research demonstrating the central role of graduate-trained social workers in national mental health infrastructure
Conclusion
Social workers are foundational to the U.S. behavioral health system. Excluding the Master of Social Work degree from professional classification contradicts workforce data, licensure structures, and decades of research on service delivery and access to care.
Given rising mental health needs nationwide and existing workforce shortages, policies that restrict access to graduate social work education risk exacerbating already significant public health challenges.
These comments are submitted on behalf of the Society for Social Work and Research (SSWR), the premier international professional membership organization dedicated to advancing, disseminating, and translating rigorous social work research. SSWR represents a global community of over 2,000 scholars, faculty, research scientists, practitioners, policy experts, and doctoral and master’s students who are committed to generating knowledge that improves social conditions and promotes equity and well-being.
[1] U.S. Bureau of Labor Statistics – Social Work: https://www.bls.gov/ooh/community-and-social-service/social-workers.htm
[2] “Reimagining and Improving Student Education,” A Proposed Rule by the Education Department on 01/30/2026: https://www.federalregister.gov/documents/2026/01/30/2026-01912/reimagining-and-improving-student-education
[3] U.S. Bureau of Labor Statistics – Social Work: https://www.bls.gov/ooh/community-and-social-service/social-workers.htm
[4] Health Resources and Services Administration, Bureau of Health Workforce. State of the Behavioral Health Workforce, December 2025: https://bhw.hrsa.gov/data-research/review-health-workforce-research
[5] Association of Social Work Boards. 2024 Social Work Workforce Study: https://www.aswb.org/workforce-data-now-available-to-social-work-researchers/
[6] Health Resources and Services Administration, Bureau of Health Workforce. State of the Behavioral Health Workforce, December 2025: https://bhw.hrsa.gov/data-research/review-health-workforce-research
[7] National Conference of State Legislatures, April 29, 2024: https://www.ncsl.org/labor-and-employment/behavioral-health-workforce-shortages-and-state-resource-systems
[8] National Library of Medicine. “Interprofessional collaboration between social workers and community health workers to address health and mental health in the United States: A systematized review”: https://pmc.ncbi.nlm.nih.gov/articles/PMC10675993/