Friday Audiogram: Who Counts As A Professional Degree?

Jill Desjean, Director of Policy Analyss at the NASFAA joins us as we unpack how a legacy definition of professional degrees now shapes graduate loan limits and why that affects the pipeline for licensed clinicians. We map the rulemaking timeline, pinpoint the public comment window, and outline how targeted advocacy can expand recognition for audiology, SLP, and other fields.

• the current definition of a professional degree and its criteria
• how a statistical category became a funding gate
• constraints regulators faced when Congress pointed to old definitions
• why audiology and SLP may have been omitted
• what negotiated rulemaking and public comment allow
• the loan burden realities for clinical students
• workforce shortages in hearing care and patient impact
• practical steps to submit effective comments and contact Congress

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Chapters

• 0:00 Defining A Professional Degree
• 1:47 History Of The Definition And Loan Caps
• 3:14 Why Audiology And SLP Were Omitted
• 4:22 How Rulemaking And Comments Work
• 6:40 Debt Realities And Workforce Gaps
• 8:10 Rallying Advocacy Across Health Fields

Transcript

Blaise M. Delfino, M.S. - HIS : 0:00

So, Jill, under the new regulatory definition, as described by the U.S. Department of Education and the Reimagining and Improving Student Education Committee, RISE negotiations, what are the precise criteria that a degree program must meet to qualify as a professional degree?

Jill Desjean: 0:22

Sure. So buckle up. I'm going to read this to you because it is precise to your point. So a professional degree is a degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor's degree. That's the first thing. Generally requires professional licensure to begin practice, and includes a four-digit program SIP code or classification of instructional programs code. I'm sure we'll talk about that later, as assigned by the institution or determined by the Secretary of Education in the same intermediate group as a set of fields that have already been defined as professional degrees by the Department of Education many, many years ago. And so those include pharmacy, the PharmD, dentistry, veterinary medicine, chiropractic, law, medicine, optometry, osteopathic medicine, podiatry, theology, and clinical psychology. It's a lot.

Blaise M. Delfino, M.S. - HIS : 1:27

It is. And Jill, am I correct in saying that perhaps there are some unintended consequences as it relates to the semantics of this current policy as it relates to professional licensure?

Jill Desjean: 1:41

Yeah, yeah. You know, it this definition is a it's it's a it's got a very long history. Sort of, you know, a long, long time ago, the Department of Education created a definition for purposes completely unrelated to what the definition is being used for right now. Um, an arm of the Department of Education called the National Center for Education Statistics was using this just to classify programs for reporting purposes, for statistical purposes. They never envisioned this as being a way to distinguish who can borrow how much money. Congress then, when they wrote the One Big Beautiful Bill Act, decided for the first time ever to distinguish different types of graduate programs and to say these programs, students should be able to borrow X dollars, these very specific programs, students should be able to borrow more. They pointed to this existing regulatory definition that was not created for these purposes and said, here's something to use as a guide. So, you know, the Department of Education did have their hands tied a bit because Congress was explicit in pointing to that definition. So they had to, when they were deciding what's a professional program, they had to say what's kind of like what's already in there. They couldn't just start with a fresh list because Congress pointed to that definition. So they had to find other programs. If they were going to add other programs, they had to find things that shared all those same common characteristics as the programs in that definition, if that makes sense.

Blaise M. Delfino, M.S. - HIS : 3:01

I was just about to say that makes total sense. And we'll get into it a little bit later in this interview, but there will be a comment period where uh my colleagues, SLPs and AUDs, will be able to contact their elected officials. Jill, given your experience and your role as director of policy analysis, why do you suspect that feels like audiology, speech language, pathology, physical therapy were omitted? So we have this definition, but could could our elected officials that were putting this language together, even the uh Department of Education, could we have reached out to certain advisors to talk about the unintended consequences? And what does that process look like?

Jill Desjean: 3:46

Yeah, yeah. So the the process, you know, advocacy is um, there's a lot of ways to engage in advocacy. You mentioned this opportunity for public comment. And that is a, you know, the great thing about all of this, this rulemaking process is that it is transparent, it is open, it is public. You know, Congress passes a law, they require agencies, in this case the Department of Education, to draft implementing regulations. So to sort of fine-tune, you know, Congress cannot be expected to be experts on every little thing, but we've got all these executive agencies that are experts. And so the Department of Education knows education. They say, here's what we want you to do. Go ahead and write implementing regulations to, you know, here's the what, you do the how, basically. And that's what the Department of Education did through this rulemaking committee, which are public, you know, they're they're um they're live streamed, their people can attend in person. I was there, you know, um, they are transparent, they bring in stakeholders, so they're bringing in people from different constituency groups that may be impacted. Um, interestingly, you know, there was someone at the negotiating table that represented psychology programs, and psychology is included in that group. Financial aid administrators, who were very impacted by a lot of these changes, because we have to work with all of them, you know, with the students who are enrolled in these programs, were not included at the table. So, you know, the decisions about who's there, you know, are not always on point. But when, you know, the committee votes, they have to all agree to basically can we live with this or not. But after that step, it's not just like this is done. Then the Department of Education has to go out to everyone, to all Americans and say, what do you think? So they will open this public comment period. We're hoping January, we really are, you know, we're hoping to see this. Um, all this needs to be operationalized by July 1. So we really want to see regular, you know, this finalized quickly so schools can actually start doing what they need to do. But this public comment process is your opportunity to say, this doesn't make any sense. Hey, help us out here. Um, another great way to advocate is at the level of Congress. They passed this law, but you know, Congress makes laws, Congress changes laws. So, you know, you can still go, you know, there are many opportunities to say, we think you were off the mark here. Go to your elected officials and say, this is how this impacts me, this change to the law. We don't know if you meant to do this. Did you really mean for the department to just stick with those 11 programs that they have? Or did you mean for them to kind of use that as a framework and expand on that? And did you think audiology should have been in there? And, you know, Congress could go back and be a little more prescriptive. They could change the law and say, hey, department, you know, we meant there for you to, you know, use those programs that were already defined and to throw some more in there, but you stuck to the ones that were already defined. So um, yeah, so lots of different places where you can go to advocate for the field that you're in that um, you know, anything that's of interest to you.

Blaise M. Delfino, M.S. - HIS : 6:33

And Jill, I'm I'm so excited about the advocacy opportunity because when this was first released, of course, usually emotions as humans they can run high and you get upset. And really taking that pragmatic approach of, okay, this was just released on social media. Let us actually review the language. What does the language say? So, first and foremost, your article helped my understanding tremendously, so thank you. Um, but also when you dive deeper into the language, the overarching theme here is that student loan debt. Okay, and and we're not going to go into how that affects the economics of the situation by any means, but I went to school for speech language pathology. I initially went to a private school and then ended up graduating from East Strasburgh University of Pennsylvania. I graduated with a little bit over$100,000 in student loan debt, but those were private loans. So, of course, interest rate was a little bit higher. So I'm speaking from experience to not only my colleagues, but also those wanting to enter the field of speech language pathology and audiology. And before we hit record today, I was sharing with you some statistics. You know, there's uh over 50 million Americans that present with hearing loss on an audiogram, another 26 million Americans that present with normal hearing yet struggle to understand speech in noisy situations. But there's only 20,000 about hearing care professionals to serve those in our country who present with hearing loss. So the unintended consequences of this uh specific policy is that there might be students who would say, well, if I can't get a cap of 200,000 for my professional degree because audiology and speech language pathology, speech language pathology, you can get a master's, but you can also get a doctorate. And then the AUD degree is a doctoral level degree and both prepare students for clinical practice and requires a licensure. So I'm excited as it relates to the advocacy aspect of it because we have the opportunity to really rally the troops in SLP, AUD, also PT, OT, nursing to comment and share. We are a professional degree and we hold licensure, and let's work together.