The U.S. Department of Education has proposed changes in how graduate students are able to access student loans. Degree programs would be designated as either "graduate" or "professional." Students enrolled in programs leading to "graduate degrees" would have a lifetime loan limit of $100,000 while the limit would be $200,000 for those pursuing "professional degrees." As written, the proposed regulation neither specifically includes or excludes audiology or speech-language pathology in the professional degree category. However, if speech-language pathology and audiology are not ultimately included in the list professional degrees, then we can expect significant limits on lifetime loans. These limitations would make it more difficult to pursue careers in the professions, and may worsen pre-existing personnel shortages.
You can take action on this important issue by submitting a public comment to the Federal Register for review before March 2, 2026.
The letters below are fully editable. Please feel free to add additional research, data and professional experiences that illustrate your concerns. We have been advised to emphasize the alignment of our professions with the <a href="https://www.federalregister.gov/documents/2026/01/30/2026-01912/reimagining-and-improving-student-education#p-128" target="_self">proposed operating definition</a> of professional degree and to generate examples of return on investment for treatment of communication, swallowing and hearing difficulties.&nbsp;
After you have submitted your comment, we will provide you with information about how to contact your elected officials on this important matter.&nbsp;
Sources: <a href="https://www.asha.org/news/2025/proposed-definition-of-professional-degree-programs-would-exclude-audiology-and-speech-language-pathology/?srsltid=AfmBOoqIb9_NrFIQyZ3eJeVYoGT4HB1mWewebweiQlmj2EhdVhBkC-FZ" target="_self">ASHA</a>, <a href="https://www.federalregister.gov/documents/2026/01/30/2026-01912/reimagining-and-improving-student-education#p-128" target="_self">Federal Register</a>&nbsp;
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Keep SLPs and Auds listed as "professional degrees": Protect Access to Student Loans

Excluding speech-language pathologists and audiologists from the list of “professional degrees” would create significant barriers for students seeking to enter these fields. This exclusion would ultimately harm Americans by limiting access to essential speech, language, and hearing services.

These services promote long-term independence and quality of life while also reducing overall healthcare costs by improving medical outcomes. For example, use of hearing aids has been shown to reduce the risk of dementia (Cantuaria ML et al.), and timely treatment for swallowing disorders can lower hospital readmission rates related to pneumonia (Lin FR et al.).

Shortages of speech-language pathologists and audiologists already exist across schools, hospitals, and community-based programs nationwide, limiting access to care and negatively affecting individuals and families every day. Failing to recognize these professions as professional degrees would further worsen these shortages.

I urge you to recognize the critical role of speech-language pathologists and audiologists and to avoid policies that would make it more difficult to obtain degrees in these vital fields.

Citation 1: Cantuaria ML et al. Hearing Loss, Hearing Aid Use, and Risk of Dementia in Adults. JAMA Otolaryngology–Head & Neck Surgery. 2024.
Citation 2:  Lin FR et al. Hearing intervention versus health education control to reduce cognitive decline in older adults with hearing loss. The Lancet (ACHIEVE trial). 2023.

Submit a Comment to the Federal Register

Pennsylvania Speech-Language-Hearing Association

I would like to recommend that speech-language pathologists and audiologists be explicitly included in the list of "professional degrees."

Speech-language pathologists and audiologists play a critical role in supporting communication, feeding and swallowing, hearing and overall quality of life across the lifespan. These licensed professionals require 2-3 years of education beyond the bachelor's degree, in order to obtain licensure and begin work in the field. These requirements align with the 3 part operating definition defined in the regulation under section 685.102.

There is a growing demand for these professionals across a backdrop of a preexisting shortage.  For 2024-2034 the US Bureau of Labor statistics predicts growth of 15% for speech language pathologists and 9% for audiologists, much faster than average for both fields. 

Failure to list speech-language pathology and audiology within the list list of professional degrees will make it much harder to pursue careers in these fields, by limiting the availability of student loans. This will exacerbate the existing shortages in these fields and ultimately reduce access to care for Americans. 

Thank you for your consideration.

Speech Language Pathology and Audiology Should be Included in Professional Degrees

Not including SLPs and audiologists from the list of "professional degrees" will prevent students from pursuing careers in these fields. This will harm Americans by making it harder to access speech, language services and hearing. These services promote long term independence and quality of life, and save money by improving medical outcomes. For example, use of hearing aids reduced the risk of dementia (Cantuaria ML et al.), while treatment for swallowing disorders can reduce the risk of hospital re-admissions due to pneumonia (Lin FR et al). There are already shortages of these professionals in many schools, hospitals and community-based programs, which harm Americans every day. Please recognize the important work of these professionals and don't worsen the shortage by making it harder to get a degree in these important fields.

Citation 1: Cantuaria ML et al. Hearing Loss, Hearing Aid Use, and Risk of Dementia in Adults. JAMA Otolaryngology–Head & Neck Surgery. 2024.
Citation 2:  Lin FR et al. Hearing intervention versus health education control to reduce cognitive decline in older adults with hearing loss. The Lancet (ACHIEVE trial). 2023.

Keep SLPs and Audiologists on the List of Professional Degrees

I have personal experience working with individuals with communication, hearing and swallowing difficulties, and have witnessed how services from a licensed professional in communication, hearing and swallowing can improve individual quality of life, employment, health and independence.  For example, individuals with traumatic brain injury who are receiving speech and language services are twice as likely to  be employed one year post injury and 45% less likely to live in a nursing home. Individuals with swallowing disorders who receive treatment from a speech-language pathologist have reduced hospital stays, and reduced g-tube placements, among other positive outcomes. Access to early identification of hearing loss through audiology services reduces the need for special education services. Inclusion of speech-language pathology and audiology in the list of professional degrees in section 668.2 is critical to ensure adequate numbers of professionals in these fields for Americans to reap the positive health outcomes and cost savings of these services. 
Sources: 
https://www.asha.org/siteassets/ebp/dov/value-of-slps-in-pediatric-feeding-and-swallowing-disorders.pdf
https://www.asha.org/research/ebp/demonstrating-your-value/value-of-cognitive-rehabilitation-for-adults-with-acquired-brain-injury/
https://thehearinginstitute.org/future-children-hearing-loss/#:~:text=Reduction%20of%20funding%20could%20potentially,5

Professional Degree List Should Include Speech Pathologists and Audiologists

I respectfully recommend that speech-language pathology and audiology be explicitly included in the list of “professional degrees.”

Speech-language pathologists and audiologists play an essential role in supporting communication, feeding and swallowing, hearing, and overall quality of life across the lifespan. These licensed professionals complete two to three years of graduate education beyond a bachelor’s degree to obtain licensure and enter the workforce. This level of preparation aligns with the three-part operating definition outlined in the regulation under Section 685.102.

Demand for these professionals continues to grow amid an already well-documented workforce shortage. The U.S. Bureau of Labor Statistics projects employment growth from 2024–2034 of 15 percent for speech-language pathologists and 9 percent for audiologists—both significantly faster than the average for all occupations.

Excluding speech-language pathology and audiology from the list of professional degrees would create additional barriers to entering these fields by limiting access to student loans. Such barriers would further exacerbate existing workforce shortages and ultimately reduce access to critical services for individuals and families across the United States.

Thank you for your consideration.

Supporting Workforce Access by Recognizing SLP and Audiology as Professional Degrees

Protecting Access to Speech, Language, and Hearing Services

I have firsthand experience working with individuals who have communication, hearing, and swallowing disorders, and I have seen how services provided by licensed professionals in these areas significantly improve quality of life, employment outcomes, health, and independence.

For example, individuals with traumatic brain injury who receive speech and language services are significantly more likely to achieve stable employment after injury, as communication ability is a strong predictor of vocational success (Meulenbroek & Turkstra, 2016; Meulenbroek et al., 2022). Individuals with swallowing disorders who receive treatment from a speech-language pathologist experience shorter hospital stays, reduced incidence of aspiration pneumonia, fewer gastrostomy tube placements, and other positive health outcomes (Kaylor & Singh, 2023; PMCID, 2020). In addition, access to early identification and intervention for hearing loss through audiology services improves language outcomes in children, supporting better academic achievement and reducing the need for later special education services (Grey et al., 2021; Korver et al., 2010).

Including speech-language pathology and audiology in the list of professional degrees under Section 668.2 is essential to ensuring a sufficient workforce to meet the needs of Americans. Doing so will allow individuals to continue benefiting from improved health outcomes, greater independence, and meaningful cost savings across healthcare and education systems.

Grey, B., Holcomb, M., & Smith, K. (2021). Impact of meeting early hearing detection and intervention guidelines on language outcomes in children with hearing loss. Journal of Early Hearing Detection and Intervention, 6(2), 45–56. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9447840/

Kaylor, S. A., & Singh, S. A. (2023). Clinical outcomes associated with speech, language, and swallowing difficulties post-stroke. South African Journal of Communication Disorders, 70(1), 1–10. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10623651/

Korver, A. M. H., Smith, R. J. H., Van Camp, G., Schleiss, M. R., Bitner-Glindzicz, M., Lustig, L. R., ... & Wuyts, F. L. (2010). Newborn hearing screening and developmental outcomes. JAMA, 304(15), 1701–1708. https://jamanetwork.com/journals/jama/fullarticle/186749

Meulenbroek, P. J., & Turkstra, L. S. (2016). Communication ability and stable employment after moderate–severe traumatic brain injury. Disability and Rehabilitation, 38(12), 1168–1175. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5308217/

Meulenbroek, P., Turkstra, L., & Wang, A. (2022). The speech-language pathologist’s role in return to work for adults with traumatic brain injury. American Journal of Speech-Language Pathology, 31(5), 1985–1998. https://pubs.asha.org/doi/10.1044/2021_AJSLP-21-00129

PMCID. (2020). Speech-language pathology evaluation is associated with decreased mortality in hip fracture patients with dysphagia. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC12494601/

Recognizing Speech-Language Pathology and Audiology as Professional Degrees