The American Institute of CPAs submitted a letter in response to the U.S. Department of Education’s proposal to exclude accounting from its definition of “professional degree” programs, urging it to adopt a more expansive definition.
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The letter, sent Friday to Secretary of Education Linda McMahon from AICPA president and CEO Mark Koziel follows up on an effort by the AICPA and leaders of other professions that were similarly excluded from the definition, including nursing, engineering and architecture, potentially reducing the amount of student loan aid available to graduate students enrolled in those degree programs. A negotiating committee convened by the Department of Education has proposed a definition that designates medicine, dentistry, law and several other high-cost programs as eligible for a $200,000 borrowing limit, but students who pursue a degree in other types of graduate or doctoral programs would be capped at $100,000 in federal loans.
Koziel spoke about the subject during a meeting last month of the Accountants Club of America and the letter comes after the Department of Education released a formal Notice of Proposed Rulemaking on “Reimagining and Improving Student Education.” in late January.
In his letter, Koziel said the AICPA appreciates that the department has now recognized a more expansive definition of the term “profession” by including in its summary of the notice with the following statement: “The designation, or lack thereof, of a program as ‘professional’ does not reflect a value judgment by the Department regarding whether a borrower graduating from the program is considered a ‘professional.’ This NPRM only interprets the phrase ‘professional student’ as used in the context of the loan limits established by the OBBB [One Big Beautiful Bill].”
However, he would like the department to go further. “While we appreciate this acknowledgment and clarification, the AICPA recommends that the Department incorporate similar language into its final rule that makes this intent clear within the Code of Federal Regulations itself,” he wrote.
In response to the notice, the AICPA is strongly encouraging the definition to explicitly include “accounting” or retain current language stating that, “professional degrees may include but are not limited to” the list included in the NPRM.
“Accounting is a profession,” said Koziel. “CPAs are state-licensed, subject to rigorous education requirements beyond a standard bachelor’s degree, validated by the Uniform CPA Examination and governed by ethics and competency standards. Furthermore, the accounting profession is an essential part of our nation’s economic stability, contributing to economic growth at the local, national and global levels. This fact is supported by more than 30 references throughout U.S. Code to terms such as ‘professional accounting’ standards, opinions and expertise.”
Other accounting organizations have also been pressing for changes in the definition in recent months before the Department of Education unveiled the formal notice, with the AICPA, the National Association of State Boards of Accountancy, state CPA societies, the American Accounting Association and other accounting organizations banding together to protest the move.
“Fundamentally, recognizing accounting programs as professional degree programs makes common sense,” Koziel wrote. “This recognition reflects the impact CPAs make on the lives of individuals, the health of communities and the integrity of financial systems, as well as the rigorous path taken to become a licensed Certified Public Accountant. Students pursuing this pathway should have equitable access to graduate-level financing, consistent with other recognized professional programs that serve critical public needs.”
Many state CPA societies are also submitting comments to the Department of Education, which plans to review and consider all of the comments that have been submitted before final regulations are implemented by July 1, 2026, in accordance with the One Big Beautiful Bill Act.
