AIA’s formal comment accepted by the U.S. Department of Education

Federal comments submitted and posted

The Architecture Organizations Alliance, which includes AIA, the American Institute of Architecture Students, the Association of Collegiate Schools of Architecture, the National Architectural Accrediting Board, the National Council of Architectural Registration Boards, and the National Organization of Minority Architects, submitted formal comments on the U.S. Department of Education’s proposed rule implementing changes to federal student loan programs.

The letter urges the department to classify NAAB-accredited Master of Architecture (M.Arch) and Doctor of Architecture (D.Arch) programs as professional degree programs for federal borrowing purposes. The alliance’s comments explain that architecture clearly meets the criteria used to define other licensed professions because entry into practice requires:

• Completion of an accredited professional degree
• Documented supervised experience
• Passage of a national licensure examination

The coalition emphasized that failing to recognize architecture programs as professional degrees would misclassify a regulated profession, restrict access to required education, and undermine workforce pipelines that support housing production, infrastructure delivery, and economic growth.

The comments also outline several policy concerns with the proposed rule:

• Inconsistent standards: Some degrees currently listed as “professional” do not actually meet the department’s own criteria, while architecture degrees that do meet those criteria are excluded.
• Economic risk: Constraining access to architecture education would reduce the number of licensed architects, delaying projects and slowing development nationwide.
• Housing impact: Fewer architects would translate directly into slower housing production, higher development costs, and worsening affordability pressures.
• Equity implications: Lower federal loan limits would push students toward private loans or family financing, disproportionately affecting first-generation and underrepresented students.
• Market distortion: Loan caps do not reduce tuition or program costs in licensure-required fields; they simply shift the financial burden to students.

To address these concerns, the alliance recommended that the department adopt a flexible, criteria-based definition of “professional program,” delay implementation to prevent harm to current students, assess workforce and housing impacts, and support congressional action to modernize statutory loan caps. 

National coalition leadership

AIA also strengthened its coalition advocacy efforts by signing onto a national letter from the Advanced Professional Workforce Alliance, a network of approximately 75 organizations working to protect access to professional education across licensed fields.

AIA is expanding this coalition work through targeted advocacy outreach. This includes a joint action campaign encouraging stakeholders to contact federal policymakers in support of legislation affecting architecture students and the profession’s workforce pipeline.

Legislative priorities

AIA continues to advocate for three federal bills designed to ensure architecture students can access the financial resources required to complete their education and enter practice:

• H.R. 6574 — Equalizes federal loan caps between graduate and professional students.
• H.R. 6718 — Formally recognizes architecture as a professional degree for federal aid purposes.
• H.R. 6677 — Restores prior federal loan structures that supported professional education pathways.

You can send your Members of Congress a letter in support of this legislation here.

What’s next

AIA will continue working alongside coalition partners, higher education institutions, and policymakers to ensure federal regulations and legislation support the licensed professionals responsible for designing safe, resilient buildings and communities.

Members can expect additional opportunities to engage in advocacy as these efforts move forward.