Advocacy Update on Federal Definition of "Professionals"
AIA Advocacy has been working with partner organizations and legislators to make progress towards both including architects in the federal definition of 'professionals,' and in passing legislation on student loan caps to ensure affordable education.
The Department of Education’s narrow interpretation of ‘professional programs’ under the One Big Beautiful Bill Act threatens to exclude architecture students from higher federal loan limits–limiting access to graduate education in our field. AIA is working to ensure that architecture maintains its rightful place among recognized professional programs and that future architecture students can afford the education path that’s best for them.
To-the-Date Timeline
July, 2025: The One Big Beautiful Act (OBBBA) is signed into law, establishing new annual and lifetime loan limits for graduate students at $20,500 annually and $100,000 in aggregate, with higher limits for “professional” programs, which the bill left to the Department of Education to define. The Department of Education announces RISE and AHEAD negotiated rule-making panels to implement the OBBBA provisions.
October, 2025: The RISE Committee completes its first negotiated rule-making session on financial aid-related program changes.
November, 2025: The RISE Committee finishes negotiations. The Department of Education interprets “professional program” narrowly, limiting the designation to only the ten legacy fields and excluding architecture, and many other professions. This interpretation excludes approximately 93% of all graduate programs from higher borrowing limits.
November 21 and 24, 2025: AIA issues a statement and a member briefing on the issue, opposing the Department of Education’s restrictive interpretation and calling for architecture to be recognized as a professional program.
Coming Soon: Sometime before the final rule is released, there will be a period for public comment on the definition of “professional degree.”
July 31, 2026: The rule will go into effect, barring delays.
Why This Matters for Architecture
Students pursuing advanced Architecture degrees typically face substantial educational costs amidst the higher education cost crisis in America. Under the Department’s narrow interpretation, architecture students would be limited to borrowing only $20,500 annually for graduate degrees in Architecture. For many students who lack personal or family resources, these limits would make graduate architecture education financially out of reach, and/or force them into high-interest, low-flexibility private loans–which would only exacerbate the student loan crisis.
Architecture has long been recognized as a professional field requiring specialized education and state licensure. The National Architecture Accrediting Board (NAAB) accredits professional architecture programs, and all 50 states require candidates to earn a NAAB-accredited degree before pursuing licensure. Excluding architecture from the progressional program designation ignores this reality and contradicts Congressional intent to support workforce-critical fields.
The bottom line: the cost of higher and post-graduate education is a well-known crisis in America. This policy will do nothing to reduce costs. It will, however, punish students who lack the funding to pay for post-graduate education out of pocket; it will limit their choices of institutions to attend; and it will force them into high-interest private loans which will only worsen the student debt crisis in this country.
How AIA is Responding
Legislative Action
AIA is supporting two pieces of legislation. First, Rep. Torres (NY-15)’s Professional Degree Access Restoration Act cleanly repeals the changes to student loan limits thus reverting them back to “full cost of attendance."
Rep. Lawler (NY-17)’s Professional Student Degree Act designates several degrees, including the masters in architecture, as professional for purposes of loans. This legislation would provide clear statutory language directing the Department of Education to use objective criteria–such as accreditation requirements, state licensure mandates, and workforce necessity–when determining which fields qualify as professional programs, and therefore, for higher limits on federal loans to pursue post-graduate degrees of study ($50,000 per year).
For the time being, AIA is pursuing both legislative avenues as we work with coalition partners to try to advance them through Congress. You can contact your member of Congress and ask them to support for both pieces of legislation.
Engaging in the Regulatory Comment Period
AIA is actively partnering with organizations inside and outside the AEC industry to engage with the public comment period, which will open sometime this spring. It’s hard to say exactly when that public comment period will open, but we’ll be ready when it does.
AIA will submit a formal comment, explaining why architecture meets every reasonable criterion for professional program status and why the Department’s interpretation contradicts both the statutory text and Congressional intent. We’ll work with some related groups to submit formal comments from different corners of the architecture ecosystem. We’ll also be organizing architecture schools, students, and practitioners to submit their own comments demonstrating the real-world impact of this policy.
Public comments provide an important record that can influence the final rule and support potential legal challenges or legislative action if the Department proceeds with its narrow interpretation.
What You Can Do
Contact your Congressional representatives: Tell your Representatives and Senators that architecture should be recognized as a professional program, and that you support the Lawler and/or Torres legislation. Share your own experience with graduate architecture education costs and the importance of accessible federal loans.
Prepare to submit public comments: Think about how this rule would’ve affected you, other architects you know, or future architects. Plan to submit a public comment and share this article with your fellow architects and encourage them to do the same.
Share your story with us: We are seeking architects with personal experience using federal loans to pay for MArch or DArch degrees to inform our advocacy. If you’re a recent graduate, current student, or faculty member, share how reduced loan limits of $20,500 per year would impact the ability to pursue an advanced architecture degree. Email your story to govaff@aia.org.
Engage your school: Encourage your architecture school Dean and university leadership to join the advocacy effort and coordinate with other affected institutions.
For questions about AIA’s advocacy work on this issue, please contact govaff@aia.org