Comment Period Closed. Take Action: Submit Public Comment on Federal Student Loans

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Letter Template for Student Loan Comments Public Comment Process Guide Tips for Submitting Effective Public Comments

As of March 3, 2026, the public comment period for this proposed rule is now closed. Please see below for the public comments AAMFT submitted. Thank you for your attention to this important issue. AAMFT will provide additional information when the Department of Education publishes the final rule – likely in the late spring. Please contact FamilyTEAM@aamft.org if you have any questions related to the rulemaking process.

On March 2, AAMFT submitted a public comment letter to the Department of Education, which can be found here. AAMFT’s comments emphasized that an MFT degree meets the definition of “professional degree” as referenced in H.R. 1, as well as the harm to clients, graduate students, and providers that will occur if the final rule adopted by ED continues to exclude MFTs from the definition of “professional degree.” AAMFT also signed onto three other letters to the Department of Education opposing the exclusion of MFTs and other healthcare providers from the definition of “professional degree” programs. These letters were submitted in coalition with other associations and healthcare provider organizations. They are linked below.

A letter from the Mental Health Liaison Group, which can be found here.
A letter from a coalition of MFT, mental health counseling, and social work organizations, which can be found here.
A letter from the Advanced Professional Workforce Alliance, which can be found here.

On January 30, the federal Department of Education (ED) released a proposed rule titled “Reimagining and Improving Student Education” that includes major changes to federal student loan programs. In this proposed rule, ED offers a definition of “professional degree” that excludes MFTs and many other healthcare graduate programs. If adopted, this rule will have a significant negative impact on the MFT profession. As expected, the proposed rule is not substantively different from what ED initially proposed last fall. For additional details, please see AAMFT’s detailed summary of the proposed changes to federal student loan programs.

It is essential for MFTs to ensure their voices are heard during the rulemaking process. AAMFT strongly encourages all MFTs (and other interested parties) to submit comments to the Department of Education on this proposed rule. Comments are due by March 2 and should state how this proposed rule will harm all Americans by significantly reducing access to behavioral healthcare.

AAMFT is providing resources to help simplify the process for submitting public comments. We recommend taking the following steps to submit your comment:

1. 1. View the short 7-minute video below that provides an overview of this issue and how to get involved.
  2. Review the “Tips for submitting public comments” available in the resources section.
  3. Download the template letter, available in the resources section.
  4. Personalize the template letter with your information and personal story. Make sure to personalize and update any section with [BRACKETED TEXT].
  5. Review the “Step by step public comment directions” available in the resources below.
  6. Navigate to https://www.regulations.gov/ and follow the step-by-step directions to upload your public comment.

It is vital for MFTs to have access to the same student loan resources as other healthcare professions. Thank you for participating in this advocacy effort, and please contact FamilyTEAM@aamft.org if you have any questions about this process.