Implications of Recent Department of Education Budgeting for Professional Case Management 

By Dr. Ellen Fink-Samnick DBH, MSW, LCSW, ACSW, CCM, CCTP, CRP, FCM 

There has been considerable chatter about the Department of Education ruling outlining which educational degrees are recognized as "professions." According to the proposed guidelines, only certain "professional degree" programs will qualify for future federal loan eligibility, significantly narrowing access to essential funding for master's and doctoral education in many health and behavioral health disciplines. 

The bottom line: any applicants entering programs that are outside of the defined "professional" category could be subject to lower loan caps: 

• Graduate program loans are limited to $20,500 per year, with an aggregate maximum of $100,000, whereas professional degree loans are eligible for up to $50,000 per year and a $200,000 cap. 
• The proposal eliminates the Grad PLUS loan program, which students across medicine, law, and other related fields previously used. 
• New limits for the Parent PLUS program restrict borrowing to $20,000 per student annually, with a cumulative cap of $65,000. 

While defining "professional degree" status is positioned as a strategy to mitigate student loan debt, several critical concerns have emerged. These funding restrictions disproportionately impact workforce development, counter equity efforts, and devalue recognition—especially for professions heavily comprised of women, racial and ethnic members, and often serving marginalized communities. Experts also warn that such limitations hinder efforts to diversify and expand participation in these vital professions and further limit access to care for those who need it most.  

This proposed ruling could also exacerbate existing shortages in the healthcare workforce, which are already facing challenges related to retention, stability, and sustainability. The move has also prompted warnings from across the industry about the proposed ruling's threat to public health capacity with respect to patient safety. The efficiency and effectiveness of the Quintuple Aim will be grossly impacted. Decreased workforce capacity will mean an inability to deliver patient-centric care in a timely, cost-conscious manner, higher rates of clinician burnout, and greater challenges to access to care. Healthcare users deserve far better. 

Background 

These issues stem from the 1965 Federal Law, which defines a "professional degree" as one that signifies completion of academic qualifications and advanced skills beyond the bachelor's level. The original list identified ten degrees: 

1. Dentistry (D.D.S. or D.M.D.) 
2. Veterinary Medicine (D.V.M.) 
3. Chiropractic (D.C. or D.C.M.) 
4. Law (L.L.B. or J.D.) 
5. Medicine (M.D.) 
6. Optometry (O.D.) 
7. Osteopathic Medicine (D.O.) 
8. Pharmacy (Pharm.D.) 
9. Podiatry (D.P.M., D.P., or Pod.D.) 
10. Theology (M.Div., or M.H.L.) 

Current Impact 

The professions excluded from this designation are integral to Professional Case Management. Except for Medicine and Pharmacy, most of the qualifying fields cited in CMSA's (2022) Standards of Practice A are omitted from the list. Although initial lists in the 1965 law did not include nursing, present-day implications are far more critical.  

The accreditation bodies, credentialing organizations, regulatory authorities, and professional associations representing counseling, nursing, occupational therapy, physical therapy, respiratory therapy, speech-language pathology, and social work have all strongly opposed. The nursing organizations were among the first to advocate publicly. Their varied entities, each with oversight of the workforce, have aligned to advance a petition calling for action. This list includes, but is not limited to: 

• Academy of Medical-Surgical Nurses 
• American Association of Colleges of Nursing  
• American Association of Critical-Care Nurses  
• American College of Nurse Midwives 
• Emergency Nurses Association 
• National Association of Clinical Nurse Specialists 
• National Council of State Boards of Nursing  
• National League for Nursing 
• American Nurses Credentialing Center  
• American Nurses Association  

Social work leaders have similarly responded and implemented their petition, collaborating through: 

• The Council on Social Work Education  
• The National Association of Social Workers  

Other organizations advancing advocacy include: 

• The Association of Schools & Programs of Public Health  
• The American Organization of Nursing Leadership  
• The American Occupational Therapy Association  
• The American Public Health Association  
• DNP's of Color 
• The New York Academy of Medicine has highlighted the collaborative nature of healthcare and expressed concerted support for its interprofessional colleagues. 

Recommended Actions 

First, the Department of Education is expected to issue a Notice of Proposed Rulemaking (NPRM) in the Federal Register to initiate a formal public comment period beginning in January 2026. All interested and involved parties are strongly encouraged to submit comments advocating for the inclusion of additional disciplines as "professional" degrees. 

Next, all professionals should utilize both individual and collective advocacy channels. Several petitions are already on the move, with ANA's being the largest at this time, and accessible here. In particular, the CMSA Public Policy Committee is well-positioned to collaborate with major professional organizations, including: 

• American Counseling Association 
• American Nurses Association 
• American Occupational Therapy Association 
• American Physical Therapy Association 
• National Association of Social Workers 
• American Speech and Language Pathology Association 

Case management's professional workforce has consistently achieved its most successful outcomes through collective, collaborative action. There must be a concerted effort to urge the Department of Education to revise the proposed definition of 'professional degrees' and explicitly include our health and behavioral health disciplines. Only then will the industry be able to sustain itself with a diverse workforce able to manage all populations best.  

The Department of Education’s proposed ruling would drastically cut federal loan access for nursing, social work, counseling, therapy, and other essential graduate programs. These fields form the core of professional case management, and limiting funding threatens the workforce, reduces diversity, and puts coordinated patient care at risk.

We need your voice. Write or call your legislators, sign your professional organization’s petitions, and prepare to submit comments when the public comment period opens in January. Protect access to the advanced education our healthcare system depends on.

Bio: Dr. Ellen Fink-Samnick is an award-winning industry entrepreneur whose focus is on professional case management, health equity, interprofessional ethics, quality, and trauma-informed leadership. She is a content-developer, professional speaker, author, and educator who is a faculty member, academic advisor, the Culminating Project lead and IRB coordinator for the Doctoral of Behavioral program at Cummings Graduate Institute of Behavioral Health Studies. Dr. Fink-Samnick is a member of the Professional Case Management Journal editorial board and editor of the journal’s HeartBeat of Case Management department. She also serves in national leadership and consultant roles across the industry, including as the current Chair for CMSA’s DEIB Core Committee.