The Department of Education RISE Final Rule: What It Means for Counseling

The Department of Education has finalized the Reimagining and Improving Student Education (RISE) rule, implementing strict new borrowing caps for graduate students effective July 1, 2026. For prospective Counseling students, it is a disappointing outcome, as Counseling did not receive the coveted “professional degree” classification. Current Mental Health Counseling students may benefit from limited interim exceptions if they are already enrolled and adhere to requirements.

On May 1, 2026, NBCC released a statement opposing the final rule.

Understanding the final rule and available exceptions is essential for anyone considering or currently pursuing a master’s degree in Counseling.

The Core Problem: Counseling Excluded from “Professional Degree” Classification

The final RISE rule classifies graduate programs into two categories: “professional degrees” and standard “graduate degrees.” This classification determines federal loan limits.

• Professional degree students: $50,000 annually / $200,000 lifetime
• Graduate degree students: $20,500 annually / $100,000 lifetime

Mental Health Counseling—along with social work, marriage and family therapy, nursing, physical therapy, and physician assistant studies (and many other professions)—did not receive the “professional degree” designation. This means Counseling students are capped at $20,500 annually, far below the cost of many graduate Counseling programs.

What This Means in Practice

A student in a 2-year, full-time counseling program with $35,000 annual tuition faces a significant gap. Federal loans cap at $20,500/year; that leaves $14,500 annually uncovered. Over 2 years, the gap totals $29,000—money that must come from savings, family support, private loans, or student employment. For students from working-class backgrounds, rural areas, or first-generation college families, this gap may be insurmountable. Many students will be forced to choose between pursuing Counseling or more affordable career paths.

Elimination of Grad PLUS Loans

Making matters worse, the rule eliminates the Grad PLUS loan program for new borrowers starting July 1, 2026. Previously, Grad PLUS loans allowed students to borrow up to the full cost of attendance—filling the gap between federal loan caps and actual program costs.

Without Grad PLUS, students must rely on private loans (typically 10%–14% interest) or find other sources of funding. Private loans lack the forgiveness, deferment, and repayment protections of federal loans.

Interim Exception for Currently Enrolled Students

There is limited relief. The final rule maintains an interim exception for students already enrolled in programs as of June 30, 2026.

Borrowers who meet all of the following requirements will retain pre-RISE borrowing limits:

• You were enrolled in a program of study as of June 30, 2026.
• You received at least one direct federal loan (or parent received Parent PLUS loan) for that program before July 1, 2026.
• You remain enrolled at the same institution and pursuing the same degree after July 1, 2026.
• You maintain continuous enrollment.

If you qualify, you retain:

• access to Grad PLUS loans up to full cost of attendance.
• pre-RISE federal loan limits (higher than the new caps).
• this exception for either 3 academic years or the difference between expected program length and completed coursework, whichever is shorter.

This is meaningful relief for currently enrolled students, but only if they received federal loans before the July 1, 2026, deadline and remain continuously enrolled.

New Repayment Options

The final rule also introduces streamlined repayment plans effective July 1, 2026.

Tiered Standard Plan (Fixed Payment):

• < $25,000 debt: 10-year repayment
• $25,000–$49,999: 15-year repayment
• $50,000–$99,999: 20-year repayment
• = $100,000: 25-year repayment

Repayment Assistance Plan (Income-Based):

• payments at 1%–10% of discretionary income, adjusted for family size
• $50-per-dependent deduction
• unpaid interest waived for on-time payments
• qualifies for Public Service Loan Forgiveness (PSLF)

For Counselors pursuing public service careers (community mental health, schools, nonprofits), the income-based RAP plan with PSLF eligibility may provide meaningful relief.

What Prospective Counseling Students Should Know

If you’re considering a Counseling master’s degree, the final RISE rule means the following:

1. Federal loans are insufficient: $20,500 per year won’t cover most programs. Plan for significant out-of-pocket costs or private loans.
2. Grad PLUS is gone: The safety net that previously filled gaps is eliminated for new borrowers.
3. Timing matters: If you enroll before July 1, 2026, you may qualify for the interim exception. After July 1, the stricter limits apply.
4. Diversify funding: Explore scholarships, employer tuition assistance, employer-sponsored graduate programs, and part-time work options.
5. Consider program structure: Look for programs offering assistantships, scholarships, or reduced tuition for graduate students.
6. Understand private loan implications: If you use private loans, understand the higher interest rates, lack of forgiveness programs, and absence of income-based repayment options.

Implications for Mental Health Counselors

Implication 1: The Counseling Workforce Pipeline Is at Risk

The lower federal loan limits will likely reduce enrollment in Counseling master’s programs, particularly among students from low-income backgrounds who cannot afford the tuition gap. This will worsen the already critical shortage of Mental Health Counselors.

Counselors and Counselor Educators should:

• advocate for Counseling’s inclusion as a “professional degree” in future regulatory reviews or legislation. Counseling meets criteria for professional degree classification; advocating for that inclusion is essential.
• support loan affordability legislation: The Mental Health Workforce Student Loan Affordability Coalition is advocating for legislation to address this issue.
• develop alternative funding models: Counselor Education programs should explore scholarships, assistantships, and employer partnerships to offset the federal loan gap.
• engage with accreditation bodies: CACREP monitors impacts on program enrollments and graduation rates to advocate with federal agencies about workforce implications.

The financial barriers created by the RISE rule threaten to reduce the pipeline of qualified Counselors entering the profession at a time of unprecedented demand.

Implication 2: Currently Enrolled Students Must Act Now

For students currently enrolled in Counselor Education programs, the interim exception provides critical relief, but only if they meet all requirements and act quickly.

Currently enrolled Counseling students should:

• verify your qualification: Confirm that you were enrolled before June 30, 2026, received federal loans before July 1, and understand the continuous enrollment requirement.
• maximize Grad PLUS access: If you qualify for the exception, borrow Grad PLUS funds while available. The full-cost-of-attendance borrowing option is valuable.
• remain continuously enrolled: Understand that gaps in enrollment may disqualify you from the exception. Plan your coursework accordingly.
• understand your repayment timeline: The exception lasts for 3 years or the remaining program length, whichever is shorter. Know when your higher loan access expires.
• explore income-based repayment: When you graduate, the income-based RAP plan may provide meaningful relief, especially if you pursue public service positions eligible for PSLF.

For currently enrolled students who qualify, the interim exception is significant relief. But students must understand requirements and act while the option is available.

NBCC’s Advocacy Effort: A Fight for Professional Recognition

NBCC and numerous professional organizations submitted detailed comments urging the Department of Education to classify Clinical Mental Health Counseling, Professional Counseling, marriage and family therapy, and related behavioral health pathways as “professional degree” programs. In addition, on Jan. 15, 2026, we held a packed congressional briefing to outline the problem and solutions for members and staff.

NBCC’s Case for Professional Degree Classification

NBCC’s comments demonstrated that Counselor Education programs meet all statutory criteria for professional degree classification:

• Graduate Entry and Licensure: Counseling is a graduate-entry profession requiring a master’s degree and supervised clinical preparation before independent practice.
• Specialized Training: Programs require 48–60+ credit hours of graduate coursework with specialized knowledge in mental health assessment, diagnosis, treatment planning, crisis intervention, and trauma-informed care.
• Supervised Clinical Training: Programs include 600–1,000+ hours of supervised clinical practice (practicum and internship), comparable to medical residencies.
• Postgraduate Supervision: Licensure requires 2,000–4,000 hours of postdegree supervised practice, adding 1–2 years of structured professional development.
• State Licensure Requirement: All 50 states require licensure (LPC, LMHC, LCPC, etc.) for independent practice.This is a legal requirement, not optional.
• Accreditation Standards: Programs accredited by the Council for Accreditation of Counseling and Related Educational Programs (CACREP) demonstrate rigorous, consistent professional standards.
• Federal Recognition: Medicare, Medicaid, the Department of Veterans Affairs, and TRICARE recognize licensed Counselors as eligible mental health providers.
• Inconsistent Application: The rule includes clinical psychology (when doctoral), veterinary medicine, chiropractic, and podiatry—some of which have arguably less rigorous requirements or narrower scope than Counseling.

NBCC argued that excluding Counseling while including other comparable professions is arbitrary and inconsistent. We urged the department to adopt explicit, objective criteria (accreditation standards, terminal degree status, supervised clinical training, licensure requirements, scope of independent practice) and apply them consistently across all professions.

NBCC also raised concerns that classifying Counseling as “nonprofessional” would signal to third-party payers, credentialing entities, and employers that Counseling is less rigorous or less legitimate than included professions. Such a misrepresentation could harm Counselor participation in insurance networks and employer recognition.

The Department’s Response: Rejection Without Substantive Explanation

Unfortunately, the Department of Education declined NBCC’s recommendations. In its final rule, the department stated that it “declines to treat counseling as a professional degree program.” The department’s reasoning was notably brief: It invoked Congress’s cross-reference to the existing definition of professional degree in regulations (34 CFR 668.2), implementing a “bounded framework for title IV loan limit administration” rather than developing new criteria based on “contemporary accreditation, licensure structure, terminal degree status, workforce need, or parity with other graduate clinical fields.”

In other words, the department chose to stick with a narrow, existing list of professions rather than evaluate Counseling based on its actual characteristics as a regulated, licensed, evidence-based clinical profession.

The department also stated that the professional degree classification “is not a judgment regarding the relative value of the profession,” suggesting that Counseling’s exclusion carries no negative implication. However, this statement conflicts with reality: When the department classifies Counseling as “nonprofessional” while classifying veterinary medicine and chiropractic as “professional,” it inevitably sends a message about relative value regardless of stated intent.

What This Means

The department rejected NBCC’s evidence-based arguments without providing substantive counterarguments. The decision reflects regulatory rigidity rather than policy analysis. Instead of evaluating whether Counseling meets objective criteria for professional degree status, the department simply deferred to an existing list developed decades ago—before modern behavioral health professions had developed their current rigor, licensure standards, and federal recognition.

The Broader Message

The Department of Education’s exclusion of Mental Health Counseling from the “professional degree” category—despite meeting established criteria—reflects a fundamental misunderstanding of the Counseling profession and its role in addressing America’s mental health crisis.

The result is a financial barrier that will deter talented people from pursuing Counseling careers, deepen the shortage of qualified Counselors, and widen access disparities for mental health care.

This is not inevitable. Advocacy for Counseling’s inclusion in future legislation (and through legal challenges), coupled with support for the interim exception for currently enrolled students, can help mitigate these impacts. The long-term solution is legislative action ensuring that Counseling is recognized and supported as a professional degree field critical to American mental health. We will continue to fight for the profession with your support.