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As DOE's public comment period comes to a close, read what CSWE submitted to Education Secretary Linda McMahon:
March 2, 2026
U.S. Secretary of Education Linda McMahon
U.S. Department of Education
Office of Postsecondary Education
400 Maryland Avenue SW, 5th floor
Washington, DC 20202
Docket ID ED-2025-OPE-0944
Dear Secretary McMahon,
The Council on Social Work Education (CSWE) recognizes the Department of Education’s (ED) intent to create clear and consistent criteria for what constitutes a professional degree, but we are deeply concerned by ED’s proposed definition and its potential impacts.
Excluding social work in the professional degree definition disregards the realities of the required educational preparation and licensure pathways, and will thus have dire consequences for patient care, communities, and workforce across the United States. Our comments are focused on deficiencies in how the ED applied the operative definition of professional student within the context of the illustrative list of degrees when interpreting the definition (in addition to other elements of the proposed rule). As the proposed regulation notes, “OBBB establishes a three-part test” for the definition of the “professional degree.” The comments below highlight how the Master’s of Social Work (MSW) and Doctorate of Social Work (DSW) degrees meet the first test, in that they “signify completion of the academic requirements for beginning practice in a given profession.”
These degrees also meet the second test––“that the profession must require skill(s) that students who only have a bachelor’s degree (or training below a bachelor’s degree level) would not normally have.”
Finally, the MSW and DSW meet the third test of “the profession that a degree holder would enter after graduating generally requires professional licensure. This means that before beginning practice, the degree recipient must obtain additional authorization to begin practicing.”
CSWE acknowledges ED’s inclusion of a rationale for excluding the MSW and DSW from the professional degree definition, however, we believe there are fundamental mischaracterizations with the rationale in the proposed rules:
Definitions (§685.102)
Many states do license at the Baccalaureate Social Work degree level (LBSW), however, LBSWs are only able to practice in a limited capacity (e.g., case management, advocacy, community support). Specifically, LBSWs are not permitted to diagnose mental health disorders or provide psychotherapy. For example, in Texas and Florida LBSWs must be supervised, making them unable to practice independently and unauthorized to provide clinical mental health diagnoses or psychotherapy; these are reserved for Licensed Clinical Social Workers (LCSWs). ED notes that it “is hesitant to classify degrees that lead to employment that must be supervised by a licensed professional, and cannot be performed independently, as professional degrees within this definition,” which inherently describes the nature of the LBSW. While requirements vary by state, every jurisdiction requires an MSW at minimum for LCSW licensure.
An accredited MSW/DSW degree is the required graduate credential for licensure at the level of independent and clinical practice, and therefore satisfies the definition of a professional degree. This is also acknowledged by the Bureau of Labor Statistics (BLS) as they note that “Clinical social workers need a master's degree, supervised experience, and a license to provide mental health or counseling services.” The existence of BSW licensure does not change the licensure entry point requirements for independent practice; the relevant entry point for the profession’s independent/clinical scope (e.g., assessment, diagnosis, psychotherapy) is the graduate degree.
From DOE: “The Department is aware that individuals who have earned an MSW or DSW may obtain work as a clinical social worker, which allows an individual to perform similar work in a supervisory role or to take on heavier caseloads. In some cases, a clinical social worker may perform work that is different from other social workers… but the Department does not believe the statute permits the classification of clinical social work as a separate and distinct profession, as opposed to a specialization or concentration.”
The characterization of a clinical social work degree is not correct and warrants reconsideration.
The Centers for Medicare and Medicaid Services (CMS) recognizes LCSWs as an independent provider type, and in most jurisdictions, independent practice and clinical social work are not merely a "specialization" or "concentration" within social work; they are separately regulated scopes of practice defined in state law and implemented through distinct licensure. The MSW/DSW licensure levels authorize practice that BSW licensure does not—most notably independent assessment, diagnosis of mental and behavioral disorders, and treatment/psychotherapy—and without supervision.
The state-level regulatory authorities, supervision requirements, and standards reflect a separate professional authorization, not simply a preference for heavier caseloads or supervisory work. Where a credential is legally required to perform an independent practice function, the role should be treated as a distinct professional degree for statutory classification purposes, not a specialization or concentration. To address ED’s contention that the “Department does not believe the statute permits the classification of clinical social work as a separate and distinct profession, as opposed to a specialization or concentration”; the MSW meets the definition of a separate and distinct profession. Clinical social work has its own entry requirements, its own examination, its own scope of practice, and its own federal provider classification. This is similar to clinical psychology (which ED included as a separate and distinct profession).
ED should consider clinical social work as it treats clinical psychology (not as merely a specialization within psychology). All 50 states, the Association of Social Work Boards (ASWB), and the Social Work Licensure Compact treat clinical social work as a distinct license category and not a credential added onto a base social work degree, similar to the justifications used to include clinical psychology.
From DOE: “In addition, individuals who are licensed with a BSW may later obtain an MSW with only one year of additional coursework, for a total of five years of education compared to six years as provided for in the professional degree definition.”
The MSW degree requires six years of postsecondary education.
While some BSW graduates may complete an MSW in one year through an advanced-standing track, that option is limited to eligible applicants and is not representative of the typical MSW program structure. The standard MSW curriculum is a two-year graduate degree, so the customary pathway to MSW-level preparation is six total years of postsecondary education. The advanced-standing pathway applies only to a subset of students, as the majority of MSW students enter from non-social work undergraduate backgrounds and complete the standard two-year (60-credit) program. The typical total timeline from undergraduate entry to LCSW licensure is seven to eight years, including four years for a bachelor's degree, two for a master's, and two years of supervised experience.
While ED’s proposed rule includes both Psy.D. and Ph.D. in Clinical Psychology as professional degrees, when compared to clinical social work, they are similar in structure including licensure requirements, supervised practice hours, clinical training requirements, and scope of independent practice. The core functions for both clinical social workers and clinical psychologists include assessment, evidence-based intervention with individuals/families/groups, supervision/training, and consultation. MSW/DSW programs prepare social workers to perform these same professional activities, with independent practice authority once licensed. Additionally, the 2025 Medicare Physician Fee Schedule Final Rule proposed new codes that would allow for LCSWs to be reimbursed at a rate that is comparable to clinical psychologists.
––
The Urban Institute estimates that 24% of social work students pursuing a master’s degree borrowed more than the current annual limit ($20,500), and 31% of MSW borrowers exceeded the annual limit. Reclassifying social work as a non-professional degree would further strain these systems through limiting students’ access to the federal loans needed to pursue an education, weaken public systems, and increase taxpayer costs.
CSWE urges ED to include the MSW and the DSW in the professional student definition to be eligible for the higher loan limit outlined in the proposed rules. Given that ED has previously acknowledged the social work profession through the financial value transparency (FVT) regulations regarding the inclusion of postbaccalaureate social work degree programs within the qualifying graduate programs using a longer cohort period to measure the earnings of graduates six years (rather than three) after they graduate, we would appreciate ED’s similar consideration now.
CSWE is also concerned with certain provisions within the proposed rules that may reduce student aid availability, including the complete phasing out of Graduate PLUS loans which threatens to reduce access to MSW programs and discourage students from seeking a public service degree like a social work degree. This is compounded by the annual loan limits for graduate and professional students and implementation of new lifetime borrowing caps. The combination of these two policies will have a particular impact on low-income students and students of color. A 2020 CSWE report, The Social Work Profession: Findings from Three Years of Surveys of New Social Workers, indicated that more Black students struggled with the costs of social work education compared to White students, and therefore, utilized student loans to finance their education. Thus, eliminating Graduate and Professional PLUS Loans removes a financing mechanism for many of these students.
From delivering mental and behavioral health, to addressing substance use, to supporting veterans and providing services in schools and community settings, social work students go on to provide significant public service and societal good. With social workers addressing many of the challenges facing society, and providing a critical part of the behavioral health workforce, CSWE urges the ED to ensure that proposed rules promote affordable access to student financial aid programs for all students. CSWE thanks ED for this opportunity to provide comments on these proposed rules for implementing changes to the Title IV, HEA programs included in Public Law 119-21.
These comments are submitted on behalf of the Council on Social Work Education (CSWE), the national association representing social work education in the United States. CSWE’s members include more than 900 accredited baccalaureate, master’s, and practice doctorate degree social work programs, as well as individual social work educators, practitioners, and agencies dedicated to advancing quality social work education.
Published on : March 1, 2026
Below is the public comment submitted by the Council on Social Work Education (CSWE) to the U.S. Department of Education (DOE) regarding DOE's proposed definition of "professional degrees." DOE is updating that definition, which determines federal student loan eligibility for graduate programs. Historically, social work has been recognized as a professional degree, allowing MSW students to access federal Direct Unsubsidized Loans and other critical funding. Under the proposed rule, social work would no longer meet the professional degree criteria, creating significant financial barriers for students. This change comes amid growing demand for social workers in behavioral health, child welfare, education, and community services—sectors already facing severe workforce shortages.As DOE's public comment period comes to a close, read what CSWE submitted to Education Secretary Linda McMahon:
March 2, 2026
U.S. Secretary of Education Linda McMahon
U.S. Department of Education
Office of Postsecondary Education
400 Maryland Avenue SW, 5th floor
Washington, DC 20202
Docket ID ED-2025-OPE-0944
Dear Secretary McMahon,
The Council on Social Work Education (CSWE) recognizes the Department of Education’s (ED) intent to create clear and consistent criteria for what constitutes a professional degree, but we are deeply concerned by ED’s proposed definition and its potential impacts.
Excluding social work in the professional degree definition disregards the realities of the required educational preparation and licensure pathways, and will thus have dire consequences for patient care, communities, and workforce across the United States. Our comments are focused on deficiencies in how the ED applied the operative definition of professional student within the context of the illustrative list of degrees when interpreting the definition (in addition to other elements of the proposed rule). As the proposed regulation notes, “OBBB establishes a three-part test” for the definition of the “professional degree.” The comments below highlight how the Master’s of Social Work (MSW) and Doctorate of Social Work (DSW) degrees meet the first test, in that they “signify completion of the academic requirements for beginning practice in a given profession.”
These degrees also meet the second test––“that the profession must require skill(s) that students who only have a bachelor’s degree (or training below a bachelor’s degree level) would not normally have.”
Finally, the MSW and DSW meet the third test of “the profession that a degree holder would enter after graduating generally requires professional licensure. This means that before beginning practice, the degree recipient must obtain additional authorization to begin practicing.”
CSWE acknowledges ED’s inclusion of a rationale for excluding the MSW and DSW from the professional degree definition, however, we believe there are fundamental mischaracterizations with the rationale in the proposed rules:
Definitions (§685.102)
From DOE: "The Department has determined that MSW and DSW would not meet the professional degree definition because neither degree is generally required to obtain an entry-level licensure in the social work field or to begin work in a profession.”
“Most states license BSW holders as certified social workers, making the baccalaureate level degree the one necessary to begin practice in the social work profession.”
“Finally, the Department is hesitant to classify degrees that lead to employment that must be supervised by a licensed professional, and cannot be performed independently, as professional degrees within this definition."
Many states do license at the Baccalaureate Social Work degree level (LBSW), however, LBSWs are only able to practice in a limited capacity (e.g., case management, advocacy, community support). Specifically, LBSWs are not permitted to diagnose mental health disorders or provide psychotherapy. For example, in Texas and Florida LBSWs must be supervised, making them unable to practice independently and unauthorized to provide clinical mental health diagnoses or psychotherapy; these are reserved for Licensed Clinical Social Workers (LCSWs). ED notes that it “is hesitant to classify degrees that lead to employment that must be supervised by a licensed professional, and cannot be performed independently, as professional degrees within this definition,” which inherently describes the nature of the LBSW. While requirements vary by state, every jurisdiction requires an MSW at minimum for LCSW licensure.
An accredited MSW/DSW degree is the required graduate credential for licensure at the level of independent and clinical practice, and therefore satisfies the definition of a professional degree. This is also acknowledged by the Bureau of Labor Statistics (BLS) as they note that “Clinical social workers need a master's degree, supervised experience, and a license to provide mental health or counseling services.” The existence of BSW licensure does not change the licensure entry point requirements for independent practice; the relevant entry point for the profession’s independent/clinical scope (e.g., assessment, diagnosis, psychotherapy) is the graduate degree.
From DOE: “The Department is aware that individuals who have earned an MSW or DSW may obtain work as a clinical social worker, which allows an individual to perform similar work in a supervisory role or to take on heavier caseloads. In some cases, a clinical social worker may perform work that is different from other social workers… but the Department does not believe the statute permits the classification of clinical social work as a separate and distinct profession, as opposed to a specialization or concentration.”
The characterization of a clinical social work degree is not correct and warrants reconsideration.
The Centers for Medicare and Medicaid Services (CMS) recognizes LCSWs as an independent provider type, and in most jurisdictions, independent practice and clinical social work are not merely a "specialization" or "concentration" within social work; they are separately regulated scopes of practice defined in state law and implemented through distinct licensure. The MSW/DSW licensure levels authorize practice that BSW licensure does not—most notably independent assessment, diagnosis of mental and behavioral disorders, and treatment/psychotherapy—and without supervision.
The state-level regulatory authorities, supervision requirements, and standards reflect a separate professional authorization, not simply a preference for heavier caseloads or supervisory work. Where a credential is legally required to perform an independent practice function, the role should be treated as a distinct professional degree for statutory classification purposes, not a specialization or concentration. To address ED’s contention that the “Department does not believe the statute permits the classification of clinical social work as a separate and distinct profession, as opposed to a specialization or concentration”; the MSW meets the definition of a separate and distinct profession. Clinical social work has its own entry requirements, its own examination, its own scope of practice, and its own federal provider classification. This is similar to clinical psychology (which ED included as a separate and distinct profession).
ED should consider clinical social work as it treats clinical psychology (not as merely a specialization within psychology). All 50 states, the Association of Social Work Boards (ASWB), and the Social Work Licensure Compact treat clinical social work as a distinct license category and not a credential added onto a base social work degree, similar to the justifications used to include clinical psychology.
From DOE: “In addition, individuals who are licensed with a BSW may later obtain an MSW with only one year of additional coursework, for a total of five years of education compared to six years as provided for in the professional degree definition.”
The MSW degree requires six years of postsecondary education.
While some BSW graduates may complete an MSW in one year through an advanced-standing track, that option is limited to eligible applicants and is not representative of the typical MSW program structure. The standard MSW curriculum is a two-year graduate degree, so the customary pathway to MSW-level preparation is six total years of postsecondary education. The advanced-standing pathway applies only to a subset of students, as the majority of MSW students enter from non-social work undergraduate backgrounds and complete the standard two-year (60-credit) program. The typical total timeline from undergraduate entry to LCSW licensure is seven to eight years, including four years for a bachelor's degree, two for a master's, and two years of supervised experience.
While ED’s proposed rule includes both Psy.D. and Ph.D. in Clinical Psychology as professional degrees, when compared to clinical social work, they are similar in structure including licensure requirements, supervised practice hours, clinical training requirements, and scope of independent practice. The core functions for both clinical social workers and clinical psychologists include assessment, evidence-based intervention with individuals/families/groups, supervision/training, and consultation. MSW/DSW programs prepare social workers to perform these same professional activities, with independent practice authority once licensed. Additionally, the 2025 Medicare Physician Fee Schedule Final Rule proposed new codes that would allow for LCSWs to be reimbursed at a rate that is comparable to clinical psychologists.
––
The Urban Institute estimates that 24% of social work students pursuing a master’s degree borrowed more than the current annual limit ($20,500), and 31% of MSW borrowers exceeded the annual limit. Reclassifying social work as a non-professional degree would further strain these systems through limiting students’ access to the federal loans needed to pursue an education, weaken public systems, and increase taxpayer costs.
CSWE urges ED to include the MSW and the DSW in the professional student definition to be eligible for the higher loan limit outlined in the proposed rules. Given that ED has previously acknowledged the social work profession through the financial value transparency (FVT) regulations regarding the inclusion of postbaccalaureate social work degree programs within the qualifying graduate programs using a longer cohort period to measure the earnings of graduates six years (rather than three) after they graduate, we would appreciate ED’s similar consideration now.
CSWE is also concerned with certain provisions within the proposed rules that may reduce student aid availability, including the complete phasing out of Graduate PLUS loans which threatens to reduce access to MSW programs and discourage students from seeking a public service degree like a social work degree. This is compounded by the annual loan limits for graduate and professional students and implementation of new lifetime borrowing caps. The combination of these two policies will have a particular impact on low-income students and students of color. A 2020 CSWE report, The Social Work Profession: Findings from Three Years of Surveys of New Social Workers, indicated that more Black students struggled with the costs of social work education compared to White students, and therefore, utilized student loans to finance their education. Thus, eliminating Graduate and Professional PLUS Loans removes a financing mechanism for many of these students.
From delivering mental and behavioral health, to addressing substance use, to supporting veterans and providing services in schools and community settings, social work students go on to provide significant public service and societal good. With social workers addressing many of the challenges facing society, and providing a critical part of the behavioral health workforce, CSWE urges the ED to ensure that proposed rules promote affordable access to student financial aid programs for all students. CSWE thanks ED for this opportunity to provide comments on these proposed rules for implementing changes to the Title IV, HEA programs included in Public Law 119-21.
These comments are submitted on behalf of the Council on Social Work Education (CSWE), the national association representing social work education in the United States. CSWE’s members include more than 900 accredited baccalaureate, master’s, and practice doctorate degree social work programs, as well as individual social work educators, practitioners, and agencies dedicated to advancing quality social work education.