AICPA asks Department of Education to list accounting as a professional degree

The AICPA submitted a comment letter in response to last month’s notice of proposed rulemaking (NPRM) from the Department of Education that explained why the department’s proposed definition of a “professional degree program” didn’t include accounting.

Accounting is among a long list of degree programs — including nursing and engineering — not among the 11 fields of study proposed to be designated as “professional degree programs” for the purposes of graduate student loan limits. The programs are law, medicine, pharmacy, dentistry, chiropractic, optometry, osteopathic medicine, podiatry, veterinary medicine, clinical psychology, and theology.

“Fundamentally, recognizing accounting programs as professional degree programs makes common sense,” the AICPA comment letter read in part. “This recognition reflects the impact CPAs make on the lives of individuals, the health of communities, and the integrity of financial systems, as well as the rigorous path taken to become a licensed Certified Public Accountant. Students pursing this pathway should have equitable access to graduate-level financing, consistent with other recognized professional programs that serve critical public needs.”

The AICPA, according to a news release, acknowledges the department’s efforts in the NPRM to clarify that “the designation, or lack thereof, of a program as ‘professional’ does not reflect a value judgment by the department regarding whether a borrower graduating from the program is considered a ‘professional.’ This NPRM only interprets the phrase ‘professional student’ as used in the context of the loan limits established by [H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act].”

The AICPA letter urges the incorporation of similar language into the final rule, making the intent clear within the Code of Federal Regulations. Additionally, the AICPA strongly encouraged the department to include “accounting” in the definition or retain current language stating that “professional degrees may include but are not limited to” the list included in the NPRM.

The NPRM is in response to legislation signed into law last summer that calls for the elimination of unlimited borrowing under the Graduate PLUS Program. Effective for loans made on or after July 1, 2026, the proposal would limit borrowing amounts for students in the 11 professional degree programs to an annual limit of $50,000 with an aggregate lifetime limit of $200,000.

All other graduate students would be subject to an annual limit of $20,500 with an aggregate lifetime limit of $100,000.

The AICPA, according to its release, joins voices of CPAs across the country, with many state CPA societies also submitting comments to the Department of Education.

The NPRM was published Jan. 30, and its comment deadline was set for Monday, March 2.

— To comment on this article or to suggest an idea for another article, contact Bryan Strickland at Bryan.Strickland@aicpa-cima.com.