ABHW Dismayed by Final U.S. Department of Education RISE Rule

Washington, D.C. – May 1, 2026  — The Association for Behavioral Health and Wellness (ABHW) is dismayed by the U.S. Department of Education’s (ED) inclusion of a narrow definition of “professional degree” in the final “Reimagining and Improving Student Education” (RISE) Rule released today. ABHW warns that the language will exacerbate existing healthcare provider shortages and undermine access to high-quality, evidence-based behavioral healthcare. 

In comments submitted to Secretary Linda McMahon and Under Secretary Nicholas Kent on March 2, 2026, ABHW shared recommendations to broaden the definition of “professional degree” to include post-baccalaureate education required for entry into professional practice, such as the degrees required for licensed clinical social workers, marriage and family therapists, mental health counselors, and other behavioral health professionals. ABHW is deeply concerned that ED did not act on these recommendations. 

“At a time when demand for behavioral health services continues to rise, this rule risks further limiting access to care and weakening the integrated, whole-person care model that patients depend on,” said Debbie Witchey, MHA, President and CEO of ABHW. “The Department of Education’s rule ignores the reality of how behavioral health professionals are trained and licensed in this country.” 

The Mental Health Crisis Demands Action, Not Barriers
According to the National Alliance on Mental Illness (NAMI), 23.4% of U.S. adults—61.5 million people—experienced mental illness in 2024. Yet only about half of those in need receive treatment. The proposed RISE rule would make this crisis worse by creating  financial barriers that deter qualified students from entering behavioral health professions. 

Under the proposed rule, which is scheduled to take effect July 1, 2026, students pursuing master’s degrees in clinical social work, marriage and family therapy, mental health counseling, and related fields would be capped at just $20,500 per year in federal student loans—the same limit as other graduate students. In contrast, students in programs designated as “professional degrees” would be eligible for $50,000 annually. 

This distinction is arbitrary and inconsistent with workforce needs. Entry into licensed behavioral health practice requires a post-baccalaureate degree—typically a master’s degree—that meets state licensure standards, followed by supervised clinical training and examination requirements. These programs generally take two to three years to complete and involve significant financial investment. 

The consequences of the rule are likely to be particularly severe in rural and underserved communities, where behavioral health workforce shortages are already most acute. Many prospective students would be forced to rely on high-interest private loans or reconsider pursuing a behavioral health career altogether. 

“Fewer nurses, licensed clinical social workers, marriage and family therapists, and other behavioral health professionals will be able to enter the workforce,” Witchey added. “This directly undermines national efforts to expand access to care at the worst possible time.”