Request to adopt RISE Committee member recommendations to include Audiology among Professional Degree programs for federal student loan purposes under Docket ID: ED-2025-OPE-0944
Dear Under Secretary Kent and Assistant Secretary Barker,
The Academy of Doctors of Audiology (ADA) represents audiologists who diagnose and treat auditory and vestibular disorders and improve the health and quality of life for millions of Americans each year. ADA appreciates the opportunity to comment on the William D. Ford Federal Direct Student Loan (Direct Loan) Program Definitions (§ 685.102) contained in the U.S. Department of Education (Department) proposed rulemaking under Docket ID: ED-2025-OPE-0944 (Proposed Rule).1
The Department stated that it expressly seeks comments on its analysis and rationale for the Professional Degrees that were included in (or excluded from) the professional student definition contained in the Proposed Rule and the Department’s application of the operative definition of the list of Professional Degrees, using recommendations from the Reimagining and Improving Student Education (RISE) committee, through the negotiated rulemaking process.
ADA urges the Department to include audiology as a recognized program of study and the Doctor of Audiology (Au.D.) degree to the list of Professional Degrees recognized by the Department under 34 CFR 668.2 going forward.2
According to a 2004 Integrated Postsecondary Education Data System (IPEDS) technical review panel, “Since the 1950s, the degree classification pertaining to the first-professional degree has remained unchanged in both its definition and in the list of included degree programs.”3 The degree classification is outdated. The 2025 RISE Committee record clearly reflects that audiology aligns with Congressional intent and regulatory precedent. Committee members expressly acknowledged that audiology programs are classified as 100 percent Professional Degrees within IPEDS, are comparable in structure and purpose to other recognized clinical doctoring professions, and that Congressional intent would likely have been to include programs such as audiology.
The Professional Degree framework aligns with the required length, cost, and intensity of required audiology training and the value and impact of audiology services for patients from birth through end of life. Adding audiology to the list of designated Professional Degree programs recognized by the Department and allowing audiologist trainees to obtain federal loans of up to $50,000 annually/$200,000 aggregate will help protect patient access to hearing and balance services and mitigate audiology workforce shortages that lead to higher costs and reduced access to care, particularly in underserved areas.
According to the U.S. Bureau of Labor Statistics, there are fewer than 16,000 practicing audiologists in the United States.4 Fortifying the audiology workforce is a federal priority that will be supported by categorizing audiology as a Professional Degree.
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1 https://www.govinfo.gov/content/pkg/FR-2026-01-30/pdf/2026-01912.pdf
2 https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.2
3 https://edsurveys.rti.org/IPEDS_TRP_DOCS/prod/documents/trp_Technical_Review_04052004_26.pdf
4 https://www.bls.gov/ooh/healthcare/audiologists.htm