(SCROLL DOWN FOR PUBLIC COMMENT GUIDANCE)

The Department of Education (ED) has proposed a new definition of a “professional degree” that excludes masters and doctoral programs in many professions, including social work. The Impact: Graduate Students who are not enrolled in “professional degree” programs can only borrow up to $20,500 annually. These proposed changes may make an MSW or DSW unattainable through federal loans, forcing students to take out loans with predatory private companies or not complete the degree at all. Maintaining eligibility for federal student loans is essential to sustaining the workforce, particularly during a time when mental  and behavioral health access depends on it.

Read our joint behavioral health letter with the Michigan Mental Health and Healthcare Coalition HERE

What NASW is doing nationally:

• NASW has been circulating a petition that social workers can sign 
• NASW signed a coalition letter urging ED to expand, not restrict, the definition of professional programs
• NASW has updated its Student Loan Debt Relief webpage with guidance and ongoing advocacy
   

GUIDANCE FOR WRITING PUBLIC COMMENT:

(Submit using the provided form)

1) Introduce yourself

In 1–2 sentences, share:

• Your name and where you’re from (city/state)
• Your connection to social work (student, LMSW/LLMSW/LCSW, macro/clinical, professor, supervisor, etc.)
• Why you care enough to write

Example starters (choose your own):

• “I’m a social worker in ___, and I’m writing because…”
• “I’m a current MSW student and future social worker, and…”
• “I became a social worker because…”
• “I work in behavioral health / schools / child welfare / hospitals / housing, and…”

2) Say clearly what you want changed

Ask the Department of Education to:

• Revise the proposed definition of “professional degree” programs
• Include social work as a professional program/degree
• Ensure social work students retain full access to federal student loans

Plain language works best:  “Please revise the rule to include social work as a professional degree.”

3) Use your story: what it took to become (or train as) a social worker

This is where your comment becomes powerful. 

Share what requirements you had to meet:

• Graduate degree requirements (MSW/PhD/DSW)
• Licensure steps in Michigan/your state
• Exams, supervision hours, renewal costs
• Field placement/internship hours (often unpaid)
• What you invested: time, money, debt, other personal sacrifices

Prompts:

• “To become licensed, I had to…”
• “My MSW required ___ hours of field work…”
• “I worked ___ jobs while completing my internship…”
• “I took on debt because…”

4) Choose 1-2 facts about social work to integrate somewhere

Sample statistics to pull from or copy/paste:

1.  Findings from a national survey of new MSW graduates found that 2019 MSW graduates carried a mean total educational debt of $66,000, including $49,000 in debt from their social work education (The Social Work Profession: Findings From Three Years Of Surveys Of New Social Workers)
2. The CFPB notes that private loans “do not feature the flexible repayment terms or borrower protections offered by federal student loans” (CFPB: What are private student loans?)
3. The CFPB explains that federal student loan interest rates are set by Congress and remain fixed for the life of the loan, unlike the variable rates associated with private loans (CFPB: What are private student loans?)
4. NASW notes–citing the Substance Abuse and Mental Health Services Administration (SAMHSA)–that “professional social workers are the nation’s largest group of mental health services providers. There are more clinically trained social workers (over 200,000) than psychiatrists, psychologists, and psychiatric nurses combined. Federal law and the National Institutes of Health recognize social work as one of five core mental health professions” (NASW: Social Workers fact sheet).
5. According to The Bureau of Labor Statistics, there are projected to be about 74,000 openings for social workers each year on average over the next decade. (BLS: Social Workers, Occupational Outlook Handbook)
6. The Bureau of Labor Statistics projects social work employment will grow 6% from 2024 to 2034, faster than the average for all occupations. (BLS: Social Workers, Occupational Outlook Handbook)
7. The Bureau of Labor Statistics identifies social workers as the largest mental health service occupation, with the most jobs and projected openings compared to other mental health service roles.” (BLS: Careers in mental health services)
8. CSWE standards require MSW programs to include a minimum of 900 hours of supervised field instruction (CSWE: Prepare for Your Education).
9. NASW is the largest membership organization of professional social workers, representing social workers across nearly every sector (NASW: About).
10. NASW notes that the U.S. Department of Veterans Affairs employs more than 13,000 professional social workers (NASW: Social Workers fact sheet)
11. NASW reports that more than 40% of American Red Cross disaster mental health volunteers are professional social workers (NASW: Social Workers fact sheet).

But reminder: your story is more persuasive than statistics.

5) Explain why social work is absolutely a healthcare profession

In your own words, explain what social workers do in real life. Pick or write in the areas you personally work in:

• Clinical mental health therapy
• Substance use treatment
• Crisis intervention
• Hospital discharge planning
• Child and family services
• Schools
• Disability services
• Housing and homelessness supports
• Community violence prevention
• Integrated care settings

Key framing:

• Social work isn’t optional support; it’s essential healthcare infrastructure.

6) Connect it to impact

Explain that increased reliance on (predatory) private student loans and limiting access to social work education overall have direct impacts:

• Workforce shortages (especially behavioral/mental health)
• Burnout + retention challenges
• Loss of access for rural/low-income communities
• Fewer students able to enter MSW programs
• Threat to mental health access overall

Prompts:

• “If students lose loan access, fewer people will…”
• “That will directly affect patients/clients like…”
• “This would worsen provider shortages in…”

7) Close with a respectful final ask

End with 1 strong sentence that repeats your request.

Closing examples:

• “I urge the Department to revise the final rule to include social work as a professional degree.”
• “Please ensure social work programs remain eligible for full federal student loan access.”
• “Excluding social work would harm the workforce and harm access to mental health care.”