Grassroots Action Center

The Situation 

The U.S. Department of Education has released a proposed rule that would limit how much graduate students can borrow to finance their education. This rule is now open for public comment, and the Department is accepting feedback through March 2, 2026, after which the rule could be finalized and take effect on July 1, 2026. 

If implemented, these borrowing limits could significantly restrict access to counselor education, affecting students currently pursuing degrees, Counselor Educators, and licensed Counselors alike. 

At a time when the nation faces severe mental health workforce shortages, policies that make counseling degrees less affordable risk worsening access to care across the country. 

Why This Matters 

Graduate education in counseling relies heavily on federal student loans to remain accessible. Proposed borrowing limits could: 

• reduce access to counseling and therapy programs, particularly for first-generation students and students from underrepresented backgrounds.
• shrink the future mental health workforce at a time of unprecedented demand.
• undermine efforts to address Mental Health Professional Shortage Areas, where more than one-third of Americans already lack adequate access to care.
• place additional strain on counselor education programs and the institutions that prepare the behavioral health workforce.

Public comments play a critical role in shaping final federal regulations. The Department of Education is required to review and respond to stakeholder feedback before finalizing this rule. 

Act Today 

Submit a Comment Letter to the Department of Education by March 2: 

Use the template letter that best matches your role: 

• Licensed Counselors
• Counseling Students
• Counselor Educators

These letters explain how the proposed rule would affect YOU, counselor education, and the mental health workforce. 

There are indicators on each letter that show where personalization is required, but please feel free to individualize further. 

Helpful Tips for Submitting Comment Letters: 

• The Department will not accept comments submitted by email or comments submitted after the comment period closes.
• Please submit your comments only once so the Department does not receive duplicate copies.
• Additionally, please include the Docket ID (ED-2025-OPE-0944) at the top of your comments. Information on using Regulations.gov, including instructions for submitting comments, is available on the site under ‘‘FAQ.’’
• Commenters should include in their comments only information that they wish to make publicly available. Additionally, commenters should not include in their comments any personally identifiable information about other individuals.
• Commenters are encouraged to include supporting facts and research in their comments. When doing so, commenters are encouraged to provide citations to the published materials.
• Explain your views as clearly as possible and refrain from using any profanity.

Follow these easy steps to submit your personalized Comment Letter:

1) To access the template letters, follow this link.

2) Review our step-by-step instruction guide to submit your comments. 

3) Go to https://www.regulations.gov/ and follow the step-by-step directions to upload your public comment. 

Timing Matters! 

The public comment deadline is March 2, 2026! 

Final rule expected: Following review of comments 

Potential effective date: July 1, 2026 

Submitting comments before the deadline ensures your voice is part of the official record.