Letter to DOE Asking for Clarification on Accounting as a Professional Degree
February 26, 2026
Feb. 26, 2026
The Hon. Linda McMahon
Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Re: Comments in response to Docket ED2025OPE0944
Dear Secretary McMahon:
On behalf of the Virginia Society of CPAs (VSCPA), we respectfully submit comments on the Department of Education’s Notice of Proposed Rulemaking, “Reimagining and Improving Student Education” (Document ID ED2025OPE0944).
The VSCPA appreciates the Department’s acknowledgment that the designation of a program as “professional” is not a value judgment and relates solely to loan limit definitions under the One Big Beautiful Bill (OBBB). To avoid confusion, we encourage the Department to reflect this clarification explicitly in the final rule and in the Code of Federal Regulations.
Should the Department revise the definition of “professional degree” in 34 CFR 685.102 or 34 CFR 668.2(b), we urge you to either include “accounting” in the definition or retain the current phrasing that professional degrees “may include but are not limited to” those listed. Accounting is a recognized profession with rigorous education, licensure, ethics, and competency standards, and it plays a critical role in economic stability and public trust in Virginia and nationwide.
Recognizing accounting programs as professional degree programs aligns with both the demands of the profession and the public interest. Students pursuing this pathway should have equitable access to graduate-level financing consistent with other professional programs.
The VSCPA is the leading professional association in Virginia dedicated to enhancing the success of all CPAs and their profession by communicating information and vision, promoting professionalism and advocating members’ interests. The VSCPA membership consists of nearly 12,000 individual members who actively work in public accounting, private industry, government, and education.
The VSCPA appreciates the opportunity to offer comments related to this Proposed Rulemaking. Please direct any questions or concerns to VSCPA Vice President, Advocacy & Pipeline Emily Walker, CAE, at ewalker@vscpa.com or (804) 612- 9428.
Sincerely,
Stephanie R. Peters, CAE
President & CEO
Virginia Society of CPAs