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Letter to DOE on Accounting as a Professional Degree

December 05, 2025

December 5, 2025

The Honorable Linda McMahon
Secretary
U.S. Department of Education
400 Maryland Avenue SW
Washington, DC 20202

Subject: Inclusion of CPA Licensure Programs in the Definition of “Professional Degree”

Dear Secretary McMahon:

On behalf of the American Institute of CPAs (AICPA) and state CPA societies nationwide, we strongly urge the Department of Education to include accounting programs leading to CPA licensure within its definition of a “professional degree” for purposes of graduate student loan eligibility under the new lending limits established by the One Big Beautiful Bill Act.

Accounting is a state-level licensed profession that serves the public interest by ensuring financial integrity, transparency, and compliance — functions essential to the stability of our economy. State CPA societies and the AICPA advocate for the profession, provide education and resources, and promote high ethical and competency standards.

The Department’s definition of a professional degree, “a degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree,” aligns squarely with CPA licensure requirements.

CPA candidates who have completed the following are eligible for licensure in all 55 United States licensing jurisdictions:

  • Meet one of multiple pathways including attaining post-secondary education hours that exceed the standard bachelor’s degree requirement;
  • Specialized professional experience in accounting, auditing, taxation, and ethics; and
  • Successful passage of the Uniform CPA Examination, followed by state licensure.

These requirements are not merely academic; they represent the needed experience and skills for entry into a regulated profession that is critical to protecting investors, businesses, and the public. Like law and medicine, accounting is a licensed profession governed by state boards, and practitioners bear significant fiduciary and ethical responsibilities.

Excluding CPA-track programs from the definition of a professional degree would create unintended consequences:

  • Workforce impact: The accounting profession faces a growing talent shortage, with demand for CPAs in public accounting, corporate finance, and government roles outpacing supply.
  • Cost of compliance: Meeting the post-secondary education requirement option often necessitates graduate-level coursework, increasing educational costs beyond those of a standard bachelor’s degree.
  • Public interest: CPAs serve as guardians of financial transparency and compliance. Limiting access to affordable financing for CPA candidates risks weakening this essential pipeline.

We share your concerns about the increasing costs of education. However, we respectfully request that the Department recognize programs leading to CPA licensure as professional degree programs. Doing so will ensure equitable treatment of a profession that is foundational to the nation’s economic health and regulatory compliance.

Thank you for your consideration of this important matter.

Sincerely,

American Institute of Certified Public Accountants
Alabama Society of CPAs
Alaska Society of CPAs
Arizona Society of CPAs
Arkansas Society of CPAs
California Society of CPAs
Colorado Society of CPAs
Connecticut Society of CPAs
Delaware Society of CPAs
Greater Washington Society of CPAs
Florida Institute of CPAs
Georgia Society of CPAs
Guam Society of CPAs
Hawaii Society of CPAs
Idaho Society of CPAs
Illinois CPA Society
Indiana CPA Society
Iowa Society of CPAs
Kansas Society of CPAs
Kentucky Society of CPAs
Society of Louisiana CPAs
Maine Society of CPAs
Maryland Association of CPAs
Massachusetts Society of CPAs
Michigan Association of CPAs
Minnesota Society of CPAs
Mississippi Society of CPAs
Missouri Society of CPAs
Montana Society of CPAs
Nebraska Society of CPAs
Nevada Society of CPAs
New Hampshire Society of CPAs
New Jersey Society of CPAs
New Mexico Society of CPAs
New York State Society of CPAs
North Carolina Association of CPAs
North Dakota CPA Society
Ohio Society of CPAs
Oklahoma Society of CPAs
Oregon Society of CPAs
Pennsylvania Institute of CPAs
Puerto Rico Society of CPAs
Rhode Island Society of CPAs
South Carolina Association of CPAs
South Dakota CPA Society
Tennessee Society of CPAs
Texas Society of CPAs
Utah Association of CPAs
Vermont Society of CPAs
Virgin Islands Society of CPAs
Virginia Society of CPAs
Washington Society of CPAs
West Virginia Society of CPAs
Wisconsin Institute of CPAs
Wyoming Society of CPAs

Cc: House Committee on Education and the Workforce; Senate Committee on Health, Education, Labor and Pensions; Speaker of the House Mike Johnson; House Minority Leader Hakeem Jeffries; Senate Majority Leader John Thune; Senate Minority Leader Charles Schumer