Recent federal rulemaking tied to graduate student lending policy has prompted significant engagement from the engineering community as the Department of Education considers how graduate engineering programs will be treated under the definition of a professional degree in 34 C.F.R. § 668.2.

As reported in the previous issue of this newsletter, statutory changes enacted in 2025 eliminate the Graduate PLUS loan program beginning July 1, 2026, and replace it with a tiered borrowing structure for graduate students. Under this framework, borrowing limits depend in part on whether a program is classified as a professional degree under existing federal regulations.

Because graduate engineering programs are not explicitly listed among the regulatory examples, engineering organizations raised questions about how accredited graduate engineering programs will be evaluated as the Department of Education moves forward with implementation.

NSPE led the engineering profession’s response by drafting and coordinating a joint coalition letter to the Department of Education urging clarification on how graduate engineering programs that prepare students for professional engineering practice may be evaluated under the professional degree definition. To view the coalition letter, click here.

The letter explains that engineering education, professional practice, and licensure operate as an integrated system that prepares engineers to design and safeguard infrastructure and technological systems that serve the public. Graduate education frequently supports this preparation by helping engineers develop advanced technical competencies and take on responsibilities in safety critical fields.

In addition to NSPE, organizations signing the coalition letter included the American Council of Engineering Companies (ACEC), the American Society of Civil Engineers (ASCE), the American Society for Engineering Education (ASEE), and ASHRAE.

In addition, NSPE submitted its own comment letter to the Department of Education providing the perspective of licensed professional engineers and the engineering profession. NSPE’s comment letter is available here.

NSPE’s comments emphasized that engineering licensure remains grounded in the long established education experience examination framework governing professional engineering practice in the United States. Graduate education does not replace that process but often supports advanced technical preparation and readiness for complex professional responsibilities.

NSPE also launched a national grassroots campaign encouraging professional engineers and engineering students to submit comments to the Department of Education during the public comment period. The effort included direct outreach to members, social media engagement, and coordination with state societies, which promoted the campaign and encouraged members to share their perspectives.

The public comment period closed on March 2. The Department of Education will now review submitted comments as part of the rulemaking process before issuing final implementation guidance related to the new federal graduate loan framework.

NSPE will continue monitoring developments and coordinating with engineering and higher education organizations as the Department of Education moves toward finalizing the rule.