Update on Federal Student Aid Professional Degree Status for Naturopathic Medical Students
June 30, 2026
Dear Naturopathic Medicine Community:
Over the past week, the landscape regarding federal student loan limits and the Reimagining and Improving Student Education (RISE) rule has shifted rapidly. The Boards of Directors for both the American Association of Naturopathic Physicians (AANP) and the Association of Accredited Naturopathic Medical Colleges (AANMC) have been meeting continuously and are carefully evaluating each decision juncture to ensure we are taking the most strategic and effective actions on behalf of our students and institutions.
On June 25, 2026, a federal judge issued a preliminary injunction that successfully blocked the Department of Education from implementing its extra-statutory requirements for defining a “professional degree.” However, we are disappointed by the scope of the judge’s actions. While the court stayed the Department’s newly fabricated requirements, it declined to mandate which specific degree programs meet the remaining three-part statutory test, leaving that determination up to the Department of Education.
Following the court’s order, the Department of Education issued an Electronic Announcement on June 29, 2026, providing an interim list of programs it will treat as granting professional degrees during the stay. The new guidance expanded the list of professions temporarily eligible for “professional” loan limits under the temporary injunction. The guidance also explicitly excluded 25 programs that may no longer be eligible for the higher professional degree loan limits. The Naturopathic Doctor program was on neither the inclusionary nor the exclusionary lists.
While we are deeply disappointed that naturopathic medicine (CIP 51.3303) was entirely omitted from the approved list, we are not surprised, because the Department specifically argued in its final rule that ND programs fail the statutory three-part test because naturopathic medicine is banned in some states and is not licensed in all 50 states, meaning the Department does not believe it meets the requirement that “professional licensure is also generally required” to begin practice.
Fundamentally, our organizations (and legal counsel) and the Department of Education hold vastly different legal interpretations of the Higher Education Act. As we laid out thoroughly in our formal substantive comments to the Department earlier this year, the Doctor of Naturopathic Medicine (ND) degree unambiguously meets all three criteria of the statutory test:
- Signifies completion of academic requirements for beginning practice: Upon completion of the ND degree, graduates are ready to sit for the NPLEX and enter independent primary care practice.
- Requires professional skill beyond a bachelor’s degree: Our doctoral-level clinical competencies — including advanced diagnostic skills, pharmacological knowledge, and minor surgical procedures — are obtained through four years of post-baccalaureate education comprising approximately 4,100 hours of didactic instruction and 1,200 hours of supervised clinical training.
- Professional licensure is “generally required”: In 100% of the 26 jurisdictions that regulate our profession, professional licensure is strictly required before practice.
The Department of Education has unlawfully and inequitably imposed an unstated fourth requirement — that a profession must be licensed in a majority of all 50 states — to deny ND students professional degree status. We firmly believe that the statutory phrase “generally required” means required as a general rule where the profession is regulated. Allowing antiquated bans in three states to override the deliberate, modern legislative frameworks of 26 jurisdictions undermines state authority, ignores our classification as a “first-professional degree” by the Department’s own National Center for Education Statistics since 1999, and would forever preclude any newer developing profession from becoming recognized.
We are firmly committed to fighting for the proper recognition of the ND degree as a professional degree on behalf of our current and future students. Because the court’s injunction has superseded the Department’s previous rationale, we are working closely with legal counsel to submit an immediate letter urging the Department to reevaluate naturopathic programs strictly under the lawful three-part test. Should the Department refuse to correct this oversight, we are prepared to explore targeted, standalone legal action to protect our students’ access to equitable federal borrowing limits.
How You Can Help
The administrative and legal battles ahead require significant resources. We ask our community to stand with us as we fight for the future of the naturopathic workforce.
- Donate: Please consider making a contribution to the AANP Foundation’s Education Advocacy fund to support these ongoing legal and administrative efforts.
- We Are Hiring: To help sustain these critical efforts, the AANP Foundation is currently seeking to hire a part-time Foundation manager and fundraiser. If you or someone you know is passionate about advancing naturopathic medicine with substantial fundraising experience, please reach out to us for more information on this vital role. Email [email protected].
Students should stay in close contact with your financial aid offices for updates regarding how the ongoing litigation, the temporary injunction, and the interim professional degree list might impact federal loan limits. At this point in time, because naturopathic medicine is not currently included on the Department’s interim list of programs treated as professional degrees, we advise a conservative approach and continued exploration of alternative funding options.
We will continue to keep you informed of our progress. Thank you for your unwavering support and dedication to the naturopathic profession.
Sincerely,
The American Association of Naturopathic Physicians (AANP) and Association of Accredited Naturopathic Medical Colleges (AANMC) Boards of Directors
