COCPA Submits Comments to U.S. Department of Education on Student Loan Definitions Impacting Accounting Programs

The COCPA submitted formal comments to the U.S. Department of Education in response to a Notice of Proposed Rulemaking titled "Reimagining and Improving Student Education" (Docket ED2025OPE0944), urging the Department to ensure that students pursuing accounting degrees are not disadvantaged by proposed changes to student loan definitions.

The letter, submitted on behalf of more than 5,000 COCPA members and nearly 400 currently enrolled college students, requests that the Department of Education either explicitly include "accounting" in its definition of "professional degree" under the One Big Beautiful Bill (OBBB), or retain current language clarifying that professional degrees "may include but are not limited to" those listed in the rule.

The proposed rulemaking raises concern that, without further adjustments, students pursuing accounting — a profession with rigorous education, licensure, ethics, and competency standards — could face inequitable access to graduate-level financing compared to students in other recognized professional programs.

"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 Colorado and nationwide," the letter states. The COCPA emphasized that while the Department noted the "professional" designation is not a value judgment, confusion in interpretation could still negatively impact accounting students.

The letter specifically calls on the Department to reflect any clarification explicitly in the final rule and in the Code of Federal Regulations — either by revising 34 CFR 685.102 or 34 CFR 668.2(b) to include accounting by name, or by preserving inclusive language that has historically protected access for accounting students.

The COCPA will continue to advocate for equitable treatment of accounting students at both the state and federal level and to support initiatives that strengthen the accounting pipeline and protect the public interest.

To view the full letter, click here.