AIAS’ Advocacy Efforts on the Department of Education’s ‘Professional Degree’ List

The public comment period is now open. This is your opportunity to directly influence how the U.S. Department of Education finalizes its proposed rule.

Comments submitted through the Federal Register become part of the official record and are reviewed as the Department considers next steps. You do not need to be a policy expert to participate. Your lived experience as a student matters.

Where to Submit

Submit your comment directly through the Federal Register:

Submit a Public Comment

You may type your comment into the text box or upload a written document.

How to Write an Effective Comment

Step 1: Explain Who You Are

Briefly share your perspective. For example:

• Undergraduate or graduate architecture student

• Prospective student or recent graduate

• First-generation, low-income, or nontraditional student

• Someone pursuing licensure through an accredited program

This context helps reviewers understand the real-world impact of the proposed changes.

Step 2: Describe How the Proposal Affects You

Use your own experience to explain why this issue matters. You might address:

• How federal loan caps affect your ability to pay for school

• The cost, workload, and time commitment of architecture programs

• The role of accredited education in licensure and public safety

• How access, equity, and diversity in the profession could be impacted

Step 3: Reference the Proposal

When possible:

• Refer to specific sections or subsections of the proposed regulation

• Clearly state whether you agree or disagree with the language

• Explain why, using examples, data, or experience

Step 4: Support Your Position

The Department of Education encourages comments that include evidence. You may:

• Cite research, reports, or published data

• Include active hyperlinks to sources

• Reference your academic or professional experience as supporting evidence

If you reference unpublished materials or original data, you may upload relevant documentation with your comment.

Step 5: Suggest Alternatives

If you disagree with the proposed language, consider:

• Suggesting alternative regulatory language

• Explaining how a different approach would better support students and the profession

Step 6: Review Before Submitting

Before submitting your comment:

• Keep it concise and focused

• Use clear, professional language

• Avoid profanity

• Do not include personal identifiable information such as Social Security numbers, loan account numbers, or private financial details

Federal Register Recommendations

The Department of Education specifically recommends that comments:

• Be concise and supported by objective sources

• Clearly explain your views

• Reference specific sections of the proposed rule

• Use data, research, and lived experience to support claims

• Offer alternatives where you disagree with the proposal

• Exclude personal identifiable information

Need more assistance? Regulations.gov offers a one-pager on How Your Can Effectively Participate in the Regulatory Process Through Public Comment

Why Your Voice Matters

Public comments influence how federal rules are finalized. Individual submissions, combined with coordinated advocacy, are especially impactful.

We are partnering with our Alliance organizations to submit a cohesive, coalition-based response, while also elevating individual student voices through the public comment process. Together, this approach strengthens the case for protecting access to architectural education.

We want to hear from you.
Your experiences shape our advocacy, which is why we have created a survey to compile feedback on this topic that will shape our approach to these conversations.
If you’re an architecture student or recent graduate, we would love to hear from you. Even if you’re not an AIAS member, your voice is invaluable to us.

Click on the button below to fill out the survey and help us elevate your voice with strength and clarity. Together we can become stronger advocates for the student community.

Download the AIAS Statement on the Department of Education’s Professional Degree List

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AIAS’ Statement on the Department of Education’s Professional Degree List

The American Institute of Architecture Students (AIAS) has served as the official representative organization of the collective voice of architecture students in the U.S. for nearly 70 years. As an independent, student-run, non-profit organization, we have advocated and worked alongside allies and partners to advance excellence in architectural education, training, and practice through meaningful learning opportunities and experiences that link the profession to architectural education.

In accordance with our mission, the AIAS positions itself in opposition to any policy that fails to recognize the extent and rigor of architectural education, the significance of professional licensure as an Architect, or undermines the ability of architecture students to access opportunities that allow them to become drivers of the publics’ health, safety, and welfare in the built environment.

Architecture is one of the oldest professions in modern society. As architecture students we are educated, trained, and undergo a rigorous examination process to ensure that when we become an Architect — a person who has earned a Professional License to practice — we will design buildings that protect the public. Just as a medical professional is trained to provide life-saving services to individuals, we are trained through our education to ensure that buildings are safe to occupy, ensuring that no harm comes to the people who experience these spaces every day.

The Department of Education’s proposed revisions fail to include Architecture (and other professions related to the built environment) in their list of examples that define a professional degree, thus risking the exclusion of those undergoing architectural education from accessing the necessary support outlined for Professional Students. This should be a matter of public concern, since architectural education also plays a vital role in cultivating professionals and leaders that influence and shape our communities. 

Jeopardizing the affordability and access to the profession not only takes away opportunities from individuals with great potential to protect and serve the public; it also undermines the importance of the professionals involved in protecting the public through rigorous and ethical standards.

For this reason, the AIAS joins in support of the statements issued by AIA, ACSA, NCARB, NOMA, and others, urging the U.S. Department of Education to include Architecture within the Department of Education’s list of professional study areas.

Our organization continues to protect and elevate student voices in the profession of architecture, as well as to affirm the essential role of architectural education in upholding our profession’s responsibility to the public good.

Sincerely,
The American Institute of Architecture Students
2025-2026 Board of Directors

Here are some resources you can check out to learn more about the topic:

• ACSA’s Fact Sheet

  A great synthesis of how the proposed changes will impact Architectural Education.

• AIA’s Resource Page

  A brief breakdown of the situation at hand and the context around it.

• AIA’s Public Statement

• NCARB’s Public Statement

• NOMA’s Public Statement