Why a proposed federal rule change endangers the future of natural and integrative medicine.

A seemingly bureaucratic rule change proposed by the U.S. Department of Education poses a significant threat to the educational pipeline for naturopathic doctors and a wide array of other conventional and integrative health care professionals, including nurses, physical therapists, acupuncturists, physician associates and many more. At the heart of the issue is a proposed narrow definition of “professional degree” that excludes dozens of advanced health care degrees, and would drastically cut federal student loan access for aspiring practitioners. This article dissects this draft proposal, analyzes its long-term impact on students and patient care, and provides a clear, urgent call to action for the natural and integrative practitioner community—and indeed health care professions generally.

1. Understanding the Proposal: A Restricted Definition of Professional Degrees

What began as an understandable legislative attempt to manage student loan debt has produced a proposed rule that threatens the entire health care workforce pipeline. This proposal originates from the One Big Beautiful Bill Act (Public Law 119-21) and the subsequent recommendation from the Department of Education’s Reimagining and Improving Student Education (RISE) Committee, which was tasked with drafting rules to implement the new law.

The committee recommended proposed rule language that would create a new, and very narrow, definition of a “professional degree.” The proposed definition1 states that a professional degree:

(i) 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;

(ii) Is generally at the doctoral level, and that requires at least six academic years of postsecondary education coursework for completion, including at least two years of post-baccalaureate level coursework;

(iii) Generally requires professional licensure to begin practice; and

(iv) Includes a four-digit program CIP code (Classification of Instructional Program), as assigned by the institution or determined by the Secretary, in the same intermediate group as the fields listed in paragraph (2)(i) of this definition.

Section (iv) referenced above is limited to only 11 professions:

• Pharmacy (PharmD)

• Dentistry (DDS or DMD)

• Veterinary Medicine

• Chiropractic

• Law

• Medicine

• Optometry

• Osteopathic Medicine

• Podiatry

• Theology

• Clinical Psychology

In other words, only degrees which meet the stated criteria, and which are degrees or subdegrees in the list of 11 enumerated professions would be defined as a “professional degree”—whose students would be eligible for the higher loan eligibility threshold needed to complete their studies.

Any degree that falls outside of this definition, including that of naturopathic doctors and dozens more, would only be eligible for federal loan limits of graduate degree programs. This reclassification carries severe financial consequences, effectively cutting federal loan eligibility by more than half for affected students.

While it is commonly acknowledged that we need to address the high cost of education and student loan debt, the practical effect on students aspiring to these professions would be to force them into higher-interest, private loans that are more difficult to qualify for—especially for underserved or marginalized communities—and that lack crucial federal protections like income-based repayment plans or public service loan forgiveness.

This would not reduce the cost of education but would instead perversely increase the overall debt burden and financial risk for the next generation of health care providers.

For integrative and natural health professions like naturopathic doctors, this policy would also incentivize future students toward conventional medical degrees, where students would be able to access the higher federal loan amounts to complete their degrees.

2. A Widespread Crisis: Naturopathic Doctors Are Not Alone in This Fight

Recognizing that this is a shared battle is strategically vital. The draft rule excludes a wide range of essential health care professions from the “professional degree” definition, including nursing, physician assistants (PAs), physical therapists (PTs), occupational therapists (OTs), licensed acupuncturists (LAcs), and many others. The broad scope of this proposed rule change has created an opportunity for a powerful, interprofessional coalition to urge the Department of Education to revise the proposed definition that came out of the RISE committee.

This widespread impact has also triggered bipartisan and bicameral opposition in Congress. In formal letters to the Department of Education, members have voiced grave concerns. Rep. Jen Kiggans (R-VA) advocated for post-baccalaureate nursing programs. A separate letter from Rep. Timothy Kennedy (D-NY), co-signed by dozens of his colleagues, warned that the policy deepens existing workforce shortages and “further strains a health care system already in crisis.”

This is not an isolated attack on alternative medicine but a systemic threat to the entire non-MD/DO health care workforce that millions of patients increasingly depend upon. The exclusion of so many vital professions reveals a profound misunderstanding of the modern health care landscape and patient needs.

3. A Direct Hit on Naturopathic Medicine: Reversing Decades of Recognition

This proposed rule is particularly acute for the naturopathic community, as it represents not just a financial barrier for future students, but would effectively erase more than two decades of federal recognition. The U.S. Department of Education first classified the Doctor of Naturopathic Medicine (ND) degree as a first professional degree in 2003, acknowledging the rigor and importance of the education. The current proposal would reclassify the degree to a “graduate degree,” despite the fact that naturopathic medical education has only become more complex and rigorous over the same time period.

The Naturopathic Doctor degree continues to meet all the criteria of being a professional degree:

• Rigorous Education: Naturopathic medical education follows consistent accreditation standards by institutions recognized by the U.S. Department of Education, and is a demanding four-year, post-baccalaureate doctoral program.

• Required for Licensure: The degree is a requirement for licensure in 26 U.S. jurisdictions, placing it on par with other recognized medical degrees.

• Meets Established Standards and Congressional Intent: The naturopathic profession meets all benchmarks and regulatory definitions for a “professional degree” that were referenced in the One Big Beautiful Bill (34 CFR 668.2). Congress clearly intended a wide range of health professions to fall under the definition of professional degrees, which aligns with the realities of today’s health workforce.

Further, excluding NDs and other integrative medicine providers directly undermines the stated efforts of the Department of Health and Human Services (HHS) to prioritize preventive care, whole-person health, lifestyle and nutrition. These principles are the core expertise of naturopathic physicians, whose work is essential to addressing the nation’s chronic disease crisis.

4. The Domino Effect: From Student Debt to Patient Care

This proposed administrative rule will inevitably cascade from student finances to a nationwide patient access crisis. The consequences of creating such a significant financial barrier to entry for these professions are predictable and severe, creating a domino effect that will be felt in communities across the country.

• Crippling Student Debt: Aspiring practitioners will be forced to seek out higher-interest, private loans that lack crucial federal protections or abandon their educational goals entirely. For students in programs requiring extensive unpaid clinical hours, this is not just a burden; it is a barrier that will force a generation of healers to take on ruinous debt or abandon their calling altogether.

• Exacerbating Workforce Shortages: By making education financially unattainable for many, this rule will directly reduce the number of future NDs, NPs, PAs, PTs and other clinicians entering the field. This will significantly worsen the already severe national shortage of primary care providers at the exact moment the need is surging.

• Reducing Patient Access: Ultimately, patients will bear the final cost. The more than 6 million Americans who rely on NDs for their primary care, and the tens of millions more who depend on nurses, PAs, physical therapists and other professions will face severely limited access to care. This impact will be most acute in rural and underserved areas where these practitioners are often the sole providers.

This policy creates a problem that harms students, providers, and patients alike. Fortunately, the solution is clear, and our collective voice can achieve it.

5. Our Call to Action: Protecting the Future of Our Professions

As a practitioner, student or supporter of integrative medicine, your voice is essential in opposing this proposed rule change. We must act now to send a clear, united message to federal policymakers before the rule is finalized. The Department of Education will open a public comment period in early January. In the meantime, we need Congress to make their intentions clear.

We call on Congress and the Department of Education to broaden the definition of “professional degrees” to explicitly include the Doctor of Naturopathic Medicine (ND) and other health professions to meet the needs of the modern health care landscape.

Take action through the AANP Legislative Action Center: https://naturopathic.org/page/LegislativeActionCenter#/.

Personalize the provided letter templates with your own story about the vital role naturopathic and integrative practitioners play in primary care.

This moment will shape the future of naturopathic medicine and integrative health for decades. If this rule stands, it will undo years of progress, restrict our workforce, and limit patients’ access to whole-person, preventive care.

Reference:

1 www.ed.gov/media/document/rise-section-685102-definitions-november-5-2025-112658.pdf, accessed 12.15.25.

Laura Culberson Farr is the executive director of the Association of Naturopathic Physicians (AANP), leading efforts to advance recognition and access to licensed naturopathic medicine in the US. With nearly 30 years of advocacy experience, she has served as AANP executive director since 2017, where her leadership has helped achieve licensure in several states and supported ongoing initiatives nationwide. Previously, she led the Oregon Association of Naturopathic Medicine, expanding prescribing authority and Medicaid access for naturopathic doctors. Before her work in naturopathic medicine, Farr was a lobbyist and government affairs consultant in Oregon, managing successful campaigns for Vote by Mail, smokefree workplace laws, and tobacco control. Her expertise in health care reform and collaboration among providers and insurers has been instrumental in integrating naturopathic medicine into primary care.