Department of Education Proposed Rule Comment Period Closes – What’s Next?
On March 2, the public comment period for the Department of Education’s Reimagining and Improving Student Education proposed rule formally closed. PAEA would like to extend its sincere thanks to the many faculty, program leaders, students, clinical partners, and external stakeholders who made their voice heard on the Department’s proposal to exclude PA and other advanced and licensed health professions students from professional student classification.
Through substantive comments, including those submitted by the Association on members’ behalf, the PA education community articulated the academic rigor of the PA profession, the contributions of the PA workforce to patients’ access to care, and the statutory and regulatory frameworks that govern entry into practice. Collectively, these perspectives reinforced a clear message: PA students unequivocally meet the criteria of professional students cited in the One Big Beautiful Bill Act (OBBBA), and the implementation of the law must reflect that reality.
With the public comment period concluded, the Department of Education is expected to publish a final rule in the coming months. Once released, PAEA will carefully review the final regulatory text and update members on its implications for PA programs and students.
While the community awaits the Department’s response, legislative advocacy remains essential. Members are encouraged to continue outreach to their elected representatives to urge cosponsorship of H.R. 6718 – the Professional Student Degree Act. Further codifying professional student classification in statute would reinforce the intent of Congress established in OBBBA to include all students that meet the three-part test for professional student status. Direct engagement — including meetings, calls, and emails with congressional offices – is a critical component of making congressional intent abundantly clear.
Beyond formal advocacy channels, there are meaningful opportunities to continue raising awareness more broadly. Publishing op-eds in local or national outlets, contributing commentary to higher education and health policy publications, and engaging institutional leadership in dialogue about the issue can help shape public understanding. Faculty and program directors are uniquely positioned to explain how classification decisions affect students’ financial access, institutional compliance, and workforce development.
PAEA will continue to help facilitate these efforts, and the Government Relations team is committed to being an ongoing resource to all members.
This campaign demonstrated that when the PA education community speaks with clarity and purpose, it is heard. Thank you for investing your time and expertise in advancing a policy framework that reflects the reality of PA education.
Members and students with questions are invited to contact Tyler Smith at tsmith@PAEAonline.org.
