Washington, DC — The American Association of Naturopathic Physicians (AANP) and the Association of Accredited Naturopathic Medical Colleges (AANMC) are calling on naturopathic physicians, students, patients, and all allies to urgently submit public comments opposing a proposed U.S. Department of Education rule that would remove the Doctor of Naturopathic Medicine (N.D.) from the federal definition of a “professional degree.” The deadline is March 2, 2026.

If finalized, the Department’s proposed “RISE” rule (Docket ID: ED-2025-OPE-0944) would slash federal student loan eligibility for naturopathic medical students by more than half—despite the fact that accredited naturopathic medical education has been recognized in federal education classification systems as a professional/first-professional degree since 1999.

This isn’t about politics. It’s about math, medicine, and common sense.

What’s at Stake

Under the Department’s proposal, ND students would be moved from the professional loan category to the graduate loan category:

• Annual loan limit cut 59%: from $50,000 to $20,500

• Aggregate loan limit cut 50%: from $200,000 to $100,000

This change would make it significantly harder—if not impossible—for many qualified students to afford naturopathic medical school, particularly those from low- and middle-income backgrounds. Dual degree and career changing students are likely to hit the loan caps before degree completion, forcing them to the private loan market – if they can qualify

Why This Matters to Patients and the Healthcare System

This proposed rule is not a debate about naturopathic medicine as a concept—it is a federal student aid eligibility decision that would directly impact:

• The viability of ND medical schools, all of which qualify as “small entities” under ED definitions

• The pipeline of licensed primary care clinicians at a time of national provider shortages

• Healthcare access, especially in rural and underserved communities where NDs are already providing primary care services

• Economic mobility, by effectively blocking access to a doctoral-level health profession for students without independent wealth

The Core Legal Problem

The Department’s proposal relies on an extra, non-statutory requirement—effectively a “majority of states” test—that does not appear in the governing professional degree definition. However, naturopathic medicine meets the three-part test in 34 CFR 668.2, The ND degree satisfies all three requirements of the legal test in 34 CFR 668.2 which was referenced in the One Big Beautiful Bill: (1) it signifies completion of academic requirements for practice; (2) it requires skills far beyond a bachelor’s degree (over 4,100 didactic, including 1,200 clinical hours); and (3) licensure is “generally required” for practice. In every jurisdiction that regulates naturopathic medicine, licensure is required without exception.

AANP/AANMC Call to Action (Deadline: March 2, 2026)

We need the profession, our patients and allies to flood messages of support:

1. Amplify the Action Alert: Forward the AANP Action Alert to your allies immediately.

2. Social Media Engagement: Like and repost AANP and AANMC social media content to boost visibility.

3. Draft Your Own Letter: Use the themes above to draft a letter on your organizational letterhead. Make it authentic—describe how this affects your specific state’s healthcare access or your community.

4. Print out the flyer for your office – and encourage patient letters.

5. Expert Review: Feel free to send a draft to executive@naturopathic.org and info@aanmc.org for a factual accuracy check before you submit.

Deadline: March 2, 2026

What to Say in Your Comment (Simple Version)

• ND is a full-time, four-year clinical doctoral program

• ND licensure is required in regulated states

• ND meets the federal “professional degree” test

• This rule would cut loan access, reduce enrollment, and shrink the healthcare workforce

• The rule threatens to increase the costs of education for students

Printable Flyer for Clinics and Offices

We’ve created a one-page flyer that doctors, clinics, and schools can print and post to encourage patient participation:

Download here: Download the flyer

Final Message

This rule doesn’t just cap borrowing — it caps the healthcare workforce.
The Department of Education should revise the final rule to ensure the Doctor of Naturopathic Medicine remains recognized as a professional degree for federal student aid purposes.

AANP and AANMC are urging every ND, student, patient, and ally to take action now.