Founded in 1976, NCSPP is an organization composed of delegates from programs and schools of professional psychology.
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NCSPP Statement on Federal Loan Limitations (Public Law 119-21)
On behalf of the National Council of Schools and Programs of Professional Psychology (NCSPP), we express deep concern regarding the proposed federal loan limitations outlined in Public Law 119-21. As currently written, the bill caps graduate borrowing at $20,500 annually and $100,000 in total, while granting higher limits ($50,000 annually, $200,000 lifetime) only to medicine (M.D.), pharmacy (Pharm.D.), and law (J.D.). Doctoral programs in Health Service Psychology (Psy.D. and Ph.D.) are not explicitly included, despite clearly meeting the standards and societal function of professional graduate education. The proposed elimination of Graduate Plus loans, which support students’ ability to pursue advanced training, would further harm access for low-income borrowers and diminish the workforce of well-trained clinicians available to address urgent mental health needs.
This omission threatens the nation’s ability to train and sustain a sufficient workforce of licensed clinical psychologists at a time of high demand and widespread shortages. The 2024 HRSA State of the Behavioral Health Workforce Analysis shows both current and projected gaps, with one-third of the U.S. population living in a mental health professional shortage area.
Professional Psychology Is a Critical Health Profession
Doctoral programs in Clinical and Counseling Psychology (Psy.D. and Ph.D.) train Health Service Psychologists: doctoral-level, licensed providers of evidence-based care. These graduates serve in community mental health centers, VA hospitals, schools, integrated primary care, correctional institutions, private practice, and high-need federal and state systems, including the Department of Veterans Affairs, the U.S. Military, and the Federal Bureau of Prisons.
The training required for licensure as a Health Service Psychologist is rigorous and extensive. Per the criteria outlined in 34 C.F.R. § 668.2, Health Service Psychology programs are doctoral-level, professionally regulated, lead to licensure in a recognized field, and are offered at accredited institutions of higher education. Programs typically require five to seven years of coursework and supervised clinical training, comprehensive examinations, a year-long full-time internship, and, in most, a dissertation or capstone project. Graduates must then complete a year of supervised post-doctoral service to be eligible for licensure. The financial demands of this professional pathway are significant, making federal loans essential for many students, particularly those from underrepresented and underserved backgrounds.
Unclear Policy Language Risks Unintended Exclusion
The current version of Public Law 119-21 leaves “professional program” undefined. By naming only M.D., Pharm.D., and J.D. programs, it risks excluding doctoral programs in Health Service Psychology from higher borrowing limits, despite their alignment with every defining characteristic of professional doctoral education. Coupled with the elimination of Graduate Plus loans, such exclusion could have immediate consequences:
- Reduced access to doctoral training for students who rely on federal loans;
- Declining enrollment in programs that train mental health providers;
- Workforce shortages in critical areas including veterans’ services, rural communities, correctional institutions, and integrated primary care;
- Disproportionate barriers for underrepresented and economically disadvantaged students.
Our Recommendation
NCSPP urges lawmakers and regulatory agencies to explicitly include doctoral programs in Health Service Psychology (Psy.D. and Ph.D. in Clinical and Counseling Psychology) among the “professional programs” eligible for higher loan caps. These programs clearly meet professional criteria and are vital to the nation’s health, well-being, and public safety.
We stand ready to collaborate with professional organizations and training councils to advocate for clarity in legislation and to ensure sufficient financial resources remain available for students completing the education and training required to produce competent, licensed clinicians.
Conclusion
The consequences of vague language and inadvertent exclusion will reverberate across classrooms, clinics, correctional facilities, and communities in need. Professional psychology is, unequivocally, a professional graduate education. It must be explicitly recognized in the rulemaking and implementation of this law. Failure to do so would create unnecessary barriers to training psychologists and would harm the nation’s ability to meet its urgent mental health needs.