By Jessica Irving Marschall, CPA, ISA AM
President and CEO, The Green Mission Inc., GM-ESG, and Probity Appraisal Group
President and CEO, Marschall Accounting Services LLC
May 8th, 2026
In early May 2026, the U.S. Department of Education issued final regulations implementing the One Big Beautiful Bill Act provisions governing federal graduate student loan eligibility, identifying the graduate and doctoral programs that qualify as “professional degree” programs. After a comment period during which the American Institute of CPAs, the National Association of State Boards of Accountancy, the American Accounting Association, dozens of state CPA societies, and accounting educators across the country urged reconsideration, the Department again left accounting off the list. The eleven fields the Department recognized as professional, for purposes of this federal student-loan classification, are law, medicine, pharmacy, dentistry, chiropractic, optometry, osteopathic medicine, podiatry, veterinary medicine, clinical psychology, and theology. Nursing, engineering, architecture, and accounting were among the long-recognized fields excluded.
The financial consequence is direct and beginning July 1, 2026, students pursuing programs on the Department’s professional-degree list will be subject to federal borrowing limits of $50,000 per year and $200,000 in aggregate, while other graduate students, including those in accounting, will generally be capped at $20,500 per year and $100,000 in aggregate. Tuition for a Master of Accountancy program often exceeds those graduate limits before living expenses are added in.
The Department has been clear that “professional degree,” as the term is used in this rule, is a federal student-loan classification, not a judgment about whether a given field qualifies as a profession in any broader sense. That distinction is true and worth acknowledging. It is also incomplete. Words shape perception, and the public reads “non-professional” as exactly that, even when the underlying designation is administrative rather than substantive.
I write as someone who has practiced as a Certified Public Accountant since 2003 and in the accounting profession since 1998. My current professional responsibilities include being CEO of four tax-related companies and I serve as Treasurer and Board member for two non-profits. Additionally, I am a part-time CFO of two additional software technology companies. CPAs have a rare set of skills that allow us versatility in business organizations. I employ accountants, hire accountants, and rely every day on the work of accountants in audit, tax, advisory, valuation, and appraisal. The Department’s framework does not match what I have observed for more than two decades and potentially undermines the
The Path to CPA Licensure Is Rigorous by Any Honest Measure
To sit for the Uniform CPA Examination, candidates must complete 150 semester credit hours of qualifying coursework. That is 30 hours beyond a standard bachelor’s degree. The Department of Education itself acknowledged in its final regulations that most institutions require less than 150 credit hours to graduate. Candidates routinely complete the additional 30 hours through a Master of Accountancy or comparable graduate program, even though a master’s degree is not formally required.
The CPA exam itself is one of the more difficult professional examinations in the United States. According to the AICPA, candidates must score a minimum of 75 on a scale that runs from 0 to 99 to pass each section. Scores are not curved. The current CPA licensure model requires candidates to pass three Core sections, which are Auditing and Attestation (AUD), Financial Accounting and Reporting (FAR), and Regulation (REG), and one Discipline section selected from Business Analysis and Reporting (BAR), Information Systems and Controls (ISC), or Tax Compliance and Planning (TCP).
The 2025 cumulative pass rates published on the AICPA’s CPA Exam scoring and pass rates page tell their own story. AUD was 48.21 percent. FAR was 42.12 percent. REG was 63.12 percent. BAR was 41.94 percent. ISC was 67.79 percent. TCP was 77.65 percent. Several CPA Exam sections continue to produce pass rates below 50 percent. After passing all four required sections, candidates must complete a year of supervised work experience under a licensed CPA before they can be licensed in most states.
Licensure does not end the obligation. CPAs are bound by a code of professional conduct, are subject to discipline by their state board of accountancy and must complete continuing professional education annually to maintain their licenses. These are the structural features of any profession.
The Profession Is Older Than Most of the Fields on the Department’s List
The first state law in the United States authorizing the title of Certified Public Accountant was passed in New York in 1896. NASBA President and CEO Daniel J. Dustin, CPA, made the point directly in his Association’s November 2025 statement opposing the federal reclassification, observing that there is a reason certified public accountancy has been a licensed profession in the United States since 1896. Public protection through licensure has been a foundational feature of CPA practice for nearly 130 years.
CPAs Hold the Senior Roles That Run American Business
Walk into any well-run public company, mid-market firm, or non-profit and you will find CPAs at every level of financial leadership. Controllers, Chief Accounting Officers, Chief Financial Officers, audit committee members, and a meaningful share of Chief Executive Officers carry the CPA credential. The credential signals technical depth, ethical accountability, and a tested capacity to make professional judgments under pressure.
The U.S. Bureau of Labor Statistics projects employment for accountants and auditors to grow approximately 5 percent through 2034, faster than the projected 3 percent average growth across all occupations. That projection reflects the reality that accountants are essential to financial reporting, capital allocation, regulatory compliance, and economic stability. The Department of Education’s own description of the profession, embedded in the preamble to its final regulations, conceded that accounting work “implicates public trust and economic stability.” That sentence describes a profession.
The Talent Shortage the Country Cannot Afford to Worsen
Industry data has been consistent for several years. The CFO Pulse Survey reported that 83 percent of finance leaders could not find qualified accounting talent in 2024, up from 70 percent in 2022. Inside Public Accounting reported that the share of CPA-licensed staff in public accounting firms fell from 56 percent in 2020 to 48.4 percent in 2024, with the largest firms reporting that only 41.5 percent of their professional staff held a CPA license. The American Accounting Association and AACSB have both warned that retirements among accounting faculty over the next five to ten years could create a structural shortfall in the pipeline of CPAs entering the workforce.
A federal policy that effectively halves graduate-school borrowing capacity for accounting students will not improve those numbers. AAA President Mark Beasley said in his statement opposing the regulation that the rule works against the public interest by discouraging students from pursuing the kinds of training and education and knowledge development required to make the professional judgments on which the capital markets depend.
Why the Definition Matters Beyond the Loan Cap
The Department of Education has stated that its list is a federal student-loan classification, not a broader judgment about which fields constitute professions. That is the technical posture, and it is fair to acknowledge it. It is also true that federal regulations are read by employers, guidance counselors, parents of prospective accounting students, and the students themselves. When the federal government places nursing, engineering, architecture, and accounting outside the line that defines the term “professional degree” for federal student-loan purposes, the framing influences how those careers are perceived, how aggressively schools recruit into them, and how comfortable students feel taking on the educational debt required to enter them.
For accounting, the framing is at odds with the structural reality. CPAs are state-licensed. They are governed by codes of ethics. They are subject to mandatory continuing professional education. We actually must ensure 120 hours of credit over a rolling 3-year period. Attorneys are typically required to do 20 hours per year and CME for medical are between 20-150 on a three year rolling basis. Accountants sit for an examination on which some sections continue to produce pass rates below 50 percent. They serve in roles whose accuracy and integrity are necessary preconditions for capital markets, federal tax administration, charitable contribution compliance, governmental financial reporting, public company financial reporting and audit, and private business valuation. The work matters, and the people who do it are professionals.
Closing Thought
The Department of Education was directed by Congress to implement a loan-eligibility framework. It drew a line, and the line excluded accounting. The Department was within its statutory authority to make that choice. Its choice does not change what accounting is.
Accounting is a profession. It has been a licensed profession in this country since 1896. It will continue to be one regardless of where the federal student-loan rules draw their boundaries. The more useful question now is whether Congress will revisit the framework when the workforce consequences become visible, and whether the accounting profession itself will use this moment to communicate, more clearly than ever, the rigor and the public-interest mission that have defined CPA practice for more than a century.
Sources
Cohn, M. “Education Dept. rejects accounting as professional degree.” Accounting Today, May 2026.
Cohn, M. “AICPA, NASBA object to Education Dept. downgrade of accounting as professional degree program.” Accounting Today, November 2025.
Cohn, M. “AAA urges Ed. Dept. to recognize accounting professional degrees.” Accounting Today, November 2025.
National Association of State Boards of Accountancy. “NASBA Responds to Federal Reclassification of Accounting Degrees as ‘Non-Professional.’” November 25, 2025.
AICPA. “Learn more about CPA Exam scoring and pass rates.” AICPA & CIMA, April 2026.
Cardenas, A. “Less than half of public accounting staff hold CPA licenses: Trial Balance.” CFO.com, July 2025.
AACSB Staff. “Rebuilding the Pipeline for Accounting Talent.” AACSB Insights, June 2025.
O’Bannon, I. “Department of Education Unclassifies Accounting as a Professional Degree.” CPA Practice Advisor, November 2025.
Fortune. “Accounting is absolutely a profession, full stop.” December 2025.
