Department of Education RISE Comment from Academy of Pelvic Health Board of Directors 

Docket No: ED-2025-OPE-0944-0001

Subject: Formal comments regarding the Department of Education RISE committee’s proposed rule to classify physical therapy degrees as “graduate” and limit annual federal loans to $20,500 and a $100,000 aggregate limit

To whom it may concern: 

The Academy of Pelvic Health Physical Therapy (a component of the American Physical Therapy Association) is a 501 (c) (6) non-profit professional membership association of more than 4,000 physical therapists (PTs), physical therapist assistants (PTAs), and student physical therapists (SPTs). We would like to provide our comments regarding the recent rule proposal from the Department of Education RISE Committee regarding the classification of the physical therapy degree as “graduate” and the limitations on federal student loans. The Academy respectfully urges the Department to classify the Doctor of Physical Therapy (DPT) degree as a professional degree rather than a graduate degree, in order to preserve access to federal student loan levels consistent with other healthcare professional programs.

A Workforce Deficit Exists in the Field of Physical Therapy

The American Physical Therapy Association (APTA) recently published A Physical Therapy Profile: Demographics of the Profession, 2025, based on survey data from more than 4,400 physical therapists and incorporating data from the Bureau of Labor Statistics and the U.S. Census Bureau. The report estimates approximately 400,000 practicing physical therapists nationwide, with an annual workforce growth rate of 2–4%. However, more than half of respondents reported shortages in their geographic area, particularly in the South and West. Additionally, 7.4% of physical therapists reported plans to leave the profession within two years, and 16.2% plan to reduce their clinical hours. When projected attrition is considered alongside modest growth rates, existing workforce shortages are likely to intensify.

The proposed rule to limit federal loans that physical therapy students can borrow will have a rapid and significant impact on the number of students who can apply to physical therapy school and eventually become physical therapists. Existing shortages will continue to grow, negatively impacting not only physical therapists and patients but the healthcare system, which will become even more burdened with chronic illness, injury, and expensive interventions. 

Geographic disparities further illustrate the fragility of the workforce. States with the highest ratios of physical therapists per 100,000 residents include Maine (152), Connecticut (148),  Vermont (146), Montana (136), and South Dakota (132). The states with the lowest ratio of PTs per 100,000 people are Hawaii (20), New Mexico (46), Alabama (62), Washington D.C. (63), and Georgia (64). National loan restrictions fail to account for these regional workforce gaps and may disproportionately impact already underserved areas. These underserved regions may see rises in chronic pain conditions as patients may have to delay their utilization of physical therapy services even longer.  

Workforce shortages are particularly pronounced in specialty areas. A recent study (Cline et al 2024)  investigated the number of certified pelvic health physical therapists (PHPT) across the United States. The number of certified PHPTs found in this study is severely low and demonstrates why most PHPTs have waitlists of 3-5 months for new patients. The study found only 1135 PHPT across the United States. The lowest ratio occurred in Alabama, with 1 PHPT per 1 million people, and the highest ratio occurred in Oregon, with 8 PHPT per 1 million people. A postpartum patient may call a PHPT’s office at 6 weeks postpartum after their ob-gyn recommends they start pelvic physical therapy to address bowel, bladder issues, and pain, limiting their ability to participate in daily activities and childcare. Current wait times for this patient to get the care she needs is on average three months. If new physical therapist graduation rates are restricted due to severe loan restrictions, that waitlist may increase significantly. This situation will create a negative cascade of impact on the communities we serve. That same patient may no longer benefit from the conservative and cost-effective care they receive in physical therapy and instead be forced to pursue more invasive and costly interventions, such as urethral sling procedures, surgery for pelvic organ prolapse, and potentially addictive medication to manage pain. The research demonstrates that when this happens, often individuals are unable to return to work at their full capacity due to pain and disability. 

Broad access to the profession for individuals from a wide range of economic and community backgrounds

Financial barriers have measurable academic and professional consequences. Studies have demonstrated an association between financial stress and lower academic performance among physical therapy students  (Keles, M.N. et al 2025). Reductions in student loan availability may require students from lower socioeconomic backgrounds to take on employment or rely on higher-interest private loans. Elevated financial stress may negatively impact academic performance and persistence to graduation.

Moreover, increasing borrowing barriers may deter qualified applicants from lower-income backgrounds from pursuing physical therapy education altogether. Such barriers may limit socioeconomic mobility and reduce the diversity of the healthcare workforce. Current workforce data already demonstrates demographic disparities.  According to the APTA Physical Therapy Profile referenced above, 81.1% of PTs in the US identify as White compared to 74.8% of the overall  U.S. population. Only 3.7% of PTs are Black or African American, while the U.S. population is 13.7% Black or African American according to the Current Population Survey (CPS). Policies that reduce financial access to physical therapy education risk exacerbating these disparities. 

Evidence suggests that a more representative healthcare workforce is associated with improved patient outcomes and reduced mortality in underserved populations. Supporting access to federal student loans at levels consistent with other healthcare professional degrees supports broader workforce diversity, improves patient trust and outcomes, and contributes to long term healthcare system sustainability (Snyder, J.E. 2023).

Detrimental Effects for Physical Therapy Programs 

Restrictions on federal student loan funding may reduce enrollment, resulting in decreased tuition revenue, leading to reductions in faculty positions. The increased workload on remaining faculty may lead to programs failing to meet accreditation standards.

While not all programs will suffer from withdrawal of accreditation or probation, all programs will likely suffer from a decrease in the quality of the education provided for their students. The quality of the physical therapy profession has grown substantially since 1985 with the initiation of specialist certifications. Currently, 10% of physical therapists have a board certification and an average 2585 new specialists annually (APTA Physical Therapy Profile, 2025). Board-certified clinical specialists have advanced knowledge in differential diagnosis, evaluation, and treatment techniques. They are able to improve patient outcomes most efficiently, but also have a lower burnout rate than their peers. Board-certified specialists, on average, earn $4,540 more annually than PTs who are not board-certified (APTA Physical Therapy Profile, 2021-22). This trend is particularly important in regard to a physical therapist’s ability to pay back federal student loans. Many PT programs have an important role in residency programs that produce board-certified specialists. As programs are forced to reduce expenses, residency programs attached to PT programs will be one of the first areas to be reduced or eliminated. Even if a program does not have a residency program, the quality of education will be reduced due to the above mentioned faculty reductions, increased workload placed on remaining faculty, and decreased access to higher levels of technical equipment. The decrease in quality will likely lead to graduates who are not as motivated or have the knowledge and skills to pursue a board certification in their career.

Support of Tuition Reform

The APTA Academy of Pelvic Health supports tuition reform for physical therapy schools, including decreasing student loan interest rates, increasing availability of subsidized loans, efforts to include physical therapists in the National Health Service Corps Loan Repayment Program, and giving Federally Qualified Health Centers (Community Health Centers/CHCs) options and flexibility to provide patient access to PT services. The proposed rule from the RISE committee and significant limitations on federal student loans do not offer a sustainable approach to long-term tuition reform that supports or at least maintains the current healthcare workforce. 

Conclusion

The APTA Pelvic Health urges the Department of Education to classify the Doctor of Physical Therapy degree as a professional degree, ensuring federal loan eligibility consistent with other healthcare professional programs.

Thank you for your consideration, 

Board of Directors

APTA Academy of Pelvic Health Physical Therapy

References: 

1. American Physical Therapy Association. A Physical Therapy Profile: Demographics of the Profession, 2025. Published December 10, 2025. Accessed [Accessed February 23, 2026]. https://www.apta.org/apta-and-you/news-publications/reports/2025/demographics-profession

2. Cline, Sarah A. PT, DPT; McLaughlin, Kevin PT, DPT; Arnold, Nora PT, DPT; Austin, Mary M. PT, DPT. Distribution of Certified Pelvic Health Physical Therapists Across the United States. Journal of Women's & Pelvic Health Physical Therapy 48(4):p 242-248, October/December 2024. | DOI: 10.1097/JWH.0000000000000312 

3. Keles, M. N., Yesiloglu, A., & Inal Ozun, O. (2025). The role of demographic and psychosocial factors in academic achievement: insights from a cross-sectional study on physiotherapy and rehabilitation students. BMC Medical Education, 25(1), 361. https://doi.org/10.1186/s12909-025-06958-6

4. Snyder, J. E., Upton, R. D., Hassett, T. C., Lee, H., Nouri, Z., & Dill, M. (2023). Black Representation in the Primary Care Physician Workforce and Its Association With Population Life Expectancy and Mortality Rates in the US. JAMA Network Open, 6(4), e236687. https://doi.org/10.1001/jamanetworkopen.2023.6687

5. American Physical Therapy Association. A Physical Therapy Profile: Demographics of the Profession, 2021-22. Published July 18, 2023. Accessed [Accessed February 23, 2026]. https://www.apta.org/apta-and-you/news-publications/reports/2023/physical-therapy-profile-demographics-profession-2021-22