Federal Student Loan Limits and Occupational Therapy: What You Need to Know

The U.S. Department of Education has indicated changes to federal student loan rules that, as currently interpreted, misrepresent how occupational therapy (OT) education, certification, and licensure function in practice.

Through its recently released Reimagining and Improving Student Education (RISE) proposal, the Department plans to cap the amount of federal student loans available for students enrolled in certain graduate programs, including occupational therapy. There would be an annual borrowing limit of $20,500, with an aggregate lifetime borrowing limit of $100,000.

With this proposal, occupational therapy exam eligibility language is interpreted in a way that treats certification exam eligibility pathways as if they are alternatives to professional education and licensure. The reality is that U.S.-educated individuals cannot become NBCOT certified, obtain a state license, or practice occupational therapy in the U.S. without graduating from an accredited OT graduate program. This is the only pathway for U.S.-educated individuals to be eligible for NBCOT certification and state licensure.

The interpretation appears to rely on NBCOT’s Occupational Therapist Eligibility Determination (OTED®) process. OTED is a post‑professional, immigration‑related credential evaluation for internationally educated occupational therapists who have completed their OT professional education abroad and, where applicable, who have met regulatory or practice requirements in their country of education. It is not an educational pathway for U.S. students, and it is not connected to U.S. student enrollment or federal student loans.

In 2025, 8,333 individuals earned NBCOT certification through U.S.-accredited graduate occupational therapy education, while less than 100 individuals earned certification through the OTED process. OTED represents a distinct, post-professional pathway and is not reflective of U.S. occupational therapy education pathways.

Using a post‑professional immigration process to inform how U.S. graduate programs are classified for federal student aid misrepresents how occupational therapy education and licensure function.

See pages 37–38 and page 60 of the Department’s proposal.

How You Can Help Clarify the Record

Public comment is critical and open only until March 2, 2026. Comments can be submitted through the Federal Rulemaking Portal.

When submitting comments, it is helpful to explain the misinterpretation in your own words. Some examples include:

• Occupational therapy requires completion of an accredited graduate program for licensure and independent practice in all U.S. jurisdictions.
• Certification exam eligibility does not replace or bypass professional education or licensure requirements.
• Post‑professional exam eligibility pathways for internationally educated occupational therapists exist for immigration and workforce entry purposes and are not educational alternatives for U.S. students.
• Using post‑professional credential evaluation processes to classify U.S. graduate programs creates confusion and should not determine federal student loan eligibility.

You may also choose to share how the proposed rules could affect students, programs, workforce availability, or access to care based on your own experience.

Another way to help is to contact your U.S. Representative and Senators; let them know about these clarifications and emphasize the importance of accurate interpretation of occupational therapy education and licensure requirements.

NBCOT will continue working with policymakers and partners to clarify this issue and ensure the final rules accurately reflect occupational therapy education and licensure pathways.