AAPP joined the Advanced Professional Workforce Alliance (APWA) and other organizations to comment on the Reimagining and Improving Student Education (RISE) Notice of Proposed Rulemaking (NPRM). The letter expresses concerns regarding
the proposed definition of “professional degrees” in relation to other graduate degree programs. The concern is that the proposed framework and definition of “professional degrees” does not encompass the range of programs that fit the professional designation. Additionally, AAPP believes the definition change may severely impact individuals being able to join the behavioral health workforce where staffing shortages already exist.