Penn GSE Dean Urges U.S. Department of Education to Protect Access to Graduate Training for Educators

Penn GSE Dean Katharine Strunk—one of the country’s leading scholars on the educator workforce—is urging the U.S. Department of Education to reconsider a proposed federal rule that could significantly restrict access to graduate-level preparation for educators at a time when schools across the nation face mounting workforce shortages. 

In a detailed public comment submitted on March 1, Dean Strunk argues that the Department’s proposed definition of “professional student” fundamentally misunderstands the education field. The rule—part of the Department’s “Reimagining and Improving Student Education” initiative—would exclude all graduate education programs from the category of professional degrees, cutting education students off from the higher federal loan limits for students in fields like law, medicine, and social work.

Her message is grounded not only in her role as dean, but in more than two decades of research on how policies shape who enters, stays in, and leaves education careers. That research has documented how financial barriers, preparation requirements, and policy shifts affect the supply of teachers, counselors, principals, and district leaders. 

Dean Strunk’s overall critique is that the proposal ignores the basic structure of the education labor market and the training required to enter it. Many education professions require graduate-level training and state-issued credentials before individuals can begin to practice. School counselors complete supervised clinical hours. Principals and district leaders undergo intensive leadership preparation. School psychologists earn specialist or doctoral degrees. These pathways are not elective add-ons—they are the professional standards that ensure students receive high-quality support. 

“These roles are integral to schools’ capacity to support student learning, mental health, safety, and instructional improvement,” writes Dean Strunk. “They are not optional. They are essential.” 

By excluding these programs from the “professional” category, the rule treats education as if it were a field without specialized training, licensure, or advanced expertise—an assumption that contradicts both the evidence and the lived reality of schools.

Dean Strunk also warns that this proposal risks narrowing federal loan eligibility just as districts across the country struggle to fill critical positions. Nearly one in five students attends a school without access to a counselor, and national surveys show that 40 percent of principals expect to leave the profession within three years. Reducing financial access to required preparation, she argues, will deepen these shortages. 

Those shortages are particularly acute for teachers. Data show that one in eight teaching positions nationally are either unfilled or filled by someone not fully certified. Dean Strunk argues that limiting future teachers’ abilities to take out adequate loans—while suggesting that they are not “professionals”—is especially vexing as the nation faces this growing staffing crisis. 

Graduate education is also the pathway through which many working educators advance in their careers. Many of Penn GSE’s programs, such as the School Leadership master’s, the Urban Teaching Residency, and the School and Mental Health Counseling program, are designed in part-time or executive formats so candidates can continue serving students while completing required internships and supervised clinical experiences. Yet the proposed rule defines program length only in terms of full-time enrollment—an approach that misrepresents how educators actually pursue advanced training and one that could shorten their eligibility for existing loan limits.

Dean Strunk offers clear recommendations: include credential-required education programs in the professional student category; remove or revise the proposed doctoral-level requirement; adjust the definitions of program length to reflect part-time and executive formats; and ensure supervised practice requirements are protected rather than weakened. 

Ultimately, her message to the Department is both practical and urgent: excluding education programs from the professional student definition is not a technical adjustment, it is a policy choice that will harm schools, students, and communities. Education, she writes, “is a public good—the bedrock of a free and flourishing democracy.” Preserving access to graduate training is essential to sustaining the educator workforce on which that democratic foundation depends.