IHPC Submits Federal Comments on Student Loan Policy with Implications for the Healthcare Workforce

The Integrative Health Policy Consortium (IHPC) has submitted formal comments to federal policymakers regarding proposed changes to student loan accountability frameworks that may significantly influence the future of the U.S. healthcare workforce. The proposed regulations introduce a new “value-added earnings” standard that evaluates educational programs based on the relationship between program cost and early-career earnings. While intended to promote accountability and protect students and taxpayers, IHPC’s analysis highlights important limitations in how these measures apply to healthcare professional education.

A Measurement Challenge in Healthcare Professions

Many healthcare careers—particularly those involving clinical practice, entrepreneurship, or community-based care—do not follow linear earnings trajectories. Graduates often experience a period of income development as they build patient panels, establish practices, or complete additional training. As a result, early-career earnings may not fully reflect long-term financial outcomes or the ability of graduates to successfully repay student loans.

Federal data consistently demonstrate that licensed healthcare professional programs, including integrative disciplines such as chiropractic, exhibit low cohort default rates and strong long-term repayment performance. These outcomes are driven by high program completion rates, licensure-based entry into practice, and sustained demand for healthcare services.

Potential Implications for Workforce Development

IHPC’s comments note that reliance on short-term earnings metrics may unintentionally misclassify programs that produce qualified, licensed healthcare providers as higher risk, despite strong repayment outcomes. The proposed framework may also have broader implications for workforce development. Healthcare delivery in the United States increasingly depends on a diverse range of providers, including non-MD professionals who deliver prevention-focused and community-based care. Policies that do not fully account for the economic structure of these professions could affect educational pathways and, over time, influence access to care—particularly in underserved communities.

Aligning Policy with Healthcare Objectives

IHPC’s submission emphasizes the importance of aligning student loan accountability measures with broader national healthcare goals, including:

• Expanding patient choice

• Supporting prevention-focused care

• Reducing long-term healthcare costs

• Strengthening community-based provider networks

To support these objectives, IHPC recommends that policymakers prioritize direct measures of loan performance—such as repayment and default rates—over early-career earnings metrics that may not accurately predict long-term outcomes in healthcare professions.

Looking Ahead

IHPC and its member organizations remain committed to working with federal policymakers to ensure that student loan policies support both responsible stewardship of federal resources and the continued development of a diverse and effective healthcare workforce.