The Institute for School Counselor Advocacy & Research
The Institute for School Counselor Advocacy & Research
The Institute for School Counselor Advocacy & Research
At ISCAR, we believe that school counselors are the heartbeat of a thriving school community. From navigating mental health crises to guiding students toward their future careers, the role of a school counselor has never been more vital.
However, a new federal proposal could make it significantly harder for the next generation of counselors to enter the field.
The Institute for School Counselor Advocacy & Research
In July 2025, the One Big Beautiful Bill Act (OBBB) was signed into law, aiming to simplify the federal student loan system. On the surface, simplification sounds positive. However, the Department of Education’s proposed rule to implement this law—the “Reimagining and Improving Student Education” (RISE) rule—contains a technicality that could have devastating real-world consequences.
The rule establishes two tiers of graduate students: “Professional Students” (who have access to higher loan limits) and everyone else. As it stands, school counseling—a field requiring 60+ graduate credits, state licensure, and hundreds of hours of unpaid internships—would not be explicitly recognized as a professional degree in this context any longer.
This is more than a labeling error; it is a funding crisis. By capping loans at $20,500 per year for aspiring counselors, the RISE rule creates a massive funding gap. For a student already balancing an unpaid full-time internship with high tuition costs, this gap isn’t just a hurdle—it’s a dead end.
To understand why the RISE rule is so dangerous, we have to look at the ground we are already standing on. The American School Counselor Association (ASCA) recommends a 250:1 student-to-counselor ratio. The reality, however, is a landscape of scarcity: from the 2024/2025 school year, the national average is 372:1, with states like Arizona reaching a staggering 570:1.
But the shortage isn’t just about numbers; it’s about diluting the profession itself. Across the country, we are seeing a desperate—and dangerous—move to fill these gaps by lowering the bar:
The Institute for School Counselor Advocacy & Research
When districts face 500:1 ratios and a dwindling pool of qualified applicants, the temptation is to fill the gap with warm bodies. We are seeing an increase in policies that allow underqualified individuals to serve as school counselors.
While these individuals may enter the school with the best of intentions, good intentions are not a substitute for expertise. When we replace a Master’s-level School Counselor with an underqualified individual, we aren’t just lowering a standard—we are creating a massive liability for our schools and a physical danger to our students.
School counselors are trained to distinguish between normal conflict and targeted bullying or predatory violence. A classic example of the risks involved is the landmark case Gammon v. Edwardsville (1980), in which a well-meaning but undertrained staff member attempted “mediation” between a bully and a victim. Because they didn’t understand the power dynamics or the escalating threat, the intervention backfired, resulting in a student suffering a skull fracture.
The Institute for School Counselor Advocacy & Research
Underqualified staff often lack the training to conduct Lethality Assessments. These assessments identify the difference between a student having a bad day and a student at active risk for suicide or self-harm. Additionally, trained school counselors recognize behaviors that require mandated reporting. Master’s-level training provides deep dives into the subtle signs of abuse and neglect that a layperson might miss, resulting in a child or the community suffering.
A school counselor is often a leader for 504 plans and a key player in Individualized Education Programs (IEPs). These are not just suggestions; they are federal civil rights documents. When an underqualified individual who doesn’t understand the legal nuances of the Individuals with Disabilities Education Act (IDEA) they could inadvertently deny a student their right to a Free Appropriate Public Education (FAPE). This leads to systemic failure for students with disabilities and opens school districts up to massive, costly lawsuits.
School counselors operate under a strict code of ethics regarding confidentiality and professional boundaries. Underqualified staff—particularly those from religious backgrounds—may struggle to maintain the secular, inclusive boundaries required in a public school setting.
Students from LGBTQ+ backgrounds or minority faiths may feel coerced rather than counseled, effectively severing their only link to school-based support. When the counselor is just a generalist, students lose the social capital (the college-access expertise and career-path support) that only a trained professional provides.
The Institute for School Counselor Advocacy & Research
This is why the RISE rule’s failure to designate school counseling as a professional degree is so dangerous. By creating a funding gap for graduate students, the federal government is effectively subsidizing the deskilling of our schools. If the government makes it financially impossible to earn a Master’s degree, school districts will have no choice but to hire underqualified candidates. And if the federal government treats those with advanced degrees as non-professionals, it gives local districts a green light to continue hiring untrained staff. It validates the idea that a school counselor is just a generalist rather than a licensed mental health professional. We are watching a race to the bottom where the losers are our children.
When we make it harder for qualified professionals to enter the field, we aren’t just creating a shortage—we are creating a safety gap. At ISCAR, we refuse to stand by while the invisible bridge is dismantled. School counseling is a high-stakes, high-impact profession. The designation of professional student must reflect the magnitude of the impact counselors have on our nation’s children.
We have officially submitted our dissent to the Department of Education. We are calling on the Secretary to recognize that you cannot solve a national shortage by making the path to entry more difficult and the role itself less respected.
The Department needs to hear from the people on the front lines. They need to know that we cannot afford a budget-friendly alternative to a trained brain.
Let’s ensure that the bridge to a student’s future remains open, accessible, and staffed by the licensed professionals they deserve.
The Institute for School Counselor Advocacy & Research
Government & Legal Documents
Professional Standards & Statistics
State Legislation (Professional Dilution)
The Institute for School Counselor Advocacy & Research
Advocacy is not a solo endeavor—it is a collective resonance.Whether you are navigating role ambiguity in a school building, drafting policy at the state level, or conducting groundbreaking research in a university lab, your experience is the data that drives our mission. We would love to hear your journey and see how we can strengthen your purpose.