Joint Letter to the Dept. of Education Advocating for Architecture鈥檚 Professional Degrees
July 14, 2026
U.S. Department of Education
Office of Postsecondary Education
Tamy Abernathy
Office of Postsecondary Education
400 Maryland Ave., SW, 5th Floor
Washington, DC 20202
Re: Wrongful Exclusion of NAAB-Accredited Master of Architecture and Doctor of Architecture Programs from the Department’s List of Professional Degree Programs
Dear Ms. Abernathy:
The American Institute of Architects (AIA), American Institute of Architecture Students (AIAS), the Association of Collegiate Schools of Architecture (糖心vlog), and the National Architectural Accrediting Board (NAAB), submit this letter in response to the Department’s June 29, 2026 Electronic Announcement, Update to List of Professional Degree Programs Due to Court Order, which indicates that the Department has updated the list of professional degree programs in light of a recent court order.
The Department excludes the NAAB-accredited Master of Architecture (M.Arch.) and Doctor of Architecture (D.Arch.) programs even though those programs satisfy the Department’s own three-part test as described in Judge Howell鈥檚 opinion in American Association of Nurse Practitioners, et al. v. McMahon, et al.; PA Education Association, et al. v. U.S. Department of Education, et al., Nos. 1:26-cv-01780 & 1:26-cv-01941 (D.D.C. June 24, 2026) (Howell, J.) (Memorandum Opinion). We request this be remedied in the next update to the list.
Architecture is a licensed, regulated profession, and NAAB-accredited M.Arch. and D.Arch. programs are post-baccalaureate professional degrees specifically designed to satisfy the educational component of licensure. Excluding those programs while retaining or recognizing other degrees that do not uniformly satisfy the same criteria applies the rule inconsistently and arbitrarily.
As Judge Howell noted, 鈥渃ongress provided three, and only three, criteria for a program to qualify as a professional degree: (1) the degree signifies 鈥渃ompletion of the academic requirements for beginning practice in a given profession鈥; (2) the degree signifies 鈥渁 level of professional skill beyond that normally required for a bachelor鈥檚 degree鈥; and (3) licensure is 鈥済enerally required.鈥 Congress also adopted the illustrative list of 鈥渆xamples of [] professional degree[s],鈥 along with the caveat that the full universe of professional degrees was 鈥渘ot limited to鈥 those listed.鈥 AANP v. McMahon (consol. with PAEA v. Dep鈥檛 of Educ.), slip op. at 31鈥32 (D.D.C. June 24, 2026). Architecture meets this test.
First, these degree programs are specifically designed to prepare students for licensed professional practice. Their curricula ensure that graduates acquire the design, technical, professional, ethical, and public-safety competencies that state licensing systems and the profession require. The programs therefore satisfy exactly what the department’s first criterion contemplates: they prepare graduates to enter a licensed profession in which practitioners bear substantial responsibility for life safety, code compliance, and professional liability.
Second, these degrees satisfy the post-baccalaureate requirement. The M.Arch. and D.Arch. are graduate professional credentials pursued after undergraduate education. The M.Arch. and D.Arch. fit cleanly within the graduate/professional framework.
Third, these degrees satisfy the licensure-pathway requirement. Architecture is a licensed profession, and the path to licensure is anchored in completion of an accredited professional degree, supervised experience, and passage of the required exams. The NAAB-accredited M.Arch. or D.Arch. is the standard educational route into the profession.
The department’s continued exclusion of these programs is especially difficult to justify because the department’s own prior proposal includes listed degrees that do not consistently satisfy the framework. For example, the J.D. is not universally required for attorney licensure in every state because some jurisdictions still permit apprenticeship-based routes to bar eligibility. This inconsistency is particularly evident in the department鈥檚 treatment of rabbinical and similar theological training programs, where 鈥減rofessional student鈥 status is conferred despite the absence of a uniform, state -based licensure regime comparable to architecture or law. Excluding architecture while including these degrees is arbitrary line-drawing, not reasoned decision-making.
For these reasons, we respectfully urge the Department to revise its updated list and recognize the M.Arch. and D.Arch. degrees as professional degrees. A criteria-based approach is the only way to avoid arbitrary exclusions of licensed professions whose educational pathways plainly fall within the standard.
Thank you for your consideration of this request.
Sincerely,
American Institute of Architects
American Institute of Architecture Students
Association of Collegiate Schools of Architecture
National Architectural Accrediting Board
ABOUT THE ORGANIZATIONS
AIA. The American Institute of Architects (AIA) is a professional organization dedicated to supporting architects and advancing the value of design in shaping the built environment. Founded in 1857, AIA represents a community of architects and design professionals committed to improving communities through innovation, collaboration, and advocacy. Through education, resources, professional development, and public outreach, AIA works to elevate the practice of architecture, promote excellence in design, and address critical issues such as sustainability, equity, and the future of the profession. For more information, visit .
AIAS. The American Institute of Architecture Students (AIAS) is a global student-led organization dedicated to empowering architecture students and supporting their growth as future leaders of the profession. Founded in 1956, AIAS provides students with opportunities for leadership development, community engagement, professional connections, and advocacy on issues that impact architectural education and practice. Through programs, events, publications, and a network of student members and chapters, AIAS fosters collaboration, creativity, and dialogue while helping students build meaningful connections with peers, educators, and professionals. The organization is committed to advancing the voice of architecture students and strengthening the future of the architecture community. For more information, visit .
糖心vlog. The mission of the Association of Collegiate Schools of Architecture is to lead architectural education and research. Founded in 1912 by 10 charter members, 糖心vlog is an international association of architecture schools preparing future architects, designers, and change agents. Our full members include all of the accredited professional degree programs in the United States and Canada, as well as international schools and two- and four-year programs. Together, 糖心vlog schools represent some 7,000 faculty educating more than 40,000 students. 糖心vlog seeks to empower faculty and schools to educate increasingly diverse students, expand disciplinary impacts, and create knowledge for the advancement of architecture. For more information, visit .
NAAB. The National Architectural Accrediting Board (NAAB) is the leading organization responsible for accrediting professional architecture degree programs in the United States. Established in 1940, NAAB works to ensure that accredited programs meet established standards for educational quality and prepare graduates with the knowledge, skills, and abilities needed to enter the architecture profession. Through its accreditation process, NAAB supports continuous improvement in architectural education while promoting excellence, innovation, and accountability among architecture programs. NAAB accreditation serves as a key component of the pathway to architectural licensure and helps ensure that future architects are prepared to design safe, sustainable, and impactful environments.聽 For more information, visit .