At Whipp Educational Services, 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 Growing Gap: Policy vs. Reality
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.
A Profession Already on the Brink
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 Chaplaincy Trend: In states like Texas and Florida, new laws now allow clergy to serve as school counselors or provide support services without the rigorous training required for a Master’s degree.
- Emergency Certifications: In many districts, the shortage is being met by hiring individuals with only a Bachelor’s degree under emergency permits. These individuals are being asked to navigate complex mental health crises and academic planning without the 60+ credits of graduate specialized training the role demands.
When school districts are unclear about the school counseling role’s intent and impact , they don’t just fill a vacancy—they undermine a standard of care and risk student success.
The High Cost of the Quick Fix: Why Professional Credentials Save Lives
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.
1. The Safety Gap: Mismanaging Crisis and Conflict
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.
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.
2. The Legal Minefield: 504s and IEPs
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.
3. Ethical Erosion and Social Capital
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.
Connecting the Dots
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.
Our Stand: Advocacy for the Professional
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 Whipp Educational Services, 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.
How You Can Help
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.
- Submit your own: The public comment period for the RISE rule (Docket ED-2025-OPE-0944) is open until March 2, 2026.
- Spread the Word: Share this blog with your local school board and fellow educators so others may understand the potential impact this will have on the future of school counseling.
Let’s ensure that the bridge to a student’s future remains open, accessible, and staffed by the licensed professionals they deserve.
References
Government & Legal Documents
- Department of Education. (2025). Reimagining and Improving Student Education (RISE): Notice of Proposed Rulemaking (NPRM). [Docket ID: ED-2025-OPE-0944]. Federal Register.
- Gammon v. Edwardsville Community Unit School District No. 7, 82 Ill. App. 3d 586, 403 N.E.2d 43 (Ill. App. Ct. 1980). (Citing the liability risks of under-trained staff in student mediation).
- One Big Beautiful Bill Act of 2025 (OBBB), Pub. L. No. 119-XX (2025). (The primary legislation establishing new federal loan limits and repayment structures).
- U.S. Department of Education. (n.d.). Protecting students with disabilities: Frequently asked questions about Section 504 and the education of children with disabilities. Office for Civil Rights.
Professional Standards & Statistics
- American School Counselor Association. (2025). Student-to-school-counselor ratios 2024-2025. [Data Set]. https://www.schoolcounselor.org/ratios
- American School Counselor Association. (2024). The role of the school counselor. [Position Statement].
- National Association for College Admission Counseling (NACAC). (2020). The state of college admission. (Source for social capital).
State Legislation (Professional Dilution)
- Florida House of Representatives. (2024). HB 931: School chaplains. Florida State Legislature.
- Texas Legislature. (2023). SB 763: Relating to allowing public schools to employ or accept as volunteers chaplains to perform the duties of school counselors. Texas State Senate.
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