Dean Giles: Public Health is a Professional Degree
Introduction
As Dean of the University of Illinois Chicago (UIC) School of Public Health, I appreciate the opportunity to provide comments in response to the Department of Education’s proposed rulemaking regarding the definition of “professional degree programs” under the One Big Beautiful Bill Act (OBBA). The UIC School of Public Health has a 55-year history as being the only fully accredited school of public health in the state of Illinois. We have trained more public health professionals than any other school in the state, and our graduates work at federal agencies including the Centers for Disease Control and Prevention, Environmental Protection Agency, National Institutes for Health, state and local health public health agencies, hospitals, research institutions, and community based organizations. Our graduates are epidemiologists who track outbreaks, health educators who build trust in communities, environmental health specialists who keep water systems safe, and the leaders who coordinate responses when crises strike. They protect communities every day by preventing disease, strengthening preparedness, responding to emergencies, and advancing healthier lives for all.
I am writing to express my concern about the proposed definition of “professional degree programs,” particularly the exclusion of public health degrees. While the proposed change may appear technical, the consequences are not. The classification of public health degrees directly affects who can afford to enter the field and whether the nation can sustain the workforce needed to improve health outcomes, reduce healthcare costs, and respond to emerging threats.
The last five years in Illinois and Chicago have demonstrated—more clearly than any time in recent history—that public health is an applied, high-stakes, professional discipline, not an academic abstraction. The public health threats facing Illinois and Chicago–including decreasing access to care, cuts to immigrant health, loss of federal engagement with the World Health Organizations (WHO), increasing environmental health threats, infectious disease threats, and an ongoing opioid crisis–provide concrete evidence that today’s health landscape requires professionals with specialized training, regulated competencies, and practice-ready skills equivalent to those expected of physicians, pharmacists, clinical psychologists, and other Department of Education recognized professional fields. We must ensure that public health trainees have sufficient financial resources to complete their degrees; the health of communities across Illinois and Chicago depends on it. Below are current threats jeopardizing the health and well-being of communities across Illinois and Chicago.
Large-Scale Medicaid Cuts Expose the Need for Professionally Trained Public Health Practitioners
Federal Medicaid reductions threaten to strip coverage from up to 330,000 Illinois residents, worsening inequities and risking hospital destabilization across the state. Cook County Health—where Medicaid accounts for 56% of payments—warns of major system strain. Reduced access to care will affect both urban and rural communities across the state. These conditions require professionally trained experts in:
- Health-policy analysis
- Epidemiology
- Community health practice
- Intervention design
- Population-and community-level needs assessment
Public health graduates must be prepared to perform complex, real-time impact analyses and help health systems absorb shocks. This is professional work that will have direct consequences for life expectancy, as seen in the 20-year gap across Chicago neighborhoods. A field responsible for safeguarding millions of residents’ access to care warrants professional status.
Cuts to Immigrant Health Programs Require Advanced Training in Equity, Systems-Level Planning and Cross-Cultural Practice
Illinois’ plan to end coverage for over 30,000 immigrant adults puts additional stress on safety-net systems and places vulnerable residents at risk. To respond effectively, Illinois needs practitioners with:
- Specialized training in cultural competence and health equity
- Professional skills in community engagement and health-system navigation
- Expertise in policy mitigation and population-impact modeling
This is applied professional work typically found in fields with Department of Education-recognized professional degrees. Public health should be no different.
Loss of Federal World Health Organization (WHO) Engagement Demonstrates the Need for Professional-Level Epidemiologic & Preparedness Expertise
After the U.S. withdrew from the WHO in 2025, Illinois lost access to key outbreak-early warning systems, forcing the state to join the WHO Global Outbreak Alert and Response Network (GOARN) independently in 2026. This underscores the professional nature of public health work, requiring trained experts capable of:
- Conducting genomic surveillance
- Operating wastewater monitoring systems
- Interpreting international outbreak data
- Coordinating with global partners
- Communicating risk to the public
These competencies mirror those expected in professionalized fields such as pharmacy, medicine, and osteopathic medicine, yet public health degrees still lack formal professional status.
Chicago’s Environmental Health Threats Require Advanced Technical, Analytical, and Community-Practice Skills
The Chicago Department of Public Health and the University of Illinois Chicago School of Public Health launched Open Air Chicago, deploying 277 hyperlocal sensors to address dangerous PM2.5 and NO₂ exposures—some of the most sophisticated community-level environmental surveillance in the country. Such efforts require:
- Environmental epidemiologists
- Exposure-science specialists
- Geospatial and data analytics professionals
- Community-engagement practitioners
These are advanced professional competencies, not merely academic ones, and merit a professional designation.
Infectious Disease Threats Underscore the Need for Professionally Prepared Workforce Capacity
COVID-19 variants. State and local public health officials continue issuing state and community-wide alerts urging vaccination and preventive measures. Responding to infectious disease threats requires:
- Immunization-program specialists
- Surveillance epidemiologists
- Public health communication experts
- Maternal and child health professionals
- Biostatisticians and informaticians
These are applied practice roles essential to real-world outcomes—fitting the definition of a professional field requiring accredited training and standardized competencies.
The Opioid Overdose Crisis Requires Professional Competencies in Harm Reduction & Behavioral Health
Illinois and Chicago have experienced dramatic declines in opioid deaths over the last three years. Illinois’ decision to expand naloxone access, including stocking reversal agents in public libraries, will help to sustain these efforts, but also reflects the escalating opioid crisis. Effective crisis response requires:
- Harm-reduction training
- Community-based intervention models
- Behavioral-health integration
- Program-evaluation expertise
- Cross-sector coordination
These are not optional skills; they are professional competencies necessary for saving lives.
Synthesis: Public Health Work Meets Every Department of Education Criterion for a Professional Field
Across all documented threats, public health professionals are responsible for:
- Protecting and safeguarding population-level health
- Operating advanced surveillance and analytic systems
- Mitigating destabilizing policy changes
- Addressing complex community-level inequities
- Managing emergency response systems
- Translating science into real-world action
These responsibilities are on par with—if not more complex than—professional fields already recognized by the Department of Education, such as pharmacy, clinical psychology, theology, and optometry. The absence of recognition for public health degrees as professional degrees diminishes the field’s credibility, complicates workforce recruitment, and hinders our institutions’ ability to expand graduate-level training that directly protects the health of Illinois and Chicago residents.
Conclusion: Federal Recognition Is Not Merely Justified; It is Necessary
Illinois and Chicago’s recent crises make one fact undeniable: Public health is a professional discipline, essential to the functioning, safety, and resilience of Illinois communities.
Public health degrees—particularly Master of Public Health (MPH), Doctor of Public Health (DrPH), Master of Healthcare Administration (MHA), and specialized master’s programs—should be classified as professional degrees. These efforts will assist in the:
- Recognition of the advanced applied competencies required for the degree
- Expansion of accredited professional training pathways
- Protection of the workforce pipeline during a period of unprecedented demand
- Alignment with other fields of comparable societal impact
- Ensure that public health trainees have the financial resources to complete their training.
The last five years have provided overwhelming evidence: public health protects the public in ways that only a professionally trained workforce can. Designating the MPH, MPA, and DrPH as professional degrees will ensure that the public health workforce will continue to protect the health and well-being of Illinois and Chicago residents.
Learn more at the Association of Schools and Programs of Public Health’s website.