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Have any recent rule changes or guidance (2024–2026) altered which degrees are considered professional vs nonprofessional?
Executive summary
The Department of Education (ED) has proposed and negotiated new regulatory language tied to the 2025 One Big Beautiful Bill Act (OBBBA) that narrows which programs it will treat as “professional degrees,” with practical consequences for loan caps and eligibility; reporting and stakeholder letters indicate nursing, public health, audiology, speech‑language pathology, physician assistant programs and other health and education fields are among those affected [1] [2] [3]. The changes come through negotiated rulemaking and an ED proposal that would sharply reduce the list of programs counted as professional (from roughly 2,000 to fewer than 600, by one account) and set new substantive criteria (doctoral level, six years of instruction, matching certain CIP codes) that many current programs do not meet [4] [5] [1].
1. What changed and why it matters: loan caps and program status
Under OBBBA’s new loan framework, ED is implementing annual and lifetime caps tied to whether a program is classified as “professional”; programs labeled professional can access higher loan amounts and different lifetime limits, so redefining the category directly changes students’ borrowing access and cost of attending particular programs [6] [1]. Multiple outlets report ED’s negotiated rules would limit the number of programs eligible for the higher professional limits to a much smaller list, meaning many health, education and allied professions could face lower federal borrowing limits [1] [7].
2. How ED is defining “professional degree” now: criteria and process
ED’s proposed definition — developed in negotiated rulemaking through the RISE committee — emphasizes specific criteria: most programs must be doctoral level (with narrow exceptions), require at least six years of academic instruction (including post‑baccalaureate years), and fall within a small set of CIP code matches or be among roughly 11 explicitly named professions [5] [8]. The negotiated‑rulemaking documents and ED briefings show the department aimed to replace a decades‑old, broader interpretation with a narrower, criteria‑based test to decide professional status [8] [5].
3. Which degrees reporting says were excluded or at risk
News outlets and professional associations list fields reported as excluded or at risk under ED’s proposal: nursing (MSN, DNP), public health (MPH, DrPH), audiology, speech‑language pathology, physician assistant, occupational and physical therapy, social work, education master’s degrees, accounting, architecture and others [9] [3] [10]. Advocacy groups such as the Association of Schools and Programs of Public Health (ASPPH) and ASHA explicitly warned that public health and audiology/speech‑language programs are excluded by the proposed language [2] [3].
4. What stakeholders are saying — competing perspectives
Universities, professional organizations and state nursing groups say exclusion will reduce access to critical workforce pipelines and make advanced training unaffordable, arguing the longstanding practice had recognized these as professional credentials and the ED move is abrupt and harmful [9] [2] [3]. ED officials and some negotiators counter that the department is returning to a historical regulatory definition and that consensus language emerged from a committee including higher‑education representatives, framing the move as restoring disciplined limits on which programs get higher taxpayer‑backed borrowing [9] [10].
5. Rulemaking status and effective dates — what remains unsettled
ED released a proposed rule and negotiators circulated draft lists and CIP code mappings; the department expected to finalize rules in spring 2026 at the latest in some reporting, and multiple outlets note implementation for some loan changes slated for July 1, 2026 — but negotiated rulemaking, public comment, and final rule timing mean the classification and its practical effects could still change before becoming binding [11] [10] [8]. Available sources do not provide a final, published federal regulatory text as of the reporting cited here [5] [10].
6. How to follow or challenge the changes — where groups are focusing
Professional associations (nursing, public health, speech and hearing, universities) have urged ED to revise the proposal or explicitly add programs to the professional list and are preparing public comments and advocacy campaigns; some outlets urge lawmakers to intervene because the loan caps are set by statute while ED’s rule would determine which programs qualify for higher statutory limits [2] [3] [9]. ED convened RISE and shared partial CIP code lists with negotiators to help institutions identify affected programs, indicating a continued rulemaking dialogue rather than a finished change [8].
Limitations: reporting is based on ED proposals, negotiated‑rule drafts, stakeholder letters and press reporting; the final regulatory language and any judicial or congressional responses were not available in the cited coverage [5] [10].