Which specific institutions or programs were added or removed from the professional degree list in the 2025–2026 guidance?
Executive summary
The Department of Education’s 2025–2026 “professional degree” guidance sharply narrows the set of programs treated as professional for federal loan limits, keeping roughly a small core of established fields while excluding many health, education and allied-practice programs that had previously been treated as professional by institutions and advocacy groups (for example, nursing, public health, physician assistant, PT/OT, audiology and speech-language pathology) [1] [2] [3]. The agency and its negotiated-rulemaking committee identified about 11 core fields that remain explicitly professional (medicine, pharmacy, dentistry, optometry, law, veterinary medicine, osteopathic medicine, podiatry, chiropractic, theology and clinical psychology) and said roughly 44 other CIP-coded programs “could” qualify only if they meet additional criteria; the total universe would shrink from roughly 2,000 programs to under 600 under the proposal [1] [4] [5].
1. What the guidance added and what it removed — a bird’s‑eye view
The new guidance does not massively add brand‑new professions; instead it tightens and narrows the official list. Reporting and advocacy groups describe eleven fields left squarely in the professional category (medicine, pharmacy, dentistry, optometry, law, veterinary medicine, osteopathic medicine, podiatry, chiropractic, theology and clinical psychology) while hundreds of programs that schools long treated as professional — including many nursing, public‑health and allied‑health degrees — were excluded from the default list unless they meet additional, program‑specific criteria [1] [6] [3].
2. Which specific programs were cited as removed or at risk
Multiple organizations and fact checks list nursing (MSN, DNP, NP specialties), physician assistant programs, occupational therapy, physical therapy, audiology, speech‑language pathology, public health degrees (MPH, DrPH), social work (MSW/DSW), many counseling and education master’s degrees, and some architecture and business programs as no longer included by default on the Department’s professional‑degree list — meaning they would not automatically qualify for the higher borrowing limits unless institutions demonstrate they meet the new criteria [2] [7] [5] [8].
3. The Department’s criteria and the “could qualify” caveat
ED tied professional status to defined conditions — a level of skill beyond the bachelor’s degree, typical attainment at doctoral level, and a general expectation of professional licensure — but the agency also said about 44 other fields could qualify if specific program criteria are met and institutions apply that CIP coding and documentation [4] [9]. That creates a case‑by‑case pathway rather than blanket inclusion, shifting responsibility to institutions to prove eligibility [4] [9].
4. Who is objecting and why their lists differ
Professional associations (American Institute of Architects, Association of Schools and Programs of Public Health, ASHA, nursing groups) say ED’s narrowed list contradicts decades of precedent and will reclassify many licensure‑dependent degrees as “non‑professional” for loan purposes, even when state licensure still treats them as professional credentials [6] [3] [7]. Advocacy groups emphasize workforce risks — e.g., nursing shortages — while ED frames the move as restoring a regulatory definition and limiting federal borrowing exposure for graduate students [6] [4].
5. Practical impact: borrowing caps and financial stakes
Under the One Big Beautiful Bill Act framework the policy implements, “professional” programs qualify for higher annual and aggregate loan caps ($50,000 annual, $200,000 lifetime for professional in some reporting), while general graduate caps are substantially lower — making the professional designation directly consequential for students’ ability to finance expensive graduate training [10] [11] [12].
6. Areas of uncertainty and what sources don’t say
Available sources document which fields ED explicitly kept and which programs advocacy groups report as excluded or at risk, but they do not publish a definitive, final federal list of every program added or removed specific to the 2025–2026 guidance in a single authoritative table; the Department’s public docket and final rulemaking (and any institution‑level determinations) remain the ultimate record and are not provided in these sources [6] [4]. Sources also show the negotiated rulemaking outcomes and preliminary lists but indicate further public comment and institutional certification steps will shape final coverage [6] [9].
7. How institutions can respond and next steps to watch
Schools will need to examine CIP codes and program documentation to seek “professional” status for affected programs; negotiated‑rulemaking materials show institutions and NASFAA members are already requesting clarity and the DOE shared that about 44 additional CIP groups might qualify if criteria are met [9] [4]. Watch for the Department’s published final rule, the public‑comment docket, and institution‑level determinations — those will definitively list which programs were formally added or removed [6] [4].