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What guidance did colleges and accreditation agencies receive about degree categorizations in 2025?
Executive summary
Federal guidance in late 2025 narrowed which graduate programs the Department of Education (ED) would treat as “professional degrees” for federal loan limits, explicitly excluding many health, education, and social‑service fields such as nursing, social work, and some therapy professions — a change that triggers lower borrowing caps and prompted urgent requests for clarification from colleges and accreditors [1] [2]. Colleges and associations pushed ED for faster, formal guidance (including a Dear Colleague letter) and accused the agency of using a narrower interpretation of a decades‑old regulatory definition; ED said it would issue written guidance and proposed regulatory language to explain what does and does not count as a “program of study” [3] [1].
1. What the Department of Education changed — and why it matters
In late 2025 ED proposed narrowing the set of programs it counts as “professional degrees” — the classification that determines higher federal graduate loan limits — by excluding fields such as nursing (MSN/DNP), education master’s degrees, social work (MSW/DSW), public health (MPH/DrPH), and several therapy and allied‑health degrees, among others [1] [2]. That reclassification matters because ED’s changes were tied to caps in the One Big Beautiful Bill: students in programs labeled “professional degree” could qualify for larger lifetime and annual borrowing allowances, while students in other graduate programs would face stricter caps [4] [5]. News outlets and professional groups warned that the change could increase student financial strain and affect workforce pipelines in high‑need areas [2] [6].
2. How colleges and accrediting communities reacted
Colleges, professional organizations and accreditors reacted with alarm and sought quick clarification. Nursing groups (e.g., AACN) publicly objected, saying excluding nursing “disregards decades of progress” toward parity among health professions [2] [6]. Financial‑aid professionals and NASFAA flagged practical problems for campuses and recommended ED issue immediate guidance rather than leaving institutions to interpret narrow regulatory language on their own [3]. Commenters on NASFAA’s reporting urged ED to add specific Classification of Instructional Programs (CIP) codes — e.g., physician assistant CIP 51.0912 — to lists to prevent inconsistent campus decisions [3].
3. The Department’s chosen communication route
ED indicated it would not change course through an immediate rulemaking alone but planned to provide institutions clarity via non‑regulatory guidance such as a Dear Colleague Letter (DCL) while also circulating proposed regulatory language; some observers criticized that timing because institutions are already admitting students for 2026‑27 and need definitive answers now [3]. ED also offered revised draft language explaining what would not count as a “change in program of study” — for example, students changing majors within the same degree would be treated as remaining in the same program — illustrating ED’s effort to narrow ambiguity in practice [3].
4. Disputes over interpretation and precedent
ED defended its approach by saying its interpretation aligns with a long‑standing regulatory definition first outlined in mid‑20th‑century regulations, but critics contend the agency’s reading is narrower than long‑held practice and will upend expectations for many graduate programs [1]. Snopes and other fact checks summarized that ED was applying a narrow reading of 34 CFR 668.2 and that the resulting list of excluded programs represented a policy shift with significant downstream effects for borrowers [1].
5. Practical effects institutions and students face now
Reporting and professional outlets warned that removing “professional” status from many advanced degrees could reduce students’ ability to borrow (e.g., elimination of Grad PLUS and new per‑program caps cited in coverage) and force institutions to rethink admissions, tuition aid, and program structuring to protect students and revenues [5] [4] [6]. Colleges that award large numbers of graduate degrees in the affected fields confront urgent operational questions: how to advise current and prospective students, whether to change program classification or curricular structure, and what codes to use when reporting to accreditors and federal systems [3] [6].
6. What remains unresolved and where to watch next
Available sources indicate ED said final rules would be released by spring 2026 at the latest, and that ED intended to provide interim guidance via a DCL, but the exact final list of included/excluded programs and how accreditors must treat program categorization remained unsettled in late 2025 [1] [3]. Watch for the Department’s Dear Colleague Letter and the spring 2026 rule package for definitive regulatory language, and for professional associations’ continued advocacy to restore or clarify “professional” status for fields like nursing and social work [3] [2].
Limitations: reporting in these sources focuses on ED’s proposed treatment for loan‑eligibility and program classification in late 2025; available sources do not mention other potential federal or state actions beyond those cited here [1] [3].