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Which graduate degrees were reclassified as non-professional by the Department of Education in 2025?
Executive summary
The Department of Education’s negotiated rulemaking in late 2025 proposed a much narrower definition of “professional” degrees, effectively removing many graduate programs — including advanced nursing, physician assistant, occupational therapy, audiology, and public health programs — from the list that would qualify for the higher professional loan cap; reporting and advocacy groups say the change reduces “professional” programs from roughly 2,000 to fewer than 600 [1] [2] [3]. The RISE committee and ED settled on recognizing only 11 primary professions (plus some doctoral programs) as “professional,” which advocates and higher‑ed groups warn will exclude many healthcare and allied‑health master’s and advanced‑practice degrees from professional status and associated loan relief [4] [3].
1. What the Department of Education actually proposed
The Department of Education’s negotiated rulemaking set three tight criteria for a program to count as a “professional” degree: it must signify the skills to begin practice in a particular profession, require a skill level beyond the bachelor’s, and generally be a doctoral‑level degree that requires at least six years of postsecondary instruction (including at least two years post‑baccalaureate). In addition, ED’s draft ties eligibility to being in the same four‑digit CIP code as one of 11 explicitly named professions — a combination that drastically narrows the field of qualifying programs [5] [3].
2. Which programs reporting says were effectively reclassified
Multiple outlets and advocacy posts identify core healthcare and allied‑health programs that would lose “professional” status under ED’s approach: physician assistant programs, advanced nursing degrees (including many advanced practice nursing programs), occupational therapy, audiology, and several public health degrees are cited as likely losers under the proposed definition [1] [6]. Reporting also summarizes ED and RISE’s agreement to recognize only 11 primary programs and a narrower set of doctoral programs as professional — meaning many graduate programs previously treated as professional for loan‑limit purposes would no longer qualify [4] [3].
3. Scale of the change and the numbers cited
Advocates and social posts say the net effect is dramatic: the list of programs considered professional would shrink from roughly 2,000 programs to fewer than 600 under the new definition [1]. The negotiated rulemaking and related explainers emphasize this is the product of translating the OBBBA law into regulatory text and using the July 4, 2025 baseline regulation language to define “professional” [2] [3].
4. Why CIP codes and degree level matter here
ED’s use of four‑digit CIP coding plus a minimum of six academic years (and usually doctoral‑level status) is the linchpin. NASFAA and other higher‑ed groups point out that many legitimate professional programs don’t share a 4‑digit CIP with one of the 11 enumerated fields or aren’t doctoral‑level despite preparing graduates for licensure and practice; under ED’s formulation those programs would be excluded even if otherwise similar to recognized professional degrees [3] [5].
5. Who is raising alarms — and why
Research universities, nursing and public‑health associations, and student‑borrower advocates have warned that excluding such programs will restrict access to federal loan amounts previously available to students in those fields, push students to riskier private lending, and could deter enrollment in critical healthcare pipelines [4] [3] [1]. The Association of American Universities and Student Borrower Protection Center commentary emphasize the change’s potential to affect access and equity for graduate students in excluded programs [4].
6. What the Department and rulemaking process say about next steps
Documents and reporting make clear the RISE committee agreed on draft regulatory language that ED plans to publish for public comment (the department could still adjust language if consensus breaks). The department signaled it exerted pressure during negotiations and that finalized rules will follow the Federal Register/notice‑and‑comment process early next year [5] [4] [2].
7. Limits of the available reporting
Available sources do not publish a final list of every degree program reclassified; instead they describe categories and examples (e.g., nursing, PA, OT, audiology, public health) and the mechanics (CIP codes, years of instruction) that drive exclusion [1] [6] [3]. The precise enumeration of “which graduate degrees” (by school/program name or full CIP list) is not included in the linked reporting and therefore not available here [1] [3].
8. How to follow developments and what to watch for
Watch the Department of Education’s Federal Register publication of the negotiated‑rule language and subsequent public comments for an explicit program list or CIP‑code annex; interested institutions and professional associations are likely to submit formal comments and legal analyses during the rulemaking window [5] [4] [2]. If you need a definitive, program‑by‑program list, those forthcoming regulatory documents and association comment letters will be the authoritative sources [5] [4].