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Which degrees did the 2025 Department of Education guidance label non-professional and why?
Executive summary
The Department of Education’s 2025 negotiated rulemaking draft narrows which graduate programs count as “professional degrees,” removing or excluding a range of health‑and‑service fields from that category — most prominently nursing and public health (MPH, DrPH) — and thereby limiting which students can access higher federal loan caps such as the $50,000 annual / $200,000 aggregate professional‑student limits under the One Big Beautiful Bill framework (OBBBA) [1] [2] [3]. The RISE committee agreed to recognize only about 11 primary fields (plus some doctoral programs) as professional; critics from nursing, public‑health and social‑work organizations say the change will shrink loan accessibility for critical workforce programs [4] [5] [1] [6].
1. What the Department changed — a narrower “professional degree” definition
Negotiators on the Education Department’s RISE committee have proposed a much tighter definition of “professional degree” for purposes of the new student‑loan rules tied to OBBBA, shrinking the set of qualifying programs from thousands to a few hundred and formally recognizing roughly 11 core fields (and certain doctoral programs) as professional for the higher loan caps [4] [3]. The department’s approach ties the designation to specific Classification of Instructional Programs (CIP) codes and to whether a program fits a listed field, rather than leaving the label broad or determined by individual institutions [3] [6].
2. Which degrees are explicitly reported as newly excluded
Reporting and trade organizations single out nursing (including advanced nursing degrees such as DNPs and nurse‑practitioner tracks) as excluded from the professional‑degree list in the department’s draft, which would reduce affected students’ access to the larger annual and aggregate loan limits reserved for “professional” students [2] [7] [8]. Public‑health degrees — specifically the MPH and DrPH — are also identified by the Association of Schools and Programs of Public Health as being left out of the professional category in the proposal [1]. Social work and certain education and human‑services programs are also among the programs flagged by professional associations as not qualifying under the proposed definition [6] [9].
3. Why the department says it made the change
The department and pro‑rule commentators argue the narrower list is designed to align higher loan access with programs where borrowing historically exceeded standard limits and where graduates enter licensure‑bound professions that require extensive, costly training, while preventing broad, unchecked access to larger loans for programs in which most students already borrow within standard limits [3] [9]. AEI’s commentary endorses excluding programs such as the Ed.D. or MSW because most students in those fields borrow within standard limits, arguing the change targets loan relief to higher‑need professional pipelines [9].
4. Critics’ perspective — workforce and access concerns
Nursing groups (AACN, American Nurses Association) and public‑health schools warn that excluding nursing and public health from the professional label will constrain graduate funding, worsen pipeline shortages in health care and public‑health practice, and undercut efforts to expand advanced clinical and population‑health capacity — a particular worry for rural and underserved communities [5] [7] [1] [2]. Social‑work educators say the CIP‑focused approach risks arbitrary distinctions that don’t reflect program rigor or workforce need [6].
5. The practical effect on loans and students
Under OBBBA’s structure described in reporting, students in non‑professional graduate programs would face lower annual and aggregate loan limits (the department and analysts cite limits of $20,500 annual / $100,000 aggregate for typical grad students versus $50,000 / $200,000 for professional students), and the phaseout of Grad PLUS would concentrate borrowing and repayment changes on these new caps — meaning reclassification can substantially change how much students can borrow to pursue advanced degrees [3].
6. Political and institutional dynamics to watch
The negotiated rulemaking outcome reflects the department’s attempt to put a definitional floor under legislation passed by Congress, but it also triggers predictable opposition from professional associations and universities; AAU notes the committee “reached consensus” on the narrowed list but that litigation and policy pushback are likely as affected sectors mobilize [4] [3]. Advocacy and policy outlets present competing frames: efficiency and targeting of loan relief (AEI) versus workforce and access harms (AACN, ASPPH, CSWE) [9] [5] [1] [6].
7. What reporting does not (yet) show
Available sources do not mention a final, department‑issued regulation in the Federal Register or a completed Notice of Proposed Rulemaking at the date of these reports; they describe negotiated draft language, consensus on a proposed list, and expected rulemaking steps including a 30‑day comment period [1] [3]. Specifics on every program removed or kept (a full list of the roughly 600 now‑eligible CIP entries) are not reproduced in the cited reporting [4] [3].
Bottom line: the Education Department’s 2025 negotiated rulemaking narrows the official definition of “professional degree,” explicitly excluding nursing and public‑health degrees in the draft and prompting concerns from professional associations that the move will limit students’ ability to finance critical health and service professions while proponents say the change targets scarce higher borrowing capacity to programs that historically need it [2] [1] [3] [9].