Keep Factually independent
Whether you agree or disagree with our analysis, these conversations matter for democracy. We don't take money from political groups - even a $5 donation helps us keep it that way.
What criteria were used in 2025 to reclassify certain graduate degrees?
Executive summary
The 2025 proposal from the U.S. Department of Education would narrow which graduate credentials count as “professional degrees” for federal loan limits by tying that status to a specific, narrowly interpreted regulatory definition and to a short list of fields (medicine, law, dentistry, pharmacy in several accounts), which would remove many health‑ and service‑oriented programs from higher borrowing caps (e.g., nursing, social work, public health, PA, OT) [1] [2] [3]. Critics say the department is basing the change on a 1965 regulatory definition and on Classification of Instructional Programs (CIP) codes—so programs that do not share the designated 4‑digit CIP codes with the enumerated fields would lose “professional” status [4] [5] [2].
1. What the Department of Education’s rule changes actually focus on
The rulemaking and draft regulatory language center on a new, narrower definition of “professional student” and “professional degree” used to determine eligibility for higher graduate/professional loan limits under the One Big Beautiful Bill Act (OBBBA). Under the draft, ED would treat a student as “professional” only if enrolled in programs that award what ED designates as a professional degree in a short list of fields—effectively limiting high aggregate and annual borrowing to those areas [5] [6].
2. The practical criterion: CIP codes and an enumerated list
A key, concrete criterion reported by stakeholders is whether a program’s 4‑digit CIP code aligns with the 11 program fields the department names as ones “in which a professional degree may be awarded.” Programs that don’t share those CIP codes would not count as professional degrees even if they are similar in content or outcome, per NASFAA summaries and public comments [4] [5].
3. Which programs are most affected in reporting and examples
Multiple outlets and advocacy groups report that nursing (MSN, DNP), social work (MSW, DSW), public health (MPH, DrPH), physician assistant, occupational/physical therapy, audiology, speech‑language pathology, counseling and related degrees were singled out as being moved out of the “professional” category in late‑2025 commentary and drafts [2] [7] [3]. Independent and trade reporting similarly notes that under the draft only medicine, law, dentistry and pharmacy would keep professional status for loan purposes [1].
4. Why the department gives for narrowing the definition
The public materials and advocates quoted in coverage frame the department’s move as an attempt to standardize and limit high borrowing by tying “professional” status to an older regulatory definition and to explicit program codes—arguments include preventing outsized indebtedness relative to income and simplifying loan categories under the new RAP/loan caps established by OBBBA [1] [6]. New loan architecture under OBBBA phases out Grad PLUS and imposes annual and aggregate caps that make the “professional” label the gatekeeper for higher limits [6] [8].
5. Opposition and consequences flagged by professional groups
Nursing and other professional organizations, and commenters to the department, argue that removing advanced practice nursing and similar programs from the professional category will reduce students’ access to federal loans, deepen workforce shortages, and threaten care access and equity; they stressed these programs meet “every criterion of a professional field” and asked ED to retain or expand listed CIP codes [4] [7] [5].
6. Confusion and limits in current reporting
Fact‑checking outlets caution that as of late 2025 the agency had proposed but not finalized a reclassification—reports differ on whether ED has “reclassified” programs or only proposed a narrower interpretation of an existing 1965 regulatory definition; Snopes notes the proposal had not formally passed at the time of that write‑up [2]. That caveat matters because a proposed rule can change in negotiation and comment periods [2] [5].
7. Two competing framings: fiscal discipline vs. workforce impact
Supporters of the narrower definition argue it curtails unlimited Grad PLUS borrowing, improves ROI and reduces long‑term debt burdens [1] [6]. Opponents emphasize immediate access issues for high‑need professions and gendered impacts (healthcare, counseling, social work) and warn the symbolism of “downgrading” widely respected fields could harm recruitment and retention [3] [4] [7].
8. What to watch next
The outcome will hinge on negotiated rule language, whether ED adds or amends CIP codes or field lists after stakeholder comment, and on any litigation or congressional pushback. NewAmerica and NASFAA summaries note a phased implementation for existing borrowers and that institutions can limit loans for specific programs—details that will matter for students currently enrolled [6] [5].
Limitations: available sources do not include the final, enacted regulatory text or the full ED internal rationale; much reporting is based on drafts, stakeholder comments, and summaries of OBBBA provisions rather than a single final rule [2] [5].