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Which specific degree programs were listed as professional degrees in the 2025 memo and why?
Executive summary
The Department of Education’s 2025 memo (and related drafts) lists a narrowly defined set of graduate programs as “professional degrees” — examples repeatedly cited include medicine, dentistry, pharmacy, veterinary medicine and law — and it ties that label to specific regulatory criteria (doctoral-level, multi‑year instruction, and CIP-code grouping) that exclude many other health and allied‑health masters and doctorates such as nursing, audiology, speech‑language pathology and physician assistant programs (examples: pharmacy, dentistry, medicine, veterinary medicine, law) [1] [2] [3] [4]. The department’s stated rationale is to limit higher federal graduate loan caps to programs that are long, training‑intensive and clearly tied to licensure/clinical practice, while reducing fiscal exposure from shorter, high‑cost master’s programs that have produced borrowers with poor repayment outcomes [5] [4].
1. What specific programs the memo lists — a short inventory
The department’s draft and accompanying media summaries repeatedly name a core set of fields as examples of programs the agency views as “professional” for loan-cap purposes: medicine, dentistry, pharmacy, veterinary medicine and law, among others; one reporting round reduced an earlier list to about 10 examples and later proposals expand to 11 CIP‑code–linked professions [1] [2] [4]. Stakeholders’ summaries and advocacy groups treat that list as the operative “named” set that will qualify for the larger professional‑degree loan caps [6] [3].
2. Why those programs were chosen — the regulatory criteria explained
The memo and ED’s proposal tie the professional label to concrete criteria: generally doctoral‑level degrees (with narrow exceptions), programs requiring at least six years of academic instruction (including post‑baccalaureate years), demonstration that graduates can begin practice in a licensed profession, and classification within specific four‑digit or two‑digit CIP codes matching the named professions [4] [7]. The public rationale is fiscal: authors of the submitted memo warned that a broader definition would expand access to higher loan limits for many master’s programs that have produced high borrowing and weak repayment outcomes since the creation of Grad PLUS loans [5].
3. What the memo’s language does that affects other programs
The memo’s approach is intentionally narrow — it anchors the definition to the set of programs “as in effect” on July 4, 2025, and to programs that existed and received Title IV funds in 2024–25 — which has the practical effect of excluding many postgraduate clinical and allied‑health degrees not explicitly named [8] [7]. That legal anchoring plus CIP‑code matching means programs such as nursing master’s/doctorates, audiology, speech‑language pathology, physician assistant, and similar fields could fall outside the higher “professional” loan cap and face the lower aggregate and annual graduate loan limits [3] [2] [6].
4. Pushback and differing perspectives from affected fields
National associations for excluded professions—e.g., the American Speech‑Language‑Hearing Association—have publicly said the proposed definition would exclude audiology and speech‑language pathology and pledged to fight for explicit recognition, arguing that students in those programs require access to higher loan limits to finance training [3]. Nursing organizations and advocates likewise described being left off the list as damaging and have criticized the Department’s use of a short exemplar list and rigid criteria [1] [2]. By contrast, the memo’s drafters and the Department emphasize fiscal stewardship and targeting higher loan exposure to long, licensure‑directed professional training [5] [4].
5. The practical consequences — loan caps and timing
Under the One Big Beautiful Bill Act’s loan architecture discussed in the rulemaking, students in programs designated “professional” would remain eligible for higher annual and lifetime graduate loan caps (for example, past reporting contrasts $50,000/year up to $200,000 total for professional programs vs. lower caps for other graduate students), whereas students in programs left off the list would face the lower graduate limits — a change that would take effect under the rulemaking timeline tied to OBBBA implementation [1] [6] [3].
6. Limitations in the public record and open questions
Available sources do not mention a final, exhaustive list of every degree program included; the documents and reporting show variations (a list of 10 in an initial draft, later references to 11 CIP‑linked professions and to “examples” rather than an exhaustive roll) and make clear the definition is still subject to regulatory process and public comment [4] [8] [6]. The precise boundary tests — e.g., how the CIP‑code matching or the “substantially similar” language will be applied campus‑by‑campus — are not fully detailed in the materials provided [7] [4].
Bottom line: the 2025 memo elevates a compact set of long, licensure‑oriented doctoral programs (medicine, dentistry, pharmacy, veterinary medicine, law and similar professions) into the “professional” category for student‑loan purposes and deliberately narrows eligibility through degree‑level, instructional‑length, and CIP‑code criteria; affected professions not explicitly named are mobilizing to press the Department and rulemakers to broaden the list before rules are finalized [1] [4] [3].