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What criteria did the 2026 DOE regulations use to classify a degree as 'professional' versus 'nonprofessional'?
Executive summary
The Department of Education’s negotiated draft regulations narrow the category of “professional degree” to a short list of fields and a small set of criteria — including a focus on certain doctoral-level programs and matching 4‑digit CIP codes to 11 designated fields — which would shrink programs counted as professional from roughly 2,000 to fewer than 600 and make many health‑related degrees ineligible for higher loan limits (e.g., nursing, public health, PA, OT) [1] [2] [3]. The RISE committee’s language emphasizes that professional programs are generally doctoral or require extended post‑baccalaureate coursework, and that program classification hinges on whether a program’s CIP code aligns with the 11 designated professional fields in the new regulatory text [4] [3].
1. What the DOE’s test looks like — short list plus structural criteria
Negotiators at the Department’s RISE committee agreed on a narrow approach: instead of treating “professional” as a broad or precedent‑based label, they propose recognizing only about 11 primary program areas (and some doctoral programs) as professional, meaning eligibility will depend on whether a program falls within those enumerated fields in the regulation [2]. Practically that means programs must satisfy the definitional text and, per NASFAA’s read, must share a 4‑digit CIP code with one of the 11 designated fields to qualify as “professional” under the draft rule [3].
2. Degree‑level and length requirements play a central role
Negotiators debated provisions that read like a structural test: a professional degree is “generally at the doctoral level” or otherwise requires an extended sequence of postsecondary coursework (for example, at least six years total with two years post‑baccalaureate) [4]. Committee members flagged this as vague in practice — does “generally” require a doctorate in all cases, or can long non‑doctoral programs meet the test if they satisfy other provisions? — and urged clearer guidance [4].
3. Coding mechanics: CIP alignment effectively gates access
NASFAA explains that even programs that look like professional programs could be excluded if they don’t share a 4‑digit CIP code with one of the listed professional fields; in other words, classification turns on program taxonomy as much as on substance [3]. That technical reliance on CIP codes means two otherwise similar clinical degrees could be treated differently for loan limits solely because of how their CIPs are organized [3].
4. Real‑world consequences cited by stakeholders: health fields at risk
Multiple organizations warn the practical outcome is exclusion of many health‑care and public‑health programs from the higher “professional” loan limits. Reporting and advocacy groups say the proposed definition would remove advanced nursing degrees, physician assistant programs, occupational therapy, audiology, MPH/DrPH and others from the professional bucket — shrinking eligible programs from ~2,000 to under 600 and curtailing loan access [1] [5] [2]. Advocacy groups such as ASPPH explicitly warn that excluding MPH/DrPH threatens the public‑health workforce pipeline [5].
5. Disagreement and pushback inside and outside rulemaking
The Department and RISE negotiators argue the draft aligns with historical regulatory text and the goal of simplification; Department spokespeople told outlets there’s a consistent definition and that consensus language aligns with precedent [6]. By contrast, nursing and public‑health groups, Newsweek coverage, and higher‑ed associations say the draft contradicts decades of precedent and will have damaging workforce and access effects [7] [6] [5] [2].
6. Unresolved ambiguities and timing pressures
Participants flagged ambiguities — especially around the “generally doctoral” phrasing and program‑of‑study definitions — and asked the Department for clearer text because institutions are enrolling students for 2026‑27 and need certainty [4]. NASFAA and others note that answers remain tentative pending final rules expected in early 2026, and that legacy eligibility and implementation details (e.g., how “loans made” before July 1, 2026 are treated) also require clarification [3].
7. What reporting doesn’t settle (limitations)
Available sources do not mention the exact final regulatory text (word‑for‑word), specific lists of the 11 designated fields in the negotiated draft, or any finalized government cost‑benefit analysis quantifying impacts on particular student populations beyond the estimates and warnings cited [2] [1] [5]. Final determinations and precise operational rules remain to be published in the formal rulemaking record [3].
Bottom line: the DOE’s draft shifts from precedent and professional‑practice markers toward a compact, code‑and‑degree‑level test that privileges 11 enumerated fields and certain doctoral/long programs; critics say this technical approach will exclude many health and public‑service degrees and reduce loan access, while the Department maintains it is following longstanding regulatory definitions [2] [6] [3].