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How are professional degrees (e.g., law, medicine, engineering) typically classified and under what rules?
Executive summary
The Department of Education’s recent negotiated rulemaking adopted a specific, regulatory-based definition of “professional degree” for federal loan purposes: it generally tracks the long-standing list in 34 CFR 668.2 (examples like Pharm.D., DDS), adds Clinical Psychology, and then extends eligibility to other programs that share the same four‑digit CIP code as those listed fields — a change that will affect loan limits beginning July 1, 2026 (students in professional-degree programs get higher annual/aggregate limits) [1] [2]. Several professional associations — for public health, nursing, and social work — say the new framing excludes important health and service fields and could restrict access to federal loan resources [3] [4] [5].
1. What the Department’s rule actually says — a regulatory, CIP-code approach
The RISE committee and ED anchored the working definition of “professional degree” to the existing regulatory examples in 34 CFR 668.2 as of the OBBBA enactment, explicitly listing fields already in that regulation plus Clinical Psychology (Psy.D./Ph.D.), and then allowing any program with the same four‑digit Classification of Instructional Programs (CIP) code as those listed to qualify as “professional” for Direct Loan limits [1] [2]. NASFAA summarized the definition as signaling completion of requirements for beginning practice, generally doctoral‑level timing (approx. six years postsecondary), and typically requiring licensure — language ED used in justification [2].
2. Why CIP codes matter — rule uses program coding, not job function
By tying inclusion to a program’s four‑digit CIP code, ED uses an administrative identifier to determine eligibility rather than a taxonomy of workforce roles or program length; advocates warned this could produce mismatches where programs that prepare licensed practitioners are excluded because of CIP classification choices [1] [5]. CSWE and allied organizations urged ED to rely on health‑related CIP groupings (CIP 51) to avoid “unjustified distinctions” and ensure fields like social work remain eligible [5].
3. Immediate practical impact — loan limits and who benefits
Under the final language analyzed by New America, students in programs designated as professional will face higher annual and aggregate loan caps: for example, students in professional-degree programs would have limits of $50,000 annually and $200,000 aggregate, versus lower caps for other graduate students — a material financing difference that institutions and students will feel starting in mid‑2026 [1]. NASFAA and others framed the new definition as central to who can access those higher limits [2].
4. Pushback from health and service professions — who’s left out
Professional groups in nursing, public health, and social work publicly decried the emerging definition, saying it excludes degrees they regard as essential to practice and workforce capacity. The Association of Schools and Programs of Public Health (ASPPH) said the proposal “excludes public health programs” such as MPH/DrPH and warned it could restrict access to higher federal loan limits and weaken the workforce pipeline [3]. The American Nurses Association called the exclusion of nursing “jeopardiz[ing] efforts to strengthen and expand the U.S. nursing workforce,” urging ED to revise the definition [4]. CSWE flagged social work’s omission and urged use of relevant CIP codes to prevent exclusion [5].
5. Competing viewpoints and implicit agendas
ED and some commenters argue that grounding the definition in an established regulatory list plus CIP codes creates administrable, predictable rules for loan programs [1] [2]. Critics counter that the approach privileges fields historically listed in 1965-era regulation and that reliance on CIP coding — which is an institutional reporting choice — can reflect administrative artifacts rather than the substance of educational preparation or licensure requirements; professional associations are lobbying to expand the list or the CIP guidance to protect access [5] [3] [4]. Institutional players (medical, dental, pharmacy schools) may favor clarity that preserves their higher loan access; workforce-focused organizations emphasize public‑interest consequences of exclusion [1] [3].
6. What remains unclear or not covered in current reporting
Available sources do not mention how ED will handle programs that straddle CIP codes, merged/renamed programs, or transitional grandfathering beyond the referenced “legacy” and program‑of‑study discussions; specifics about appeals processes or timelines for institutions to request CIP recoding are not found in the current reporting [2] [5]. Likewise, sources here do not show final regulatory text (only summaries and stakeholder statements), so precise legal language and any exceptions remain to be reviewed in the published rule [1] [2].
7. Bottom line for students, institutions, and policymakers
The defining rule is administrative and relies on an existing regulatory list plus four‑digit CIP matching; the upshot is that some professional and health‑service degrees may lose access to the higher federal loan limits unless ED or Congress broadens the definition or uses CIP guidance differently — a dispute that professional associations are actively litigating in public comment and advocacy [1] [3] [4] [5].