Which criteria determined additions or removals from the 2025–2026 professional degree list?
Executive summary
The Department of Education narrowed which graduate programs qualify as “professional degrees” for federal loan limits by returning to a short, example-based definition rooted in the 1965 Higher Education Act and applying three main criteria: the degree must signify completion of academic requirements for beginning professional practice, it must show a level of professional skill beyond a bachelor’s degree, and it is generally awarded at the doctoral level or tied to licensure — a shift that reduces the count of eligible programs from roughly 2,000 to fewer than 600 in the Department’s estimate [1] [2]. The change emerged from negotiated rulemaking under the One Big Beautiful Bill Act and has prompted objections from health and education groups who say many allied-health and public-health degrees would be excluded despite licensure links [3] [4] [5].
1. Definition redux: the 1965 language brought forward
The Department’s proposal relies on the traditional 1965 statutory phrasing — a professional degree “signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree” — but the draft regulations list only the original examples (medicine, law, dentistry, etc.) without the 1965 law’s explicit “not limited to” clause, narrowing which fields count [1] [3].
2. Three operational criteria the Department used
Reporters and the Department describe the test as requiring that a program: (a) prepares students to begin professional practice; (b) confers a level of professional skill beyond the bachelor’s; and (c) generally results in a doctoral-level credential and is linked to professional licensure to begin practice — language the Department says narrows the universe of professional-designated programs [6] [1] [3].
3. From thousands to hundreds: scale and consequences
Advocates and analysts say the proposed rule would cut the list drastically — from roughly 2,000 programs historically treated as professional down to fewer than 600 — which changes who can access higher graduate loan caps under the One Big Beautiful Bill Act and could constrain borrowing for many health, education and social-service programs [2] [7].
4. Who’s explicitly at risk — and who pushes back
Multiple professional associations — nursing, public health, audiology/speech pathology, architecture and physician assistants among them — have raised alarms that their programs meet licensure and practical-skill tests used in practice but are nonetheless omitted from the draft list; organizations like AIA, ASHA and ASPPH are mobilizing comments and advocacy to preserve inclusion [5] [8] [4].
5. Negotiated rulemaking: process matters and is ongoing
The Department used a negotiated rulemaking committee (the RISE committee) to develop draft language; that committee reached preliminary consensus but the proposal will still be posted for public comment and could change before finalization, meaning the lists and definitions are not yet final [5] [4].
6. Conflicting narratives: “internal” definition vs. accusations of devaluation
The Department defends the change as an internal, technical classification linked to loan limits — not a value judgment about professions — and frames it as implementing statutory loan caps from the OBBBA (One Big Beautiful Bill Act) [3]. Critics argue the narrow regulatory text effectively strips many licensure-linked fields of practical support and will make crucial programs less accessible, especially in healthcare and public health [4] [2].
7. What’s ambiguous or disputed in reporting
Sources disagree on whether doctoral-level status and licensure must be universal requirements: some commenters at negotiated rulemaking urged removing “generally at the doctoral level” to include professions like physician assistant programs or master’s-level advanced nursing, while the Department’s draft language keeps doctoral-level phrasing that critics say excludes many established licensure pathways [9] [6].
8. Practical takeaway for students and institutions
Institutions remain responsible for classifying programs under the Department’s rules, and the final definition will determine student eligibility for the higher loan caps; students in affected fields should track the rulemaking comment period and advocacy from their professional associations because the list as proposed would change loan maximums tied to “professional” status [6] [3].
Limitations: available sources do not provide the final, definitive list or the exact regulatory text that will be published for public comment; reporting and association statements reflect the proposal and its likely impacts but the rulemaking process could alter outcomes [5] [4].