What criteria were used to determine which degrees were no longer considered professional degrees?

1. What the Department proposed — a rules‑based redefinition

The Department of Education’s proposal creates a checklist for a degree to qualify as “professional”: it generally must be a doctoral‑level program (except for the Master of Divinity), require at least six academic years of instruction overall with at least two post‑baccalaureate years, and be classified in the same four‑digit CIP (Classification of Instructional Programs) code as one of a specified set of professions; the RISE committee’s draft language contrasts with an alternative that would have required only the first two criteria plus credit‑hour minimums and a broader two‑digit CIP match ^{[1] [3]}.

2. The practical consequence — a substantial narrowing of eligible programs

Advocates and analysts say the six‑year minimum is the decisive filter: NASFAA, cited in reporting, estimates eligible programs fall from “over 2,000” to about 650 when the department’s measures are applied, with the six‑year requirement responsible for much of that reduction; professional associations warn this could limit access to higher federal loan caps for many health‑related degrees ^{[2] [1]}.

3. Who would be excluded and why groups are pushing back

Public‑health groups and allied health organizations are explicit in their objections: the Association of Schools and Programs of Public Health calls the preliminary consensus “deeply concerning,” arguing that excluding MPH and DrPH programs undermines workforce development and ignores longstanding precedent that these are professional credentials; clinical associations (for example, PA advocates) warn fewer eligible programs could shrink the workforce and impair patient access ^{[3] [2]}.

4. How this compares to earlier or existing definitions

Historical federal definitions of “first‑professional” degrees already stressed completion of academic requirements to begin practice plus multi‑year sequencing (for example, earlier federal guidance required completion of practice‑entry requirements, two years of college pre‑entry, and six total academic years), but the new proposal’s emphasis on doctoral level and four‑digit CIP matching tightens the gate compared with some prior frameworks or less prescriptive alternatives discussed during rulemaking ^{[4] [5] [1]}.

5. The tradeoffs lawmakers and regulators are weighing

Supporters of a narrow definition argue precision matters for allocating the highest federal loan limits and ensuring loans target programs that demonstrably prepare graduates to begin practice; critics say the rules are blunt instruments that fail to reflect professional diversity (many health and public‑service programs are master’s level or shorter but nonetheless prepare for licensure or practice), creating perverse incentives for program design and access ^{[1] [3] [2]}.

6. Limits of current reporting and what’s not yet clear

Available sources document the proposed criteria and early impact estimates and reactions, but they do not provide the full negotiated‑rulemaking text, a final list of the 11 professions tied to four‑digit CIP codes, or the Department’s detailed justification for the six‑year floor in a public regulatory rationale; those specifics are therefore not found in current reporting and may change during the rulemaking comment period ^{[1] [2] [3]}.

7. What stakeholders — and observers — should watch next

Track the Department’s published regulatory text and the negotiated‑rulemaking record for the final list of professions/CIPs and any exceptions; watch formal comment filings from NASFAA, ASPPH, clinical associations, and institutions for data disputing the “650 program” estimate or arguing alternative criteria ^{[2] [3]}. Also watch whether Congress or accrediting agencies respond, since federal student‑aid eligibility, licensure practices, and accreditation norms intersect with how “professional” is defined ^{[1] [5]}.

Conclusion: The department’s proposed criteria use degree level, a six‑year duration with post‑baccalaureate minimums, and CIP alignment to redraw the “professional” boundary—measures that stakeholders say will greatly reduce programs eligible for higher loan limits and are provoking opposition from public‑health and clinical education groups; further detail and final outcomes await the rest of the rulemaking record ^{[1] [2] [3]}.