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What criteria were used to determine which degrees became non-professional and what policy documents describe the change?

Checked on November 24, 2025
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Executive summary

The Department of Education, through a RISE negotiated-rulemaking process implementing provisions of the One Big Beautiful Bill Act (OBBBA/H.R.1), agreed on a narrower definition of “professional degree” that would exclude many health, education, and social‑service programs — reportedly cutting the list from roughly 2,000 programs to under 600 — and tie higher graduate borrowing limits to that narrower list [1] [2]. Reporting and stakeholder statements say the change was reached in draft regulations from the department’s RISE committee and will be published as a proposed rule / Notice of Proposed Rulemaking (NPRM) for public comment [3] [4].

1. What decision was made and where it came from — a negotiated rulemaking, not a single memo

The change emerged from a Department of Education‑convened negotiated rulemaking (the RISE committee — Reimagining and Improving Student Education) seeking draft regulations to implement student‑loan provisions in the OBBBA/H.R.1; committee participants reportedly reached consensus on a proposed definition of “professional degree” that narrows which programs qualify for the higher loan caps and eliminates broad graduate access to Grad PLUS loans [1] [5]. Stakeholders and news outlets describe the department as preparing to publish a proposed rule (NPRM) that will formalize the draft language and open a public comment period [3] [4].

2. The criteria described or implied in reporting — consensus, historic precedent, and limiting examples

Coverage and organizational reactions indicate the RISE committee’s approach was to limit “professional degree” designation to a smaller set of program types by relying on consensus language and on examples from the decades‑old regulatory text (34 CFR 668.2) while narrowing the scope of “not limited to” language. The Department’s statements quoted in reporting say the committee “agreed on the definition that we will put forward” and framed that as consistent with historical precedent; other reporting frames the result as recognizing only about 11 primary program areas and select doctoral programs as professional [6] [1].

3. Which programs were reported excluded and why financial policy drove the change

Multiple outlets and professional associations report that graduate nursing (MSN, DNP), physician assistant, occupational and physical therapy, audiology, speech‑language pathology, social work, public health (MPH, DrPH), many education degrees, accounting, architecture, some business master’s, and others were treated as outside the new “professional” list — a change driven by OBBBA’s loan architecture: elimination or reduction of Grad PLUS, annual grad caps (~$20,500) versus higher limits for “professional” programs ($50,000 annually or greater under the law), and new lifetime caps [7] [8] [9] [10]. The stakes are explicitly financial: reclassification changes who can borrow at the higher caps [9] [11].

4. Policy documents that describe or will describe the change

Current reporting points to three policy sources: (a) the statutory framework in the One Big Beautiful Bill Act / H.R.1 (which created the new borrowing caps and removed Grad PLUS for many students — discussed in news summaries) [7] [9]; (b) the negotiated‑rulemaking draft and committee consensus language produced by the Department’s RISE committee (described in AAU and professional group statements) [1] [5]; and (c) the forthcoming Notice of Proposed Rulemaking the Department is expected to issue to implement H.R.1, which will publish the precise regulatory definition and open the public comment period [3] [4]. Available sources do not publish the NPRM text yet, only reporting about the draft and the committee’s consensus [3].

5. Competing perspectives and who objects

Universities, professional associations (e.g., nursing and public‑health groups, ASHA for audiology/speech), and higher‑education advocates say the draft definition threatens workforce pipelines and contradicts accreditation, licensure, and historical recognition of those professions as “professional” [10] [3] [4]. The Department and some supporters counter that the committee’s consensus aligns with a consistent, longstanding regulatory definition and is a necessary recalibration to limit taxpayer exposure — a line attributed to department remarks in reporting [6]. Both frames are explicit in the coverage [6] [10].

6. Limitations, next steps, and how to verify details

Reporting shows draft consensus language exists but the formal rule text was expected in an NPRM; until that NPRM is published, exact statutory/regulatory wording and final lists remain provisional [3] [1]. To verify the final criteria and the definitive program list, read the Department of Education’s NPRM and the final rule when published and track public comments from professional organizations during the rulemaking [3] [4]. Available sources do not provide the final regulatory text in full as of these reports [3].

Want to dive deeper?
Which government or accrediting bodies decided to reclassify certain degrees as non-professional?
What specific criteria (curriculum hours, clinical experience, licensing outcomes) were applied to label a degree non-professional?
Which policy documents, regulatory notices, or accreditation standards formally record the reclassification decision?
How did the change affect graduates’ eligibility for professional licensing or employment in regulated fields?
Were stakeholder consultations or impact assessments published prior to finalizing the non-professional designation?