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What criteria were used by the governing body to decide which professional degrees to reclassify?
Executive summary
The Department of Education’s proposal narrows the federal definition of “professional degree” using a set of specific criteria developed during rulemaking tied to H.R.1, with the goal of reducing the number of programs eligible for higher loan limits from about 2,000 to under 600 [1] [2]. Key tests in the draft definition emphasize program length, credentialing/licensure expectations, and typical educational level (including language about being “generally at the doctoral level” and requiring at least six years of postsecondary coursework), though debate remains about how narrowly those tests will be applied to fields such as nursing and physician assistant programs [3] [1].
1. What the governing body said it was trying to do: limit the eligible list
The Department of Education and the RISE (Reimagining and Improving Student Education) committee negotiated draft regulations intended to implement H.R.1 that would significantly shrink the set of programs classified as “professional,” with proponents framing the change as a way to limit which graduate borrowers receive the higher $200,000 loan cap reserved for professional-degree students [1] [2]. The AAU summary and other reporting note the department and committee “agreed to recognize only 11 primary programs as well as some doctoral programs as professional degree programs,” illustrating the policy objective to tighten eligibility [1].
2. The stated criteria: program length, level, and licensure or practice requirements
Draft regulatory language and stakeholder discussion emphasize three main criteria: a requirement that programs generally be at the doctoral level or meet an equivalent benchmark such as at least six academic years of postsecondary coursework (including two years post-baccalaureate), a tie to required professional licensure/certification and ongoing credentialing, and being awarded a designated “professional degree” upon completion [3]. NASFAA and commenters raised questions about phrasing like “generally at the doctoral level” and whether shorter, accredited master’s-entry programs (for example, many PA programs) meet the other prongs [3].
3. How those criteria map awkwardly onto real-world programs (disagreement among stakeholders)
Practitioners and associations argue the tests would exclude many health and service professions that rely on master’s-level entry, national board exams, and state licensure—characteristics long associated with “professional” practice—while the department’s proposed interpretation treats such programs more narrowly [3] [1]. NASFAA discussion and pushback from professional societies show explicit disagreement about whether duration alone or the presence of licensing should dominate the decision [3].
4. Which programs are explicitly in dispute and why length versus licensure matters
News outlets and membership associations report that nursing (MSN, DNP), physician assistant programs, occupational and physical therapy, audiology, speech-language pathology, counseling, public health, education, and social work are among fields flagged for exclusion under the new approach—largely because many are master’s-entry or less-than-doctoral programs despite having licensure and certification regimes [4] [5] [2]. Critics contend that relying heavily on “doctoral-level” or multi-year coursework thresholds will misclassify professions that functionally meet professional standards [3] [1].
5. Procedural context and limits of current reporting
Reporting and fact-checking note the proposal had not been finalized at the time of coverage, and some outlets caution that the Department argued it was returning to a 1965 regulatory definition but applying a narrower interpretation of that text [4]. The AAU and association briefings reflect negotiated draft language from the department-convened committee rather than a completed rule, so precise final criteria could change before any regulation is adopted [1] [3].
6. Competing perspectives and institutional agendas
Higher-education groups and professional associations emphasize access and workforce implications—arguing the narrower definition will cut loan access for critical health and education fields and worsen shortages—while the Department and some policymakers frame the move as clarifying eligibility and constraining loan caps created by H.R.1 [1] [2]. Watch for advocacy from nursing organizations and NASFAA, which have explicitly raised concerns about downstream financial impacts and administrative reclassification of students [6] [3].
Limitations: available sources do not include the final, adopted regulatory text or a comprehensive official list of the final criteria after rulemaking; coverage is based on draft regulations, committee notes, and media reporting [3] [1] [2].