Exactly which 11 degree fields did the Department of Education list in its Notice of Proposed Rulemaking?
Executive summary
The Department of Education’s Notice of Proposed Rulemaking (NPRM) lists 11 fields of study that it treats as “professional degree” programs eligible for the higher Direct Loan limits reached in negotiated rulemaking: Pharmacy; Dentistry; Veterinary Medicine; Chiropractic; Law; Medicine; Optometry; Osteopathic Medicine; Podiatry; Theology; and Clinical Psychology (Psy.D. or Ph.D.) [1] [2] [3]. That enumeration — ten longstanding entries plus an explicit inclusion of clinical psychology — is the focal point of contention in reporting and advocacy fallout [2] [4].
1. Exactly which 11 degree fields are named in the NPRM
The NPRM’s consensus drafting identifies the following eleven fields as professional-degree programs: Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), Theology (M.Div. or M.H.L.), and Clinical Psychology (Psy.D. or Ph.D.) — the last was added to the traditional list during negotiated rulemaking and is explicitly called out in the draft regulatory language [1] [2] [3].
2. How the Department framed that list and the technical rulemaking mechanism
The negotiated-rulemaking draft ties the “professional degree” label to programs that award credentials historically treated as professional degrees and maps those programs to four-digit CIP codes for administrative clarity, meaning institutions’ CIP classifications will determine coverage in many cases [5] [1] [6]. The Department’s language does not merely recycle the older “includes but is not limited to” phrasing in some summaries; several reporting outlets and stakeholder analyses indicate the proposed text narrows or formalizes the list and requires adding any additional fields through formal rulemaking rather than guidance [4] [2].
3. The political and sectoral flashpoints: who objects and why
Multiple higher-education and health‑sector groups have pushed back, arguing that the narrower listing would exclude widely recognized clinical professions — notably advanced nursing, physician assistants, occupational and physical therapy, audiology, and certain public‑health and social‑work programs — from higher federal loan limits, with potential downstream workforce implications [3] [4]. Advocacy organizations and some negotiators argued for broader language or transitional provisions; critics say a tightened list reflects administrative priorities to limit higher loan caps and could force affected students toward costlier private borrowing or alter program enrollment dynamics [4] [3].
4. What the list means practically and what remains unsettled
Practically, the NPRM’s eleven named fields create a clear baseline for who would automatically qualify as “professional students” under the proposed rule, while leaving open the pathway — but making it procedurally harder — for other fields to be added via full rulemaking or by mapping programs into the same CIP groups as listed fields [1] [2]. The Department will publish the NPRM for public comment and could revise the list before any final rule; reporting and stakeholder letters indicate both legal and political pushes to expand or clarify the definition ahead of implementation [6] [4]. Where reporting diverges — between shorthand press lists and the detailed CIP‑code crosswalk in the draft regulatory text — the authoritative source for exactly which programs qualify will be the published NPRM and its accompanying Table 3 crosswalk [5] [1].