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What are the Department of Education's 11 professional categories and where are they defined?
Executive summary
The Department of Education’s recent negotiated-rulemaking discussions produced a working list of 11 professional degree areas that the department has used to decide which post‑baccalaureate programs qualify for higher federal loan caps; that list repeatedly cited medicine, dentistry, pharmacy, law and theology among others [1] [2]. The department has also proposed a multi‑part rubric — involving things like CIP codes and pathways to licensure — to determine professional‑degree status rather than relying solely on a fixed list [3] [4].
1. What the “11” are — a working list, not a statute
Reporting describes the department’s draft as an “exhaustive list of nearly a dozen” professional degree areas that would qualify for the higher $200,000 professional‑degree loan cap established by the One Big Beautiful Bill Act, and multiple outlets name medicine, law, dentistry and theology among that group [1] [2]. Marca’s roundup explicitly lists: medicine, dentistry, pharmacy, law, osteopathic medicine, optometry, veterinary medicine, podiatry, theology, chiropractic training, and clinical psychology as remaining in the professional category [2]. Note: sources frame this as the department’s working categorization reached during RISE negotiations, not a final statutory list [1] [4].
2. Where the definitions are being drafted — negotiated rulemaking and OBBBA’s anchor
The One Big Beautiful Bill Act (OBBBA) set distinct loan caps for “professional degree” students ($50,000 annual? — reporting focuses on the $200,000 aggregate cap for professionals vs. $100,000 for graduate students) and the Department has been using negotiated rulemaking (the RISE Committee) to translate those statutory phrases into regulatory language; those sessions produced the draft list and a proposed rubric [4] [1]. New America’s review notes OBBBA even referenced an existing regulation as of July 4, 2025, as a baseline for what “professional degree” could include, which the department is now refining via RISE [4].
3. The rubric approach — criteria beyond a static list
Advocates and institutional groups point out the department’s initial framework goes beyond naming fields: the ED proposed a multi‑part test that includes whether a program requires “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,” whether the program has a 4‑digit Classification of Instructional Programs (CIP) code, and whether it includes a path to licensure [3]. NASFAA coverage confirms ED unveiled a new multi‑part definition to the RISE negotiators and discussed applying legacy provisions and CIP guidance when needed [5].
4. Who’s upset and why — public health, nursing, social work concerns
Several professional associations and sector reporters say the department’s working definition excludes degrees they expected to be covered. The Association of Schools and Programs of Public Health warned the proposed definition would exclude MPH and DrPH, jeopardizing access to higher loan limits for public health students [6]. Nursing outlets and USA Today similarly reported that nursing and related clinician programs (nurse practitioners, physician assistants, PTs, audiologists) were removed from the department’s professional list, prompting warnings from the American Nurses Association and others about workforce impacts [2] [7]. The Council on Social Work Education said the framework limits access to social work education and urged use of CIP code 51 to guide eligibility [3].
5. Competing perspectives inside the RISE process
Negotiators don’t all agree. Some RISE participants praised the new ED proposal as legally careful and thoughtful, while others questioned how many real‑world programs would meet the full set of requirements; the department signaled some guidance might arrive via a Dear Colleague Letter for legacy eligibility rather than immediate regulation [5]. Inside Higher Ed and Politico both reported alternate proposals existed at the table — one (Holt’s) more expansive and another narrowly tailored by the department — and that debate shaped the move from an initial “10‑degree” list to the larger “nearly a dozen” working list [8] [1].
6. What’s still unclear or not covered in reporting
Available sources do not mention a single authoritative ED regulation text published as final defining a definitive 11‑item list in the Code of Federal Regulations; reporting describes working lists, draft rubrics, and committee consensus points but not a final rule codified in regulation [4] [5]. Precise annual vs. aggregate dollar amounts tied to each category are referenced in reporting about OBBBA’s caps, but the coverage focuses on the $200,000 professional‑degree aggregate and the process rather than a finalized distribution of loan limits by program [4].
7. What to watch next
Watch for the Department’s Notice of Proposed Rulemaking (NPRM) or a Dear Colleague Letter, which reporting says the department may use to provide guidance on legacy eligibility and CIP‑based determinations — that will be the moment the draft list and rubric move from negotiation to formal public comment or administrative guidance [5] [4]. Expect continued pushback from nursing, public health, social work, and allied‑health stakeholders if their fields remain outside the professional‑degree rubric, and legal or congressional scrutiny if parties claim the department is narrowing statutory intent [6] [3] [7].