Keep Factually independent
Whether you agree or disagree with our analysis, these conversations matter for democracy. We don't take money from political groups - even a $5 donation helps us keep it that way.
What are the department of education's 11 professional professions
Executive summary
The Department of Education’s negotiated rulemaking this November produced a proposed regulatory test that would limit which graduate programs qualify as “professional” — tying that label to programs that fall into the same four‑digit CIP code as one of 11 explicitly named professions (and other criteria), a move that affects eligibility for higher federal loan caps (professional students up to $200,000 vs. other grads up to $100,000) [1] [2]. Reporting shows the proposal is narrower than some committee members wanted and has drawn pushback from health and social‑work organizations fearful it will exclude many clinical degrees [1] [3] [4].
1. What the Department’s proposal actually says — a narrower, code‑based test
The Education Department’s draft definition requires a program to meet multiple criteria, including being classified in the same four‑digit Classification of Instructional Programs (CIP) code as one of 11 professions that the regulation explicitly names; this is a stricter approach than alternate proposals on the table and would therefore narrow the set of degrees that count as “professional” for loan‑cap purposes [1] [2].
2. Why the “11 professions” line matters — loan limits and financial access
The negotiated package ties the “professional” label to access to the higher lifetime federal loan cap (professional students up to $200,000 vs. other graduate students up to $100,000 under the One Big Beautiful Bill Act framework). Because the department’s criteria require alignment with those 11 named professions’ four‑digit CIP codes, programs outside those codes could lose access to the larger cap, changing the financing landscape for many graduate students [2] [1].
3. Who is pushing back — health and social‑work groups warn of exclusions
Groups representing public health, social work and allied health expressed concern that the department’s narrower definition would exclude MPH, DrPH and other health professions from “professional” status, limiting student access to higher loan limits and potentially shrinking workforce pipelines in health and social services [4] [3] [2].
4. The alternate proposals — broader, credit‑hour and CIP‑code approaches
Some committee members, notably Alex Holt’s proposal, favored a more inclusive test that required fewer hurdles (meeting basic criteria plus a program‑length threshold and two‑digit CIP alignment), which would have covered more health and clinical fields; the committee ultimately reached a consensus that lands between the department’s narrow approach and Holt’s broader plan [1] [2].
5. The negotiated‑rulemaking context — consensus but room to alter
The RISE committee reached consensus on a package of proposals in early November, but reporting notes the department could still issue its own rule if full agreement on details is not finalized; several organizations lobbied during negotiated rulemaking to broaden which CIP codes count as “professional,” indicating the outcome could shift before final rulemaking [2] [1].
6. Political backdrop — amid broader Education Department restructuring debates
These technical changes to loan eligibility come at a fraught moment: national coverage describes the Biden‑era Education Department being reorganized under the Trump administration’s plans to move major functions elsewhere, a political backdrop that intensifies scrutiny around department decisions and heightens stakes for workforce and funding implications [5] [6].
7. Evidence limits — what current reporting does not say
Available sources do not list the 11 professions by name in the excerpts provided here, nor do they publish the full regulatory text in these snippets; they do not provide program‑by‑program lists showing which degrees would be excluded under the department’s draft [1] [2]. For specifics on which 4‑digit CIP codes are included or excluded, the Federal Register post or the department’s full proposed rule would need to be consulted [7].
8. Stakes and competing priorities — taxpayers, students, and workforce planning
Advocates for a narrow list frame it as a taxpayer protection and targeting of higher loan benefits to clearly licensed professions; health and education advocates frame exclusion as short‑sighted, warning of reduced access to training for essential public‑health and clinical workers. Both camps are publicly recorded in the negotiated‑rulemaking process [2] [3] [4].
9. How to follow up — where to look next
To see the final list or the department’s formal proposal, consult the Department of Education’s negotiated‑rulemaking outputs and the Federal Register index for 2025, which logs Education Department rulemaking publications [7]. Trade groups such as ASAHP, CSWE and ASPPH have published reactions and analysis that track how specific fields fare under the department’s approach [2] [3] [4].
Limitations: this summary relies on news and association excerpts that report the department’s approach and stakeholder reactions; the exact 11 professions named and the final regulatory text are not included in the provided snippets and therefore are not reproduced here [1] [2].