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What changes did the Department of Education make when it reclassified professional degrees in 2024–2025?
Executive summary
The Department of Education (ED) in 2024–2025 proposed and moved toward a narrower regulatory definition of “professional degree,” cutting the list of programs that count as professional from roughly 2,000 to fewer than 600 and excluding many health‑ and human‑service fields such as nursing, physician assistant, audiology, speech‑language pathology, public health, social work, education, and several therapy professions — a change that affects which students can access higher loan caps under the One Big Beautiful Bill/OBBBA implementation (e.g., $200,000 lifetime vs. lower graduate caps) [1] [2] [3]" target="blank" rel="noopener noreferrer">[3]. Coverage is extensive but contested: higher‑education groups and professional associations have protested the exclusions while ED and its RISE committee say their approach follows an older regulatory definition [4] [5] [6].
1. What ED changed: a much narrower “professional degree” definition
ED advanced a new rulemaking definition that limits which graduate programs are treated as “professional degree” programs for loan‑cap purposes; negotiators on the RISE (Reimagining and Improving Student Education) committee agreed on recognizing only a short list (about 11 primary programs plus some doctoral programs) as professional, rather than the broader set institutions historically treated as professional programs [5] [4].
2. Immediate financial consequence: different loan caps for students
Under OBBBA’s loan architecture and the department’s implementation plan, students in programs defined as professional students are eligible for higher lifetime and annual loan limits (e.g., up to $50,000 per year and $200,000 aggregate for professional students versus lower caps for other graduate programs), so reclassification removes higher borrowing room for those programs now excluded [1] [2] [4].
3. Who is being excluded — and who is pushing back
Multiple news outlets and professional groups report that nursing (MSN, DNP, APRN tracks), physician assistant programs, occupational and physical therapy, audiology, speech‑language pathology, public health (MPH/DrPH), social work, many education master’s, counseling/therapy degrees, and others were left off ED’s professional list in the proposal; national organizations (AACN, ASHA, ASPPH, NASFAA, AAU and others) have publicly objected, warning of workforce and equity harms [7] [1] [6] [8] [5].
4. ED’s rationale and procedural posture
ED says the committee’s consensus drafted regulations using the 1965 regulatory language (34 CFR 668.2) and that the department’s interpretation aligns with that precedent; negotiators framed this as necessary to implement OBBBA loan provisions and to standardize which programs qualify for “professional” borrowing protections [4] [9].
5. Disagreement over precedent and scope
Advocates argue the new reading is much narrower than longstanding practice and ignores licensure/clinical practice realities across many fields; ED and some negotiators counter that the change restores a consistent regulatory baseline and that the list is not entirely exhaustive — but critics say the initial draft and committee consensus still exclude commonly recognized professional programs [9] [6] [5].
6. Broader policy and equity implications
Groups representing nursing, public health, speech‑language pathology, and others warn that lowering loan availability for fields with high tuition or where working students rely on borrowing will disproportionately affect women, low‑income and rural students, and could worsen workforce shortages in health care and education [8] [6] [2].
7. What’s procedural next and limitations of current reporting
ED published the committee’s draft language and has begun or will begin formal notice‑and‑comment rulemaking (NPRM) before final regulations take effect; the proposed loan and classification changes are slated to apply with implementation dates tied to OBBBA timelines (e.g., loan caps effective July 1, 2026 in reporting) [4] [2]. Available sources do not mention a final, agency‑wide published regulation that permanently fixes every program list beyond the committee’s draft consensus (not found in current reporting).
8. How stakeholders can respond — and where disputes will play out
Universities, accrediting bodies, and professional associations are submitting comment letters and lobbying ED and Congress; expect litigation challenges and further negotiated‑rule sessions because associations say the exclusions will be reversed or clarified only through public comment, legislation, or court action [6] [5].
Bottom line: ED’s 2024–2025 actions narrowed the regulatory definition of “professional degree” in service of OBBBA loan‑cap rules, dropping many health, education, and social‑service programs from the high‑borrower category and triggering strong pushback from professional groups and higher‑education advocates; the matter remains in rulemaking and dispute, with substantial consequences for loan access if the draft stands [4] [1] [8].