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What criteria did the Department of Education use in 2025 to label degrees non-professional?
Executive summary
The Department of Education’s 2025 negotiated rulemaking and implementation of the One Big Beautiful Bill Act (OBBBA) produced a narrower, codified definition of “professional degree” that excludes many health, education, and social-service programs that historically were treated as professional programs; the department said it relied on a longstanding 1965 regulatory definition and consensus language from the RISE committee [1] [2]. Under the resulting framework, a “professional student” must be enrolled in a program that meets criteria including completion of academic requirements for beginning practice beyond the bachelor’s level, a 4‑digit CIP code, and a path to professional licensure — criteria that the Department’s interpretation left many programs outside the category [3] [4].
1. What the Department of Education said it used: consensus rulemaking tied to an old regulation
The Department framed its approach as restoring and applying the federal regulatory definition of “professional degree” as it existed on July 4, 2025, and said the negotiated rulemaking committee (the RISE committee) reached consensus language that aligns with decades‑old precedent [1] [2]. Officials and the Department press office defended the decision as consistent with the historical regulation first articulated in the 1960s [2] [1].
2. The concrete criteria the Department and allied documents cite
Advocacy and professional organizations quote the Department’s initial framework as defining a “professional student” by three core elements: [5] a program that 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,” [6] use of a 4‑digit Classification of Instructional Programs (CIP) code to identify eligible programs, and [7] inclusion of a pathway to professional licensure — together used to determine if a program qualifies for higher federal graduate loan caps [3] [8].
3. How that test translated into exclusions
When the Department applied that interpretation, it excluded many degrees that professional associations and some news outlets previously considered professional — including nursing (BSN, MSN, DNP), many public‑health degrees (MPH, DrPH), social work (MSW, DSW), education master’s, physician assistant, occupational/physical therapy, audiology, speech‑language pathology, counseling/therapy, accounting, architecture, and some business and engineering programs [9] [10] [11]. Reporting and organizational statements emphasize that the change directly affects which students can access the higher $50,000 annual / $200,000 lifetime loan caps reserved for “professional students” under OBBBA [9] [1].
4. Why stakeholders say the Department’s test is narrower than practice
Professional associations — including nursing, public health, and social work groups — argue the Department’s interpretation is excessively narrow because many programs meet longstanding definitions of professional preparation (rigorous education, licensure pathways, direct practice readiness) even if they weren’t explicitly listed in the 1965 examples. They warn that tying eligibility to specific CIP codes and a narrow licensure interpretation will limit student access to graduate loans and compress workforce pipelines in critical fields [12] [8] [3].
5. Department pushback and claims of consistency
The Department and its press secretary defended the move as consistent with historical precedent and the consensus reached in negotiated rulemaking, rejecting some reports as inaccurate and saying the language aligns with the regulatory baseline [2] [1]. News organizations cite the Department’s insistence that the change is an implementation of statutory loan limits under OBBBA rather than an arbitrary reclassification [2] [1].
6. Practical implications the Department’s criteria create
Because OBBBA set different loan caps for “graduate” versus “professional” programs, the Department’s criteria change who can borrow up to the higher limits; excluded programs’ students would face lower annual and aggregate federal loan limits, potentially making graduate education less affordable in fields such as nursing and public health, according to reporting and higher education groups [1] [8] [4].
7. Points of dispute and what the sources don’t settle
Sources show clear disagreement: the Department calls the definition consistent with precedent and negotiated consensus [2] [1], while professional organizations and outlets call the outcome a departure that will harm workforce pipelines [12] [8] [4]. Available sources do not mention detailed internal legal analyses the Department used to exclude specific CIP codes, nor do they supply the full text of the RISE committee’s consensus language in these snippets — those documents are not found in current reporting provided here [3] [1].
8. What to watch next
Expect professional associations (nursing, public health, social work, etc.) to continue pressing the Department for reversal and to file public comments or legal challenges; reporting already notes public statements, petitions, and alarm from groups like the American Association of Colleges of Nursing [12] [11]. The practical enforcement date and whether the Department refines CIP‑code or licensure guidance will determine how far‑reaching the impact becomes [1] [3].