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What criteria and process did the Department of Education use to reclassify degrees in 2025?
Executive summary
The Department of Education’s 2025 proposal to narrow the definition of “professional degree” would reduce programs that qualify for the higher graduate loan limits — reportedly shrinking the list from roughly 2,000 programs to fewer than 600 — and would exclude many nursing, public health, social work and allied-health graduate programs from that category [1] [2]. The change flows from implementing the One Big Beautiful Bill Act (OBBBA) and a RISE Committee proposal that uses an older federal regulation’s list as of July 4, 2025 and ties “professional” status to a defined set of fields and CIP codes [2] [3].
1. What the Department proposed and why it matters
The Department’s rulemaking under OBBBA and work by its Reimagining and Improving Student Education (RISE) Committee would limit “professional degree” status to a much smaller set of fields — explicitly including medicine, pharmacy, dentistry and a handful of others — and would extend that designation only to programs in the same four‑digit Classification of Instructional Programs (CIP) codes as those fields, rather than the broad set of graduate programs currently treated as professional [2]. That matters because students in programs the Department does call “professional” would retain substantially higher annual and aggregate graduate loan limits (for example, professional programs would keep $50,000 annual and $200,000 aggregate limits, while other graduate programs could be limited to $20,500 annually and $100,000 aggregate starting July 1, 2026) [2].
2. Which programs are reported excluded and who’s raising alarms
Multiple outlets and advocacy groups report that advanced nursing (MSN, DNP), public health (MPH, DrPH), social work (MSW, DSW), physician assistant, occupational and physical therapy, audiology, speech‑language pathology, many education degrees, and some counseling programs are among those the Department’s proposal would not treat as “professional” [4] [3] [5]. Nursing organizations including the American Association of Colleges of Nursing and the American Nurses Association explicitly protested the change, warning it undermines parity across health professions and could worsen workforce shortages [6] [5] [7].
3. The Department’s legal and technical framing
Reporting and analysis note that OBBBA took the unusual step of anchoring the definition to an existing federal regulation as it stood on the bill’s enactment date (July 4, 2025), and the Department’s reading narrows “professional degree” to the fields listed in that regulation plus programs sharing the same four‑digit CIP codes — a technical approach that reduces the count of qualifying programs [2]. Professional‑degree status therefore becomes a function of historical regulation text and CIP code mapping rather than a broad “licenses or direct practice” test as some stakeholders assert [2] [3].
4. Disagreement over whether this is “reclassification” or a proposal
Fact‑checking reporting emphasizes a distinction: several organizations and media treat this as the Department “reclassifying” programs now, while fact‑checkers note the rule was proposed and had not yet been finalized at the time of some coverage — meaning changes would follow rulemaking procedures including a Notice of Proposed Rulemaking and public comment, and could be altered before becoming final [4] [3]. Snopes and others caution that public messaging sometimes conflates a proposal with a completed reclassification [4].
5. Practical impacts flagged by advocates and associations
Nursing and public‑health associations say excluding their graduate programs from “professional” status would limit access to higher federal loans, make advanced education more costly for students, and risk shrinking pipelines for essential workers in underserved areas [6] [3] [7]. NASFAA commentary and public comment threads show broad pushback from students and practitioners who argue the policy will have real workforce and equity consequences [8].
6. What the public rulemaking process looks like next
ASPPH and other organizations reported the Department was expected to issue a Notice of Proposed Rulemaking and open a 30‑day public comment period after the RISE Committee’s consensus; that step is the legal channel for stakeholders to challenge, amend or support the Department’s interpretation before it becomes binding [3]. NewAmerica’s analysis underscores that litigation is likely once final rules take effect because the stakes — loan access and program classification — are high [2].
Limitations and context: available sources describe the proposal, stakeholder reactions, and the technical means (CIP codes, the July 4, 2025 regulation) the Department used, but they do not publish the full text of the Department’s final regulatory language in these excerpts — nor do they show the Department’s own internal justification beyond aligning with the regulation and OBBBA’s definitions [2] [3]. Where coverage differs, some outlets report the change as already in force while fact‑checkers emphasize its proposal status [4] [5].