What was the Department of Education's rationale and public response to the 2025 non-professional degree rule change?
Executive summary
The Department of Education (ED) and its RISE negotiated-rulemaking committee narrowed the agency’s working definition of “professional degree” to 11 named fields and a set of criteria — emphasizing doctoral-level preparation, licensure requirements and “a level of professional skill beyond that normally required for a bachelor’s degree” — which will shrink the universe of automatically eligible programs and subject many health, education and allied‑health degrees to exclusion unless they meet the new criteria [1] [2]. The change ties directly to loan-limit reforms in the One Big Beautiful Bill Act (OBBBA): under the law and proposed implementation, fewer programs qualifying as “professional” means students in many affected fields could face lower annual borrowing caps and new lifetime limits [3] [4].
1. What the Department says it changed and why
ED and the RISE committee produced a narrower, criteria‑based definition that lists 11 example degree fields and says other programs can qualify only if they meet set thresholds — generally doctoral‑level training, licensure to begin practice, and “a level of professional skill beyond that normally required for a bachelor’s degree” — a formulation ED and negotiated committee members say aligns with historical precedent and the statutory framework in OBBBA [1] [2] [5].
2. How the rule connects to loan limits in the One Big Beautiful Bill
The redefinition is procedural but consequential: OBBBA reorganized graduate borrowing by imposing annual caps and lifetime limits; the “professional” label determines which borrowers can access higher professional loan limits versus lower graduate caps. Therefore, narrowing the professional category effectively reduces borrowing eligibility for many programs, even without changing the caps themselves [3] [4].
3. Who compiled the list and the role of negotiated rulemaking
ED convened a negotiated‑rulemaking (neg reg) committee — the RISE committee — that included a range of stakeholders and reached consensus language that ED is required to publish in its proposed rule. ED’s public materials stress that the committee process and forthcoming notice‑and‑comment period mean the rule is not final and could change in response to public input [6] [5] [2].
4. Fields explicitly included and excluded in reporting
Reporting and stakeholder statements indicate ED’s examples narrowed the list to 11 fields (medicine, pharmacy, dentistry, optometry, law, veterinary medicine, osteopathic medicine, podiatry, chiropractic, theology, clinical psychology) while excluding many health, education and allied‑health programs often considered “professional” — for instance, nursing (MSN, DNP), public health (MPH, DrPH), physician assistant, occupational and physical therapy, audiology and speech‑language pathology have been reported as outside the default list unless they meet the new criteria [1] [3] [7].
5. Public and institutional backlash
Professional associations, academic groups and advocacy organizations immediately criticized the change. The American Association of Colleges of Nursing said excluding nursing contradicts ED’s own licensure‑based notion of professionalism and will harm workforce development; ASHA warned audiology and speech‑language pathology were excluded; the Association of Schools and Programs of Public Health said public health degrees were left out and vowed to press for inclusion during the comment period [8] [7] [9]. Medical‑workforce and academic groups publicly framed the move as a threat to pipeline and access for critical professions [10] [9].
6. Political framing and competing narratives
ED spokespeople defend the outcome as consistent with long‑standing regulatory language and the consensus reached in neg reg; ED also said the public will have another opportunity to weigh in prior to finalization [5] [11]. Critics portray the change as intentional narrowing that will worsen shortages in nursing, public health and allied professions and as a political move tied to OBBBA’s bipartisan statutory cap structure [10] [4] [9].
7. Practical implications flagged by analysts
Analysts and commentators warn that reducing automatic “professional” status will likely make some graduate programs harder to afford because of lower annual borrowing caps (for example, the difference between roughly $20,500 and $50,000 annual caps cited in contemporaneous reporting), potentially reducing enrollment in some fields and aggravating workforce shortages — a point made by employers and HR observers as well as higher‑education advocates [4] [11].
8. What comes next and how stakeholders can respond
ED is expected to issue a Notice of Proposed Rulemaking with a formal public‑comment window; stakeholders including professional societies, universities and state actors plan to submit comments and possibly litigation if they judge harm from the final rule [9] [12]. ED stresses it may revise language in response to comments, and multiple sources note the rule will not be final until after that process [5] [6].
Limitations: available sources do not mention final regulatory text published after the neg reg or specific numerical projections of enrollment changes tied to the final rule; the facts above are drawn from the Department’s statements, negotiated‑rulemaking summaries and contemporaneous reporting [1] [5] [2].