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 criteria did the Department of Education use to determine professional vs. non-professional degrees in 2025?
Executive summary
The Department of Education’s 2025 negotiated-rulemaking and proposal set a multi-part test that narrows which post‑baccalaureate programs count as “professional” for higher federal loan limits: the program must signify readiness for beginning practice, require skill beyond a bachelor’s, generally be at the doctoral level (with limited exceptions), include at least six years of total academic instruction (including two post‑baccalaureate years), and fall in the same four‑digit CIP code as a specified list of professions (about 11 fields) — language reported from the Department’s sessions and final proposal [1] [2]. The practical effect: the definition reduces the pool of qualifying programs and has prompted objections from nursing, social work, public health, and other professional associations worried about reduced loan access [3] [4] [5] [6].
1. What the Department officially proposed: a multi‑part test
The Department’s proposal emerging from the RISE negotiated‑rulemaking frames a “professional degree” as one that (a) signifies that students have the skills to begin practice in a profession, (b) requires a level of professional skill beyond a bachelor’s, (c) is generally at the doctoral level (with exceptions like the Master of Divinity), (d) requires at least six years of academic instruction including at least two years post‑baccalaureate, and (e) is included in the same four‑digit CIP code as one of a limited list of professions explicitly named in the regulation — all criteria reported by Inside Higher Ed and New America from ED’s sessions and final language [1] [2].
2. How CIP codes and an explicit profession list change the landscape
The Department augmented the text by tying eligibility to four‑digit CIP codes and to 11 specifically listed professions (with Clinical Psychology added in final language), meaning programs outside those CIP clusters — even if they lead to licensure or direct practice — may be excluded unless they share a CIP code with an enumerated field [2]. New America notes that this broadened psychology inclusion but warns the multi‑part test will still shrink the number of students who qualify [2].
3. The practical rule‑making mechanics: negotiated rulemaking and proposed rule
These criteria flowed from the RISE committee’s negotiated rulemaking process that concluded in early November 2025; ED presented the proposal and is poised to follow with a Notice of Proposed Rulemaking and public comment period, meaning the language could change before final rule [5] [1]. NASFAA’s coverage of the sessions also highlights active debate over degree level, program length, and definitions used across statutes [7].
4. Immediate effects and who’s sounding the alarm
Professional associations representing nursing, social work, public health, and other fields say the new definition will limit access to higher loan caps, potentially making graduate education less attainable and shrinking workforce pipelines in critical sectors [4] [3] [5]. Newsweek and Nurse.org report outcry from the American Association of Colleges of Nursing and others after nursing programs were effectively excluded from the Department’s list; ED’s press office has pushed back in media exchanges, calling some coverage inaccurate while defending historical precedent for the definition [6] [4].
5. Disagreements, ambiguity, and likely legal and policy pushback
Observers note two tension points: the rule ties professional status to program format (doctoral emphasis and six‑year threshold) rather than solely to licensure or workforce function, and it uses CIP codes that may not map neatly to how professions are organized academically or clinically — a design likely to invite challenges from schools and associations [1] [2] [3]. New America explicitly flags that even with clarified definition, other regulatory requirements and potential lawsuits make outcomes uncertain [2].
6. What advocates want changed and why
Groups like AACN, CSWE, and public‑health advocates argue the Department’s framework ignores the practical realities of health and human services training — that many essential professions require rigorous, licensed practice but do not fit the department’s six‑year/doctoral template — and they are urging inclusion based on licensure pathways and CIP parity rather than degree level alone [4] [3] [5].
7. What to watch next
Expect ED to issue a formal NPRM that opens a 30‑day comment window, continued lobbying and public statements from professional organizations, and possible litigation or congressional scrutiny if final rules remain restrictive — all of which are foreshadowed in the reporting from association statements and coverage of the RISE sessions [5] [3] [7] [2].
Limitations: available sources do not publish the full final regulatory text in this packet, so precise statutory citations, the complete enumerated profession list, and ED’s final legal defense language are not provided here; reporting indicates the criteria above but readers should consult the Department’s NPRM and the final rule for definitive legal language [1] [2].