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 was the Department of Education's rationale and rulemaking process behind the 2025 reclassification?
Executive summary
The Department of Education’s late‑2025 effort to narrow which graduate credentials count as “professional degrees” is tied to implementation of the One Big Beautiful Bill Act (OBBBA) and limits on graduate borrowing; the Department says it is applying a narrow, decades‑old regulatory definition and has convened rulemaking to clarify which programs qualify [1] [2]. Coverage shows many nursing, education, social‑work and public‑health degrees are listed as targeted for exclusion in notices and reporting, but multiple outlets note the change was proposed and not yet final as of reporting [3] [1] [2].
1. What the Department said it was trying to do — tighten an old definition to fit new loan rules
The Department frames the exercise as restoring or applying the statutory/regulatory definition of “professional degree” first outlined in federal regulations, rather than inventing a new category, and doing so in the context of OBBBA’s elimination of the Graduate PLUS program and the new borrowing caps that flow from it [1] [2]. That means the Department’s rationale is procedural and fiscal: to identify the subset of graduate credentials that should be eligible for higher federal loan limits under the changed law and the Department’s reading of 34 CFR 668.2 [1] [2].
2. Which programs are in the spotlight — nursing, education and allied‑health among those named
Reporting and fact‑checks list a set of credentials the Department said it would no longer classify as “professional degrees” under the proposed approach: education (including teaching master’s), nursing (MSN, DNP), social work (MSW, DSW), public health (MPH, DrPH), physician assistant, occupational therapy, physical therapy, audiology, speech‑language pathology and counseling/therapy degrees [1]. Newsweek and other outlets highlighted shock and pushback from groups such as the American Association of Colleges of Nursing, which warned excluding nursing “disregards decades of progress” and conflicts with the Department’s own assertion that professional programs are those leading to licensure and direct practice [3].
3. Rulemaking steps described in reporting — committee, proposed regulation, public comment
Local and trade reporting says the Department convened a rulemaking committee to define “professional” and planned a typical notice‑and‑comment sequence: issue a proposed regulation, open a 30‑day public comment period, then potentially revise before finalizing [2]. Snopes and other fact‑checks emphasize the distinction between proposal and final rule: as of late 2025 the agency had proposed reclassification but had not yet made it permanent [1].
4. The legal/legislative backdrop — OBBBA and the end of Graduate PLUS
The proximate cause for the change is legislative: President Trump’s July 2025 One Big Beautiful Bill Act repealed the Graduate PLUS program and capped graduate borrowing [1]. That statutory shift forced the Department to decide which graduate credentials should retain access to higher borrowing limits under the remaining statutory framework, prompting the reclassification effort [2].
5. Competing perspectives and stated impacts
Advocates for health and education graduate programs argue the reclassification would reduce students’ ability to finance licensure‑leading training, harming workforce pipelines — a criticism voiced by organizations such as AACN and covered in Newsweek [3]. Some conservative policy analysts framed the move as part of broader Project 2025/OBBBA efforts to rein in federal student‑loan exposure and to encourage market signals to reduce tuition — a framing noted in local coverage and analysis [2]. Snopes cautions that the Department’s narrowing is technically an interpretation of an old regulation and that social media claims overstated the immediacy or finality of a “reclassification” [1].
6. What reporting leaves unclear or unreported
Available sources do not mention specific internal Department analyses quantifying how many students or programs will lose higher loan eligibility, nor do they publish the precise legal memorandum the Department relied on to justify its narrow reading of 34 CFR 668.2 (not found in current reporting). Coverage also does not provide the full proposed regulatory text or a consolidated list of every program by CIP code that will be affected (not found in current reporting).
7. How the public process can shape the outcome
Because the Department has followed formal rulemaking steps — committee work, a proposed regulation and a public comment period — stakeholders will have opportunities to challenge definitions, present workforce data (for example nursing shortages), or urge exceptions. Local university reporting described institutions preparing targeted scholarships or other mitigations in expectation of reduced federal borrowing capacity [2].
Bottom line: The Department’s stated rationale is a legal‑technical effort to apply an older regulatory definition within a new statutory environment created by OBBBA; journalists and fact‑checkers stress the change was proposed and subject to rulemaking and public comment, while professional groups warn of real workforce and student‑finance harms if the proposal becomes final [1] [3] [2].