Which Department of Education policies define what counts as a 'professional' degree?
Executive summary
The Department of Education (ED) has proposed a narrow regulatory definition of “professional degree” that ties the label to specific criteria — including being doctoral-level (with limited exceptions), requiring at least six years of instruction, aligning with a four‑digit CIP code for one of roughly 11 named fields, and preparing students to begin practice and licensure — and that proposal would shrink programs classified as “professional” from roughly 2,000 to fewer than 600 (reported effects and criteria summarized by Inside Higher Ed and public reporting) [1] [2]. The proposal is being advanced through RISE negotiated rulemaking and is explicitly tied to new loan caps in the One Big Beautiful Bill Act, prompting pushback from nursing, public‑health, social‑work and other professional associations [3] [4] [5].
1. What the Department is proposing — rules, tests and a short list
ED’s draft rules, presented in RISE negotiations, set multiple gates a program must pass to be called a “professional degree”: it must signify preparation to begin practice in a profession, require a higher level of skill than a bachelor’s degree, generally be a doctoral‑level credential (with the Master of Divinity as an exception), require at least six years of academic instruction including two post‑baccalaureate years, and occupy the same four‑digit CIP code as one of 11 specifically listed professions — a formula far narrower than historical practice [1] [6].
2. Why loan policy drove the redefinition
The immediate policy driver is federal student‑loan limits created by the One Big Beautiful Bill Act (OBBBA): programs designated “professional” qualify for higher annual and lifetime loan caps, so the Department’s definition determines access to larger graduate borrowing limits. ED and negotiators framed the definition as necessary to implement those new borrowing rules [6] [1].
3. Scale and likely impact: far fewer programs qualify
Multiple outlets and observers say the draft definition would cut the number of programs counted as “professional” dramatically — from roughly 2,000 programs currently regarded as professional down to fewer than 600 — which would move many nursing, public‑health, social‑work, audiology, speech‑language pathology, physician‑assistant and other advanced programs out of the higher‑loan category [2] [6] [7].
4. Opposition and sector responses — health and education fields push back
Professional organizations have objected that the proposal ignores decades of precedent and threatens workforce pipelines. The American Association of Colleges of Nursing and other groups said excluding nursing and public health contradicts the Department’s own earlier language about programs leading to licensure and direct practice; ASHA and ASPPH specifically warned audiology, speech‑language pathology and public health programs are excluded under ED’s test [8] [7] [3].
5. Defense from ED and the agency’s legal posture
ED has argued it is returning to a longstanding regulatory definition first articulated decades ago and says its proposed language “aligns with this historical precedent,” while framing the rulemaking as implementation of new statutory law (the OBBBA and subsequent sections governing loan limits). Negotiated rulemaking records show ED advanced the detailed criteria during RISE sessions [6] [1].
6. Two competing definitions emerged in negotiating rooms
Negotiators offered alternative, more inclusive formulations — for example, a counterproposal (Holt’s) that would have required programs to show preparation for practice and higher skill, plus a minimum credit‑hour threshold and a broader two‑digit CIP code tie — but ED’s version tightened requirements [1] [9]. That split explains why some committee members and sector groups say consensus was thin and why legal and political fights are likely.
7. Practical consequences employers, students and schools should expect
Analysts warn that narrower loan access — shifting annual caps from $50,000 to as little as $20,500 for many programs — will make graduate education costlier on students and could reduce applicant pools in already short professions, a point made in commentary and advocacy pieces [10] [2]. Professional bodies say this could worsen workforce shortages and impair public health and education systems [4] [5].
8. What reporting does not settle
Available sources do not mention whether ED’s draft definition will change state licensure, Medicare/Medicaid reimbursement, or private‑sector credential recognition beyond loan eligibility; several organizations explicitly said the rule does not affect state licensure or federal health‑reimbursement rules, but long‑term indirect effects are not yet traced in reporting [7]. Sources also do not document final agency action; ED expected to release final rules by spring 2026 at the latest [6].
9. Bottom line and where this goes next
This is a regulatory implementation fight over how to translate a new statute into operational definitions that control graduate borrowing. ED’s proposed tests are narrow and targeted to limit which programs qualify for higher loan limits; professional associations, some negotiators and commentators say that narrowing is arbitrary and harmful to fields such as nursing, public health and social work [1] [5] [4]. Expect continued negotiated‑rulemaking minutes, a formal NPRM comment period, legal challenges and intense lobbying before any final, binding definition is set [6] [9].