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How has the Department of Education (ED) historically defined a 'professional degree' in federal regulations and guidance?
Executive summary
The Department of Education (ED) has long used a regulatory phrase—rooted in 34 C.F.R. § 668.2—that treats a “professional degree” as a credential preparing graduates to begin practice in a licensed profession, typically beyond the bachelor’s level; recent negotiated-rulemaking in 2025 narrowed which programs the department would treat as “professional,” prompting pushback from nursing, public health, social work and other fields (negotiations and lists described in committee materials and reporting) [1][2][3]. Coverage shows the department’s current working definition anchors professional degrees to programs that lead to licensure and “beginning practice,” while stakeholders say the applied list is narrower than historical or sector expectations [1][4].
1. Historical regulatory language: “beginning practice” and degrees beyond the bachelor’s
Federal regulations cited by ED define a professional degree in terms of qualifying graduates to start practice in a profession and requiring “a level of professional skill beyond that normally required for a bachelor’s degree”; ED’s references to longstanding regulatory text undergird its current interpretation and were cited by the agency in 2025 discussions [5][4].
2. How ED applied that language in recent rulemaking: a narrower, example-based list
In 2025 negotiated rulemaking (the RISE committee) ED proposed a specific, limited list of programs that would meet its practical test for “professional” status—examples repeatedly mentioned include medicine, dentistry, law, theology and similar fields—and said a student is a “professional student” if enrolled in a program awarding a professional degree upon completion [1][6][2].
3. Practical consequence driving the debate: loan limits and access
Why this matters: the One Big Beautiful Bill Act (OBBBA) set different federal loan lifetime limits for graduate students ($100,000) versus “professional degree” students ($200,000). ED’s interpretation therefore directly affects borrowing capacity for students in contested fields; organizations representing nursing, public health, social work, audiology, speech-language pathology and others warned the proposed definition would exclude their students from higher loan limits [7][3][8].
4. Sector objections: arguments from nursing, public health, social work and allied health
Stakeholders argue ED’s working list is inconsistent with professional practice realities—institutions and discipline groups (e.g., Council on Social Work Education, Association of Schools and Programs of Public Health, nursing organizations, audiology and speech-language pathology groups) say their degrees lead to licensure and entry to practice and thus should fit the regulatory standard; they contend the department’s applied list is narrower than the statutory/regulatory text implies [5][3][7][8].
5. ED’s defense and continuity claim
ED and some reporting note the agency is using the same regulatory definition found in 34 C.F.R. § 668.2 and asserts it is applying long-standing language; other accounts characterize ED’s current interpretation as narrower than past practice because of how ED anchors the definition to a limited set of example professions [4][9].
6. Media and fact-checking context: disagreement about scope and change
News outlets and fact-checkers documented both the department’s stance and the viral claims about reclassification. Reporting states ED’s interpretation will exclude multiple credentials from the department’s practical “professional” list in late 2025, but notes debate over whether this is a genuine change to the regulation’s text or a narrower agency interpretation for implementing OBBBA’s loan rules [4][6].
7. What’s unresolved in the sources: rule text vs. final rule and legal framing
Available sources show the RISE negotiated-rulemaking reached preliminary consensus language and ED planned a Notice of Proposed Rulemaking, but they do not provide the final published regulatory text in the Federal Register in these documents; sources do not mention the final regulatory language or any subsequent legal challenges as of the items provided [3][1][4].
8. Takeaway for readers: definition vs. application—and where to watch next
The technical regulatory definition points to programs that prepare for “beginning practice” at a level beyond a bachelor’s, but ED’s 2025 implementation tied the definition to a specific list of professions for loan-cap purposes—prompting sector disputes about fairness and workforce impacts. Watch for ED’s formal Notice of Proposed Rulemaking and the final rule text and for sector filings during the public comment period to see if the department broadens or narrows the applied list [1][3][2].