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Has the Department of Education proposed rules on reclassification that would retroactively remove forgiveness credits?

Checked on November 22, 2025
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Executive summary

The available reporting shows the U.S. Department of Education has proposed changing how it defines “professional degrees,” which would affect which graduate programs qualify for higher loan limits — and nursing and several other fields appear on lists excluded from that definition in the proposed rule [1] [2]. Multiple outlets note the proposal is not yet final and that the Department says it will release final rules later; at least one fact-checking outlet stressed the proposal had not yet passed and the agency is using a longstanding regulatory definition [3].

1. What the Department has proposed — and why it matters

The Department’s negotiated-rulemaking work tied to the One Big Beautiful Bill’s loan provisions would place a narrower interpretation on what counts as a “professional degree,” and that classification determines higher borrowing caps available to students in those programs [3] [1]. Newsweek and The Independent reported that nursing, physician assistant, physical therapy, social work, counseling and several other fields are listed as not classed as “professional” under the Department’s proposed approach — a change that directly affects eligibility for larger graduate loan limits [1] [2].

2. Is this retroactive removal of “forgiveness credits” in the proposal?

The specific phrase “retroactively remove forgiveness credits” is not mentioned in the provided sources. Reporting focuses on reclassification of degree types and resulting borrowing limits rather than on erasing previously awarded loan-forgiveness credits or forgiveness program eligibility; available sources do not mention retroactive removal of forgiveness credits [3] [1] [2].

3. Where fact-checkers and the Department place the locus of uncertainty

Snopes emphasized that the Department had not yet finalized any reclassification and therefore “reclassified” claims are premature; it highlighted that a proposal does not equal a final rule and that the Department points to a historical regulatory definition from 1965 as the basis for its interpretation [3]. The Department’s own spokesperson described the definition as “consistent” with decades of precedent and said a committee including higher-education representatives agreed on the language that will be in the proposed rule [2] [4].

4. Who’s pushing back — and why

Nursing organizations and some news outlets framed the change as exclusionary, arguing that removing nursing and related health and human-services fields from the “professional degree” category undermines parity and could make graduate education less accessible for those professions [1] [2]. The American Association of Colleges of Nursing (as quoted by Newsweek) called the exclusion of postbaccalaureate nursing education “disregard[ing] decades of progress” and warned it would harm workforce development [1].

5. What proponents (or the Department) say in response

The Department’s press office and the committee behind the proposal argue the redefinition merely restates a long-standing regulatory concept and was developed with input from institutions of higher education; they presented it as consensus-based language aligned with historical precedent [2] [4]. Snopes’ reporting also notes the Department’s framing that the proposal follows an old regulatory definition [3].

6. What remains unresolved and what to watch next

Sources show the rulemaking process was ongoing as of the coverage: Snopes noted the proposal had not passed and reported the Department expected to release final rules by spring 2026 at the latest [3]. Key unresolved items in available reporting include whether final language will differ from the draft lists [3] and whether any change would be applied retroactively to benefits or forgiveness already granted — available sources do not mention retroactive removal of forgiveness credits [3] [1] [2].

7. How to read the competing narratives

Critics frame the change as a material cut to graduate students’ borrowing access in fields dominated by women and in health/social-service sectors [2]. The Department frames the move as a technical, precedent-based clarification that emerged from a committee process involving higher-education stakeholders [2] [4]. Fact-checkers caution that proposals and press reports about them are not the same as enacted policy and urge readers to wait for the final rule text [3].

If you want, I can monitor follow-up reporting and the Department’s official Federal Register postings for the final rule text and any decision-making about retroactivity or forgiveness-credit treatment once those sources publish them.

Want to dive deeper?
What specific Department of Education proposal addresses reclassification and forgiveness credits?
Would proposed reclassification rules retroactively remove existing student loan forgiveness credits?
How would retroactive reclassification affect borrowers in Public Service Loan Forgiveness and IDR programs?
What legal challenges could block the Department of Education from applying reclassification rules retroactively?
What timeline and comment period apply to the Department of Education's proposed reclassification rulemaking?