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Are there recent changes or proposed updates (as of 2024–2025) to the Department of Education’s professional categories and definitions?
Executive summary
The Department of Education is actively proposing and discussing revisions to professional categories and definitions tied to student loan eligibility and program design — notably a new “professional degree”/“professional student” definition under negotiated rulemaking (RISE committee) and related loan-eligibility guidance (e.g., Parent PLUS/Graduate PLUS legacy provisions) [1]. Separately, reporting and stakeholder statements show the Department in 2024–25 rolling out multiple rulemaking and administrative changes while also planning major organizational shifts that could reassign functions to other agencies [1] [2] [3].
1. What’s changing: “professional degree” and “professional student” definitions
Negotiated rulemaking sessions convened by the Department’s Reimagining and Improving Student Education (RISE) committee have discussed and the Department has unveiled proposals to define “professional student,” “professional degree,” and to clarify what constitutes a “program of study” for loan-eligibility purposes [1]. Those discussions include changes meant to affect legacy eligibility for Parent PLUS and Graduate PLUS borrowing limits and to identify which fields (and CIP codes) qualify for expanded borrowing treatment [1].
2. Why advocates and professions are pushing back
Stakeholders such as nursing organizations have publicly objected to proposed definitions that they say would exclude large health professions — for example, nursing — from the department’s narrow definition of “professional programs,” arguing that exclusion would reduce graduate nursing students’ access to certain federal loan provisions and make advanced nursing education less affordable [4] [5]. News outlets and trade groups report these concerns as immediate and vocal, framing the change as one with workforce consequences for health care [4] [5].
3. How the Department plans to implement some changes (regulation vs. guidance)
Negotiated-rulemaking discussions indicate the Department may use both formal regulatory texts (Notice of Proposed Rulemaking) and administrative documents like Dear Colleague Letters (DCLs) to communicate changes. For example, the Department signaled it could issue DCLs to provide institutions guidance on legacy provisions rather than embedding every detail in a regulation [1]. That split matters because DCLs are faster and easier to change but carry different legal weight than final rules [1].
4. The larger administrative context: rulemaking amid institutional shake-ups
These definitional and loan-eligibility proposals come as the Department has been unusually active across rulemaking and reorganizational moves: it published hundreds of Federal Register items in 2024 [3], announced interagency agreements to move program administration to other departments [2], and has been the target of major reorganization coverage in outlets such as POLITICO and NPR outlining plans to transfer core offices to Labor, HHS, Interior, and State [2] [6] [7]. That context raises questions about which office will carry forward any final definitions and how stable those policies will be [2] [6].
5. Competing viewpoints in the record
Proponents within the Department (as reflected in RISE committee briefings) describe definitional precision as necessary to align federal loan eligibility and program integrity and to limit unintended growth in borrowing protections [1]. Opponents — professional associations and some negotiators — warn that overly narrow definitions will exclude legitimate, rigorous post-baccalaureate programs (notably nursing) and will have downstream workforce impacts [4] [5]. The Department’s use of both rulemaking and DCLs suggests it is trying to balance legal durability with administrative flexibility [1].
6. What to watch next
Watch for a formal Notice of Proposed Rulemaking (NPRM) from the Department and any accompanying Dear Colleague Letters or guidance that spell out CIP codes or named professions that qualify as “professional” [1]. Also monitor congressional reaction and legal analysis, given reporting that the Department is concurrently pursuing major redistributions of program administration to other agencies — a move already prompting legal and policy scrutiny [2] [7].
Limitations and gaps: available sources document the negotiated-rulemaking discussions, stakeholder pushback, and broader agency reorganization, but they do not provide a finalized regulatory text or an exhaustive list of affected professions and CIP codes; those specifics are "not found in current reporting" and will depend on forthcoming NPRMs or guidance from the Department [1] [4] [5].