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What criteria did the 2025–2026 DOE use to distinguish professional from nonprofessional degree titles?
Executive summary
The Department of Education’s 2025–2026 negotiated proposal set specific, narrow tests for what counts as a “professional” degree: programs generally at the doctoral level (with limited exceptions), requiring at least six years of academic instruction (including at least two post‑baccalaureate years), and tied to particular Classification of Instructional Programs (CIP) codes and an explicit link to beginning practice or licensure — a set of criteria that would shrink the list of eligible programs from roughly 2,000 to under 600 in reporting [1] [2]. The RISE committee’s draft and ED’s presentation prompted widespread pushback from nursing, public‑health, social‑work and university groups who say the criteria exclude many recognized health and service professions and will reduce student loan access [3] [4] [5] [6].
1. What the Department of Education proposed: checklist-style criteria
ED’s negotiated rulemaking proposal presented a multi-part test for “professional” degree programs. Under the version described by Inside Higher Ed and NAfSAA coverage, a program would generally need to be doctoral level (with a narrow exception for the Master of Divinity), require at least six years of academic instruction including at least two post‑baccalaureate years, and fall within the same four‑digit CIP code as one of 11 explicitly named professions — plus signpost that the program prepares students for beginning practice and a level of skill beyond a bachelor’s [1] [7] [6]. Those combined thresholds are stricter than prior, broader interpretations [1].
2. How that definition would change the universe of “professional” programs
Observers say the proposed criteria would drastically reduce the set of programs eligible for the higher federal loan limits under the One Big Beautiful Bill Act (OBBBA). Multiple accounts report that ED’s definition would shrink eligible programs from about 2,000 to fewer than 600, and the department and the RISE committee agreed to recognize only about 11 primary programs plus some doctoral programs as “professional” for loan caps [2] [5]. Inside Higher Ed noted the department’s formulation tightened eligibility compared with earlier, more permissive committee options [1].
3. Where nursing, public health and social work fit — and why groups object
Nursing organizations and public‑health and social‑work associations say the new tests exclude many established professional degrees. Nursing programs were reported as excluded from the professional category in ED’s working approach, prompting warnings that hundreds of thousands of current students and pipeline capacity could be affected [4] [8]. ASPPH and CSWE flagged that excluding MPH/DrPH and social work degrees threatens workforce development by limiting access to higher loan limits and contradicts longstanding recognition of these degrees as professional credentials [3] [6].
4. Legal and technical tensions inside negotiated rulemaking
Negotiated‑rule participants voiced concerns about ambiguous language and legal risk. NAfSAA summaries record debate over whether a program had to be literally doctoral level or could meet the six‑year instruction requirement even if not titled a doctorate; committee members warned vagueness could invite litigation [7]. Inside Higher Ed observed that one committee member’s alternative (Holt’s) proposal would have used less restrictive criteria (e.g., 80 credit hours and two‑digit CIP alignment) but did not win full support [1].
5. Financial mechanics: why the definition matters for students
The immediate reason this classification matters is loan eligibility. Under OBBBA’s implementation, only programs classified as “professional” would access the highest annual federal loan caps (and the phase‑out of Grad PLUS and new loan limits amplify that effect). Stakeholders warn capping or reclassifying degrees will reduce graduate borrowing capacity for fields like advanced nursing, PAs, occupational therapy and others, potentially deterring students from those paths [4] [2] [5].
6. Competing perspectives and implicit agendas
ED asserts a need for clear, historically grounded rules for what counts as professional; the department’s spokesperson said its approach “aligns with historical precedent” and defended consistency [9]. Universities and professional associations counter that the department’s narrower test appears designed to limit federal borrowing and program eligibility — an outcome aligned with OBBBA’s broader loan‑limit objectives — and that the criteria undervalue accreditation, licensure pathways and workforce realities [5] [3]. Advocacy groups frame the move as a cost‑cutting measure with downstream workforce impacts; ED frames it as regulatory clarity [9] [5].
7. What reporting does and does not show
Available sources document the specific criteria discussed at RISE and the immediate reactions from nursing, public health, social work and higher‑education groups, and they report the anticipated reduction in eligible programs [1] [4] [3] [5] [2]. Available sources do not mention final regulatory text, a completed rulemaking outcome, or judicial challenges beyond committee debates (not found in current reporting).
Bottom line: the department’s 2025 proposal replaced a broad, precedent‑based understanding of “professional” degrees with a tighter, multi‑part test — focused on doctoral standing, minimum years of instruction, specific CIP codes and links to beginning practice — and that narrower test has triggered concerted pushback from health, social service and academic groups who say it will shrink loan access and affect workforce pipelines [1] [4] [3] [5].