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What process did the Department of Education use in 2025 to classify degree programs as professional vs non-professional?
Executive summary
The Department of Education (ED) in 2025 used a rulemaking framework tied to an old federal regulation and the RISE committee’s work to narrow which post‑baccalaureate programs qualify as “professional” for loan rules, emphasizing criteria such as CIP codes, degree level, years of instruction, and licensure pathways (see NASFAA and Inside Higher Ed) [1] [2]. That definition produced a much smaller list of eligible programs and sparked controversy because many health and human‑service degrees (nursing, social work, public health, etc.) were left off or re‑interpreted, prompting pushback from professional associations and fact‑checks [3] [4] [5].
1. How ED framed the task: re‑defining “professional” for loan policy
ED’s 2025 effort was not an ad‑hoc list change but part of implementing Congress’s One Big Beautiful Bill Act (OBBBA) and the RISE committee process: the department proposed a regulatory definition intended to determine which graduate programs get higher federal loan caps and related repayment rules [2] [1]. ED said it was relying on a decades‑old regulatory anchor (34 CFR 668.2) and on consensus work within RISE to craft language for a Notice of Proposed Rulemaking [5] [2].
2. The criteria ED proposed: level, licensure, CIP codes, and duration
Under ED’s proposal and what the RISE committee agreed to, a program would count as “professional” only if it met multiple conditions: it prepares students for beginning practice and a level of skill beyond the bachelor’s; is generally at the doctoral level and requires roughly six years of postsecondary study (at least two post‑baccalaureate years); and is in the same four‑digit Classification of Instructional Programs (CIP) code as one of about 11 listed professions [1] [2]. Inside Higher Ed summarized these as stricter requirements than some alternative proposals on the table [2].
3. Practical implementation: using CIP codes to decide program status
ED and proponents argued that tying eligibility to four‑digit CIP codes would create a consistent, data‑driven method to determine which programs align with the enumerated professional fields, rather than subjective judgments by institutions [1] [2]. Advocates for including more programs urged ED to use broader health‑related CIP groupings (e.g., CIP 51) because narrow four‑digit matching would exclude many related programs despite similar workforce roles [4].
4. Scope change and the numbers: fewer programs labeled “professional”
Observers reported ED’s proposal reduced the count of programs considered professional from roughly 2,000 to fewer than 600, a shrinkage with immediate consequences for loan eligibility and caps under OBBBA’s new structure [3]. Commentators and advocacy groups warned that the change would limit access to higher loan amounts for many students in clinical and service professions [3] [4].
5. Who fell off the list — and why it matters
Multiple outlets and organizations highlighted that degrees central to healthcare and social services—advanced nursing (MSN, DNP), physician assistant, occupational/physical therapy, public health (MPH, DrPH), social work (MSW), and education master’s—were effectively excluded under ED’s narrower definition or its CIP‑based approach, raising concerns about workforce pipelines and affordability [6] [7] [4]. ED officials countered that the department was reverting to a historical regulatory definition and that critics overstated the novelty of the approach [5] [8].
6. Pushback and competing views: professional groups vs. ED
Professional associations (AACN, CSWE and others) argued the proposed definition contradicts accreditation, licensure practice, and workforce needs and urged ED to include broader CIP categories or recognize graduate‑level nursing and social work as professional [4] [7]. ED and some department spokespeople maintained the approach aligns with longstanding regulatory language and was the reasonable interpretation needed to implement OBBBA’s loan caps [5] [8].
7. Process mechanics: committee consensus, NPRM, and timelines
The RISE committee largely adopted ED’s proposed definition; if internal consensus faltered, the department retained authority to publish its own NPRM. ED planned to open a public comment period via a Notice of Proposed Rulemaking and aimed to finalize rules in 2026, giving stakeholders a formal avenue to argue for different criteria or broader CIP treatment [9] [5] [2].
8. Limits of current reporting and what remains unsettled
Available sources show the rulemaking rationale, the specific criteria ED proposed, and the areas of dispute, but they do not provide the final, legally binding text as of these reports nor the complete, definitive list of programs that will be labeled professional after the NPRM and comment period conclude; final outcomes were expected in 2026 [5] [2]. Stakeholders’ analyses focus largely on loan access impacts; available reporting does not fully quantify long‑term workforce effects [4] [3].
Bottom line: ED’s 2025 process replaced a broader, practice‑based understanding of “professional” with a criteria‑driven, CIP‑anchored rule intended to implement OBBBA’s loan limits; that method narrowed the set of programs that qualify and provoked pushback from multiple professional organizations and fact‑checking outlets [1] [2] [5].