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What criteria did the Department of Education use in 2025 to determine a degree is non-professional?
Executive summary
The Department of Education’s 2025 negotiated rulemaking (RISE committee) proposed a narrow definition of “professional degree” that generally limits the category to programs that complete academic requirements for beginning practice, demonstrate a level of skill beyond a bachelor’s degree, often are doctoral in nature requiring roughly six years postsecondary study, and—critically—fall into a short list of designated CIP codes; ED and the committee agreed to recognize only 11 primary fields plus some doctoral programs as “professional” for loan-limit purposes [1] [2] [3]. Advocacy groups warn this framework would exclude many health, education, and social-service degrees (nursing, public health, social work, education, etc.) from higher federal loan limits even if those programs include licensure paths [4] [5] [6].
1. What the Department proposed: a tighter, code‑based definition
The RISE committee’s draft rule ties “professional student/program” status to three core elements: (a) completion of academic requirements for beginning practice and skills beyond the bachelor’s level; (b) often alignment with doctoral-level education entailing about six years of postsecondary coursework; and (c) presence in a narrow set of 4‑digit Classification of Instructional Programs (CIP) codes—ED would formally designate 11 primary fields, plus certain doctoral programs, as professional [1] [2] [7] [3].
2. How that definition decides “non‑professional” status
Under ED’s framework, a degree that fails the combined test—especially missing the designated CIP code or the doctoral/6‑year threshold—would be treated as non‑professional even if it leads to licensure or advanced practice; negotiators explicitly noted that programs not sharing a 4‑digit CIP with the 11 listed fields would not qualify as professional degrees under the new regulatory text [2] [7].
3. Which programs advocacy groups say would be excluded
Professional associations and commentators point to an extensive list of programs that could lose professional designation under the proposal: nursing (MSN, DNP, NP, CRNA, midwifery), public health (MPH, DrPH), social work (BSW, MSW), education specialties, many allied health fields, counseling, and more. Groups argue these fields meet licensure and rigorous training standards yet would be excluded because of CIP‑code or degree‑level rules [4] [5] [6] [8].
4. Stakes: loan limits, access, and workforce concerns
The rule ties directly to loan‑limit changes in the One Big Beautiful Bill Act (OBBBA): graduate students would face lower annual and aggregate caps unless enrolled in programs ED deems “professional” (example caps cited in commentary: $20,500 annual/$100,000 aggregate for graduate programs vs. $50,000/$200,000 for professional programs beginning July 1, 2026). Critics warn that excluding many service professions from the higher caps could make advanced training less affordable and strain workforce pipelines in health, education, and social services [9] [3] [5].
5. Department response and contested narratives
ED officials, per press statements, say the new definition aligns with long‑standing precedent and a consensus reached in negotiated rulemaking; the department’s press secretary asserted the definition is consistent with historical practice and that committee language reflects that consensus [1]. Meanwhile, multiple news outlets and professional organizations dispute that narrative—arguing the effect is a substantive reclassification that will cut access—so there is an explicit conflict between ED framing and sector groups’ readings [1] [3] [5].
6. Technical levers and why CIP codes matter
CIP codes—used for federal data and regulation—function as a hard gate in the proposed rule: programs that share the designated 4‑digit CIP codes are eligible, while similar programs in different CIP codes would be excluded even if their curricula, licensure outcomes, or degree levels are comparable. Observers say this makes the rule outcome‑driven by administrative classification rather than solely by educational substance [2] [7].
7. Legal and political friction ahead
Commentary and university associations predict lawsuits and further regulatory friction because OBBBA, existing HEA language, and other federal rules reference “program of study” and “professional” status in multiple contexts—so narrowing the category in one set of loan‑implementation rules may generate challenges about consistency across statutes and regulations [7] [3].
8. What reporting does not resolve
Available sources do not provide the final, legally binding regulatory text or an exhaustive list of the 11 designated fields with their exact CIP codes; they also do not report definitive administrative answers to whether legacy programs or existing students will retain prior loan eligibility (not found in current reporting) [7] [3].
Bottom line: ED’s 2025 proposal replaces a broader, practice‑and‑licensure driven conception of “professional” with a tighter test emphasizing doctoral/6‑year thresholds and specific CIP codes—an approach ED says aligns with precedent but that professional groups say will exclude many licensure‑based fields and reduce student access [1] [2] [3] [4] [5].