What criteria did the Department of Education use to determine a degree was non-professional in 2025?

1. What the Department said it used: a “consensus-based” construction tied to existing regulation

The Department and the RISE negotiated-rulemaking committee said they relied on the longstanding federal regulatory definition from 1965 and on a consensus reached in that committee to clarify which programs count as “professional,” framing the change as restoring consistency with historical precedent rather than inventing new criteria ^{[4] [1] [3]}.

2. The working criteria reported by professional associations and committee documents

Advocacy groups and committee summaries report that the Department’s framework defined a “professional student” as someone enrolled in a program that: (a) requires completion of the academic requirements for beginning practice in the profession and a level of professional skill beyond a bachelor’s degree, (b) corresponds to a 4-digit Classification of Instructional Programs (CIP) code, and (c) includes a path to professional licensure — and these elements were used to decide which credentials qualify for the higher loan limits ^[2].

3. What programs were excluded under that test — and why critics say the criteria are narrow

Using that framework, the Department announced that many fields commonly thought of as professions — nursing (MSN, DNP), education degrees including teaching master’s, social work (MSW, DSW), public health (MPH, DrPH), physician assistant, occupational/physical therapy, audiology, speech-language pathology, and counseling/therapy degrees — would not be treated as “professional degrees” for loan-limit purposes ^{[1] [5]}. Critics (professional associations) argue the Department’s interpretation applies an unusually narrow reading of the 1965 regulation and neglects decades of precedent recognizing these credentials as professional because they meet licensure and skill thresholds ^{[6] [5]}.

4. The financial mechanism that made the definitional fight consequential

This definitional change matters because OBBBA tied different loan caps to whether a program is a “professional degree”: professional students get higher annual ($50,000) and aggregate ($200,000) limits; other graduate students face lower caps (annual $20,500; aggregate $100,000). Reclassifying a program lowers its students’ borrowing capacity and thus can affect access to graduate-level professional training ^{[1] [3]}.

5. How the Department justified exclusions and how opponents responded

The Department maintained it was using a consistent, consensus definition developed through negotiated rulemaking and rooted in the pre-existing regulation ^{[4] [3]}. Nursing and public-health organizations, and discipline-specific accreditors, countered that excluding their degrees ignores licensure requirements, workforce needs, and established academic standards — and warned of workforce shortages and reduced educational access if students lose higher loan eligibility ^{[6] [5] [7]}.

6. Reporting limits and disputed details to watch for

Available sources summarize committee outcomes, lists of excluded fields, and advocacy reactions but do not provide full agency rule text or line-by-line regulatory rationale in the supplied documents, so granular legal reasoning and any internal agency analyses are not found in current reporting ^{[1] [2]}. Snopes, news outlets and professional associations report and contest the same list of exclusions; however, the precise regulatory language and any exceptions or phase-in details are not present among the cited pieces ^{[1] [3]}.

7. Competing framings: consistency vs. narrow reinterpretation

The Department framed the change as restoring or codifying a consistent historical definition developed through consensus ^[4]. Opponents frame it as a narrow reinterpretation of precedent with immediate financial consequences for students and workforce pipelines in health, education, and social services ^{[6] [5] [7]}. Independent explainers note the change would implement OBBBA’s loan-limit structure and that litigation and further rulemaking disputes are likely ^{[1] [3]}.

8. What to expect next and what to read closely in the rule text

Watch for the final published regulatory language (the full 34 CFR amendment and any preamble explanation), any implementation guidance on CIP-code mapping and licensure-pathway definitions, and legal challenges from professional associations; those items will determine how rigid or flexible the Department’s criteria actually prove to be in practice — materials not included in the supplied sources but flagged as the decisive follow-ups by reporting and stakeholder statements ^{[1] [2] [3]}.