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What criteria did the Department of Education use in 2025 to label degrees as non-professional?
Executive summary
The Department of Education’s 2025 negotiated rulemaking proposed a narrow definition of “professional degree” that would limit the category to a short list of fields and certain doctoral programs — tying professional status to CIP codes, doctoral level/years of study, and a path to licensure — which would reduce how many programs qualify for higher federal loan limits (e.g., professional students would keep larger aggregate loan caps) [1] [2] [3]. Organizations representing nursing, social work, public health and other fields say the proposal excludes widely‑recognized professional programs (MPH, DrPH, MSN, DNP, MSW, etc.) and would constrain students’ borrowing and program access [4] [5] [6].
1. What the Department of Education proposed — a tight, code‑and‑credential test
In negotiated rulemaking convened under the RISE committee, ED staff put forward a definition that narrows “professional degree” to programs that meet multiple conditions: signify completion of the academic requirements for beginning practice in a profession, demand a level of skill above a bachelor’s, generally are at the doctoral level requiring about six academic years post‑secondary (including two post‑baccalaureate), and — crucially — sit within a limited set of 4‑digit CIP codes or an 11‑program list the Department designates [1] [7]. NASFAA summaries and RISE committee reporting emphasize that programs not sharing those CIP codes would be excluded even if they meet licensure or doctoral criteria [1] [7].
2. Why the definition matters: loan limits and who gets them
OBBBA/HR 1 created different loan ceilings: graduate programs face much lower annual and aggregate limits ($20,500 annual; $100,000 aggregate) while designated professional degree programs would continue to qualify for higher limits (up to $50,000 annual; $200,000 aggregate). Thus whether a program is labeled “professional” determines student borrowing capacity going forward — a central driver behind ED’s push to clarify the category [2].
3. Who would be affected — fields and organizations pushing back
Multiple higher‑education and professional groups warn the ED proposal would exclude many health, education, social work, and allied fields that long have been treated as professional. The Association of American Universities reported the committee agreed to recognize only 11 primary programs plus some doctoral programs as professional, a move AAU says will curtail how many programs are eligible for higher loan limits [3]. Nursing groups (ANA, AACN) and social work and public‑health associations say their degrees meet professional practice and licensure tests yet would be left out under the CIP/doctoral emphasis [6] [5] [4].
4. The procedural context: negotiated rulemaking and consensus language
ED advanced this definition through the RISE negotiated rulemaking process and reached “consensus” language to propose as part of implementing OBBBA changes. Negotiators debated program‑of‑study definitions and whether the new language would have broad effects across the Higher Education Act uses of “program of study,” reflecting concern that a targeted change could have wider legal and administrative consequences [7].
5. The technical sticking point: 4‑digit CIP codes and legacy lists
A technical mechanism — requiring a program to share a 4‑digit CIP code with designated professional fields or be on ED’s narrow list — is central to exclusions. NASFAA and other summaries flag that programs otherwise meeting licensure, doctoral level, or skill thresholds would still be excluded if they lack the particular CIP alignment, prompting criticism that program classification (an administrative code) could override substantive professional criteria [1].
6. Competing viewpoints and political framing
ED officials defended the approach as consistent with historical precedent and necessary to implement statutory loan caps, with the department saying the consensus language aligns with prior regulatory practice [8]. Advocacy groups counter that the change is arbitrary, threatens workforce pipelines (nursing, social work, public health), and may rely on technocratic coding choices rather than actual professional roles [4] [5] [6]. The AAU frames the change as a direct consequence of implementing H.R. 1 and notes the regulatory effect will reduce the number of programs eligible for higher loan limits [3].
7. What reporting does not yet say — limits of available sources
Available sources describe the draft definition, the RISE process, and reactions from affected professions, but do not provide ED’s final published regulatory text, any court challenges, or detailed lists of the eleven designated programs in full within these excerpts [1] [3] [7]. Specific numbers of students affected are reported in some outlets (e.g., nursing enrollment totals quoted elsewhere) but are not consistently summarized across the provided items [9] [10].
8. Bottom line for readers
ED’s 2025 proposal replaces a broad, precedent‑driven sense of “professional degree” with a narrower, rule‑based definition emphasizing doctoral‑level training, years of study and specific CIP codes — a technical change that directly affects federal loan eligibility and has prompted organized pushback from multiple professional associations who say it excludes programs that meet traditional professional criteria [1] [2] [4] [5].