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Which criteria did the Department of Education use in 2025 to label degrees non-professional?
Executive summary
The Department of Education’s 2025 negotiated-rulemaking proposal and RISE committee discussions set new, specific criteria for which graduate programs count as “professional” — centering on program-level attributes such as having a 4‑digit CIP code, preparing students for licensure or “beginning practice,” and demonstrating a level of professional skill beyond the bachelor’s degree [1]. That framework resulted in many health, education, and social‑service degrees being excluded from the department’s proposed “professional” category (examples and reactions documented by public health and nursing groups) and has provoked pushback over loan‑limit eligibility and workforce implications [2] [3] [1].
1. What the Department of Education proposed: a rules‑based definition
In November 2025 the Education Department, through the RISE committee negotiated rulemaking, proposed a definition of “professional student/program” that ties professional status to program features: completion of academic requirements for beginning practice in a given profession, a level of professional skill beyond a bachelor’s degree, inclusion of a path to professional licensure, and identification by a 4‑digit Classification of Instructional Programs (CIP) code [1]. NewAmerica’s reporting likewise describes the effort to codify the professional‑degree line for implementing One Big Beautiful Bill Act (OBBBA) loan caps and notes the department relied on the regulation as of July 4, 2025 when shaping which programs qualify [4].
2. Which programs were left off and why advocates say it matters
Advocacy and professional organizations say the proposed framework would exclude many programs historically viewed as professional — nursing (MSN, DNP, NP, CRNA), public health degrees (MPH, DrPH), social work (BSW, MSW), education specialties, counseling, therapy fields, and other applied health professions — which could limit borrowers’ access to the higher $200,000 aggregate loan cap reserved for professional students [5] [2] [3]. The Association of Schools and Programs of Public Health warned excluding MPH/DrPH degrees would reduce access to public health education and weaken workforce pipelines [2]. Nursing groups such as the AACN have argued exclusion contradicts precedent recognizing licensure‑leading programs as professional [6].
3. How the criteria operate in practice (CIP codes, licensure, and degree level)
The department’s approach uses discrete, documentable signals: a program’s 4‑digit CIP code, whether it explicitly prepares students for licensure or “beginning practice,” and whether it requires a level of skill beyond the bachelor’s degree [1]. Negotiators discussed using CIP codes to avoid ad‑hoc distinctions based on program length and to create a consistent administrative rule across HEA and OBBBA language [7]. NewAmerica noted the department anchored the definition to existing regulation language current on the OBBBA enactment date [4].
4. Pushback, denials, and competing narratives
The Department of Education’s press secretary told Newsweek the coverage was “fake news” and asserted the department has had a consistent definition and that consensus language aligns with historical precedent; the department said the committee included higher‑education institutions in crafting the proposed rule [3]. Advocacy groups—nursing, public health, social work—say the proposal disregards decades of precedent and will harm access and workforce capacity [6] [2] [1]. Public reporting shows both an official defense of the department’s process and broad sectoral alarm over practical consequences [3] [6].
5. Stakes: loans, workforce, and likely litigation
The reclassification matters because under OBBBA implementation students in programs designated “professional” would be eligible for higher loan limits ($200,000 aggregate) while other graduate students face lower caps ($100,000 aggregate), affecting affordability for many clinical and service professions [4] [8]. News outlets and professional societies warn that reduced borrowing capacity could deter enrollment and worsen shortages in nursing, public health, social work, and education [6] [2] [8]. NewAmerica and other commentators note uncertainty remains about implementation details and foresee legal and administrative challenges [4].
6. What reporting does and does not show
Available sources document the department’s proposed criteria (CIP code, licensure pathway, skill level beyond bachelor’s) and list fields that advocacy groups say would be excluded; they also record the department’s public defense and industry pushback [1] [2] [3] [6]. Available sources do not mention the final, enacted regulatory text taking effect after negotiated rulemaking, nor do they provide a comprehensive, official list directly from the department of every program reclassified; those items are not found in current reporting provided here [1].
Bottom line: the 2025 approach reframes “professional” status into objective program criteria (CIP code, licensure path, practice readiness beyond a bachelor’s), which produced widespread concern because many applied health, education, and social‑service degrees appear to fall outside that proposed definition — a change with material loan and workforce implications and contested interpretations between ED and professional groups [1] [2] [3] [6].