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Which criteria did the Department of Education use to label degrees as non-professional in 2025?
Executive summary
The Department of Education’s 2025 negotiated-rulemaking workgroup proposed a narrower definition of “professional degree” that ties the label to specific criteria: preparation for beginning practice beyond the bachelor’s level, a path to professional licensure, and alignment with a 4‑digit CIP code — plus a preference for longer, post‑secondary program structures that historically matched medical, law and related degrees [1] [2]. That framework led ED to propose excluding many health, education, and applied fields (nursing, public health, social work, education, many therapy fields and others) from the “professional” category, which would affect eligibility for higher loan limits under the One Big Beautiful Bill Act (OBBBA) [3] [4] [2].
1. What criteria ED proposed — the technical tests that matter
In the RISE negotiated‑rulemaking sessions ED and its committee described a “professional student” as one enrolled in a program that (a) requires completion of the academic requirements for beginning practice in a profession and a level of professional skill beyond that normally required for a bachelor’s degree, (b) includes a path to professional licensure, and (c) is identified by a 4‑digit Classification of Instructional Programs (CIP) code — language ED used to draw clearer lines for loan‑limit policy [1] [2]. Several accounts note that ED also relied on historical precedent in the statute (citing the 1965 regulation as it existed on July 4, 2025) to argue which fields traditionally fit the professional label [5].
2. How those criteria translate to exclusions in practice
Applying those criteria resulted in ED’s framework excluding many programs that advocates had long treated as professional credentials — notably postbaccalaureate nursing degrees (MSN, DNP, NP), MPH/DrPH public‑health degrees, social work (MSW), many counseling/therapy fields, education specialties, and some allied‑health and applied STEM programs [3] [6] [2]. News outlets and professional groups reported that these exclusions would mean students in those programs lose access to the higher $200,000 aggregate loan limit reserved for “professional” students and instead face the lower graduate caps established under OBBBA [3] [4].
3. Arguments ED and proponents make in favor of the narrower test
The Department framed the move as restoring a consistent, consensus‑based definition that aligns with historical regulations and clarifies eligibility across federal statutes — a technical fix supporters say prevents arbitrary distinctions and keeps the statutory meaning tied to long‑standing examples like medicine, law and dentistry [3] [5]. ED told at least one outlet that the committee included institutions of higher education and reached language meant to reflect precedent and fairness in rule application [3] [7].
4. Pushback from professional associations and fields affected
Nursing, public‑health, social‑work and education organizations uniformly warned the criteria ignore decades of professionalization, licensure realities and workforce needs. The American Association of Colleges of Nursing said excluding postbaccalaureate nursing contradicts ED’s own acknowledgment that professional programs lead to licensure and direct practice [8]. ASPPH (public health) warned excluding MPH/DrPH would restrict access to higher federal loan limits and threaten the public‑health workforce pipeline [2]. CSWE (social work) described the test as disheartening and said it could make social‑work graduate education less attainable [1].
5. The practical stakes: loans, workforce and legal questions
The change matters because OBBBA ties the larger $200,000 “professional” loan aggregate to this definition; students not classed as professional would face lower graduate loan caps [5] [4]. Advocates argue that limiting borrowing power will reduce access to graduate education in fields essential to health, education and social services [2] [8]. Observers also note the rulemaking process itself — negotiated rulemaking consensus — may prompt lawsuits or further administrative revisions as institutions and advocacy groups push back [5] [7].
6. Fault lines and hidden incentives to notice
The debate mixes technical regulatory drafting with political priorities: ED emphasizes statutory fidelity and consistency (framing the change as a correction), while critics say the narrower criteria conveniently shrink the set of students eligible for generous borrowing — a fiscal outcome aligned with OBBBA’s broader loan‑cap goals [3] [4]. Some social posts and informal lists have amplified which degrees might be on “the chopping block,” but those lists are not themselves official rule texts and sometimes conflate Department of Labor classification moves with Department of Education proposals [6].
7. What reporting does not (yet) say
Available sources do not mention ED’s final regulatory text (if any) after negotiated rulemaking or the exact list of CIP codes that would qualify; they report preliminary consensus language and organizational reactions [2] [1]. They also do not provide final determinations on litigation outcomes or whether ED will revise language in response to pushback [5] [7].
Bottom line: ED’s 2025 framework defines “professional degree” by a three‑part test — beginning‑practice skill beyond a bachelor’s, path to licensure, and a 4‑digit CIP alignment — and applying that test has led to high‑profile exclusions (nursing, public health, social work, education and others) that critics say will reduce loan access and strain workforce pipelines [1] [2] [3].