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Which criteria did the U.S. Department of Education use in 2025 to define non-professional degrees?
Executive summary
The Department of Education’s 2025 negotiated-rulemaking effort produced a new, narrower definition of “professional degree” used to determine higher federal graduate loan limits: the draft ties professional status to programs that lead to licensure, require coursework “beyond that normally required for a bachelor’s degree,” and are identified by a four‑digit CIP (Classification of Instructional Programs) code — a change many health and social‑service organizations say will exclude programs such as nursing, public health, and social work from higher loan caps [1] [2] [3].
1. What the Department proposed: a technical, CIP‑based test
The Education Department’s RISE committee reached consensus on a definition that characterizes a “professional student” as enrolled in a professional degree program that (a) requires completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree, (b) has a 4‑digit CIP code, and (c) includes a path to professional licensure [1]. Negotiation notes from NASFAA show ED officials presenting language focused on when a program “awards a professional degree” and on clarifying program‑of‑study boundaries tied to legacy loan eligibility [4].
2. Practical consequence: fewer programs eligible for higher loan caps
Advocacy groups and university associations warn that the new definition narrows which programs count as “professional,” limiting eligibility for the higher aggregate limits under H.R.1 / the One Big Beautiful Bill framework. The Association of American Universities reported the committee agreed to recognize only 11 primary programs plus some doctorates as professional, a move AAU says will curtail the number of programs eligible for expanded borrowing [3]. Organizations representing nursing and public health have warned this could restrict graduate borrowing and make advanced training less attainable [2] [5].
3. Who’s explicitly raising alarms — nursing, public health, social work
The American Association of Colleges of Nursing and other nursing groups have publicly objected that nursing was omitted from the new professional‑degree list, arguing nursing meets criteria of rigorous education, licensure, and direct practice and that exclusion contradicts precedent and threatens workforce pipelines [6] [5]. The Association of Schools and Programs of Public Health said the proposal would exclude MPH and DrPH degrees and make public health education less financially attainable [2]. The Council on Social Work Education described the definition and its effects as limiting access to social work education and pointed to the same three criteria in ED’s framework [1].
4. Department pushback and claims of continuity with precedent
The Department’s press secretary for higher education told Newsweek the reporting was “fake news,” asserting that ED has had a consistent definition for decades and that the consensus language aligns with historical precedent; the department says the committee included institutions of higher education and agreed on the proposed language to be published as a rule [7]. That response frames the change as a clarification rather than a radical reclassification [7].
5. Why the CIP code matters — an ostensibly neutral but consequential filter
Using a 4‑digit CIP code as part of the test is a seemingly technical criterion intended to standardize identification of program types across institutions, and supporters argue it prevents arbitrary distinctions based on program length. Critics say it becomes a blunt instrument: programs with legitimate professional training and licensure pathways may be excluded simply because their CIP designation or program structure does not match the department’s list of recognized professional program categories [1] [3].
6. Political and policy context: loan caps and implementation of H.R.1 / OBBBA
The negotiated definition is part of broader rulemaking to implement student‑loan provisions in H.R.1 (One Big Beautiful Bill Act) — including phasing out Grad PLUS loans and establishing new loan limits — so the stakes are both regulatory and fiscal: narrowing “professional” status reduces how many students can access the higher $200,000‑style aggregate limits that applied to some graduate programs under prior practice [7] [3].
7. Limits of current reporting and what is not yet clear
Available sources document the draft definition and stakeholder reactions but do not publish the final regulatory text or an exhaustive list of which CIP codes or program titles will be classified as professional in the final rule; they also do not provide a definitive final tally of excluded programs beyond the cited examples [1] [3]. For program‑level outcomes and exact loan‑limit mechanics, institutions and borrowers will need the finalized rule text and ED guidance, which are not provided in these sources.
Bottom line: ED’s 2025 negotiated rulemaking ties professional‑degree status to licensure pathways, educational level above the bachelor’s, and a 4‑digit CIP code — a technical triage that numerous health and social‑service organizations say will exclude many programs (nursing, public health, social work) from higher federal graduate loan limits while the Department frames the change as consistent with historical precedent and a needed clarification [1] [2] [3] [7].