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What criteria did the Department of Education use in 2025 to define a 'professional' degree?
Executive summary
The Department of Education (ED) in 2025 adopted a new, narrower definition of “professional degree” tied to the One Big Beautiful Bill Act (OBBBA) that lists specific fields, relies on 4‑digit CIP codes and requires a path to professional licensure; this change affects who qualifies for higher graduate loan caps ($50,000 annual/$200,000 aggregate) versus lower limits for other graduate programs (e.g., $20,500 annual/$100,000 aggregate) [1]. Multiple higher‑education and professional organizations say ED’s framework would exclude fields such as nursing, public health, social work and others from “professional” status under its interpretation [2] [3] [4].
1. What ED actually proposed: a coded, licensure‑linked definition
ED’s rulemaking and OBBBA implementation anchor the “professional degree” label to a statutory/regulatory list of fields (including pharmacy and dentistry), broaden inclusion by same 4‑digit CIP code, and require that the program award a professional degree and typically include a path to licensure; those programs would retain higher loan limits set by the law [1] [5] [4]. New America’s summary of the final language says the department included 11 named fields plus programs sharing the same 4‑digit CIP codes [1]. NASFAA’s reporting from negotiated rulemaking echoes that ED defined a professional student as one “enrolled in a program of study that awards a professional degree” and explained the department’s proposed professional degree definition for the committee [5].
2. The practical consequence: who keeps the bigger borrowing caps
OBBBA and ED’s implementation establish two tiers of graduate borrowing: professional degree programs would be eligible for up to $50,000 per year with a $200,000 lifetime cap, while other graduate programs face lower annual and aggregate limits ($20,500 annual/$100,000 aggregate starting July 1, 2026) — a central reason ED’s definition matters for students’ finances [1]. New America and multiple outlets highlight that the label directly changes access to the new Graduate borrowing regime and Repayment Assistance Plan provisions [1].
3. Where the controversy focuses: which fields were excluded
ED’s narrower interpretation — described in contemporaneous reporting and fact‑checks — has the practical effect of excluding many health and service professions from the “professional” bucket under ED’s framework; Snopes lists education (teaching master’s), nursing (MSN, DNP), social work (MSW/DSW), public health (MPH/DrPH), physician assistant, physical/occupational therapy, audiology and counseling degrees among those ED said it would no longer classify as professional degrees in late 2025 [2]. Advocacy groups including public health and social work educators warned that the RISE committee proposal and ED’s draft definition would leave out MPH/DrPH and social work, restricting financial access [3] [4].
4. ED’s defense and competing narratives
ED officials and some reporting say the department relied on long‑standing regulatory language that dates to the 1960s and matched the statute as enacted on July 4, 2025; ED spokespeople have pushed back on characterizations that ED “changed” the precedent, arguing the consensus‑based language aligns with historical definitions [6] [1]. At the same time, negotiators and stakeholders told NASFAA that the department’s move to pin definitions to CIP codes and explicit program lists tightened the scope compared with broader professional practice understandings [5].
5. Stakeholder reactions and lobbying — hidden agendas to watch
Professional associations for nursing, public health and social work uniformly criticized the proposal as understating the academic rigor and licensure‑linked nature of their fields and warned of workforce impacts; those groups are lobbying to be restored to the professional list and to preserve loan access [7] [3] [4]. Some media pieces frame the policy in the politics of the Trump administration’s OBBBA rollout and point to potential capacity impacts on critical sectors like nursing and education — an implicit policy agenda to reduce federal graduate lending exposure [8] [9].
6. What remains uncertain and next steps
Reporting notes ED reached negotiator consensus on proposed language but also issued a Notice of Proposed Rulemaking and anticipated public comment periods, meaning the definition was not necessarily final and could face lawsuits or revision [3] [1]. New America and NASFAA caution that practical implementation, enforcement using CIP codes, and subsequent legal challenges will determine how many programs ultimately qualify [1] [5]. Available sources do not mention a final, unappealable regulatory text that permanently fixes every affected program list beyond the negotiated and proposed rulemaking materials [1] [5].
7. Bottom line for readers
ED’s 2025 approach defines “professional degree” narrowly by named fields, CIP code alignment and licensure pathways, with direct loan‑limit consequences under OBBBA; stakeholders disagree sharply about which programs meet those criteria and legal and rulemaking processes could change outcomes [1] [2] [4]. If you are or advise students in nursing, public health, social work or related fields, follow the pending rulemaking, association lobbying, and any ED clarifications of the CIP‑based lists closely because those determinations will affect borrowing capacity and program access [3] [7].