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Which exact degrees did the Department of Education label non-professional in 2025 and what criteria were used?
Executive summary
The Department of Education’s negotiated-rulemaking committee in November 2025 agreed on a much narrower definition of “professional degree” that would leave many graduate programs out of the higher federal loan caps; the department’s draft ties eligibility to a short list of roughly 11 fields and to multi-part criteria including doctoral-level status, at least six years of instruction, and matching four‑digit CIP codes [1] [2]. Multiple higher‑education and professional groups say that nursing, many advanced practice health degrees, social work, MSW/Ed.D. and other programs will be excluded or at risk under the proposal [3] [4] [5].
1. What the Department proposed: a more restrictive rule for “professional” programs
The Department’s latest draft presented by Under Secretary Nicholas Kent would limit which graduate programs qualify as “professional” by requiring programs to (a) signify students can begin practice in a particular profession, (b) require skills beyond a bachelor’s degree, (c) generally be doctoral level (with limited exceptions), (d) require at least six years of academic instruction including two post‑baccalaureate years, and (e) fall in the same four‑digit CIP code as one of about 11 explicitly named professions [1] [2]. The package aims to implement H.R.1’s differential loan caps so that “professional” students could access larger annual ($50,000) and aggregate ($200,000) limits while other graduate students face much lower caps [2].
2. Which exact degrees are being treated as “professional” — and which are not clearly listed
Reporting and advocacy groups say the department’s list centers on a core set of fields — medicine, law, dentistry, pharmacy, theology and similar traditional professions — and expands Clinical Psychology to include Psy.D./Ph.D., producing roughly 11 named fields; other programs could qualify only if they share a four‑digit CIP code with those fields [6] [2]. The sources do not publish a complete, line‑by‑line roster of every included or excluded degree in the draft; instead they describe categories, examples, and the rule’s mechanics [1] [2]. Available sources do not provide a definitive, published list of every exact degree labeled non‑professional by the department.
3. Which programs and professions are being reported as excluded or at risk
Multiple professional associations and outlets report that nursing (MSN, DNP), many advanced practice nursing roles (nurse practitioner, CRNA), physician assistant programs, occupational therapy, audiology, social work, clinical psychology distinctions, and other health professions could lose “professional” status under the department’s framework or be limited by CIP‑code matching rules [3] [7] [4] [8]. News outlets and trade groups explicitly say nursing has been dropped from the department’s list in the draft, and nursing organizations (AACN, state nursing leaders) voice alarm that graduate nursing students would be ineligible for higher loan caps [9] [3] [10].
4. The criteria that drive inclusion and why critics say it matters
The department’s criteria — doctoral level (generally), six years of academic instruction, demonstrable readiness for practice, and four‑digit CIP code alignment — are designed to make the definition more objective and to limit which programs receive larger borrowing capacity [1] [2]. Critics argue those technical thresholds (especially the six‑year requirement and doctoral emphasis) arbitrarily exclude widely practiced, licensure‑based professions whose programs are master’s level or shorter (for example, many PA and some OT or nursing programs), and that using CIP codes and program length can mischaracterize real workforce needs [4] [11].
5. Competing perspectives and implicit agendas
The American Enterprise Institute and some policy analysts defend excluding degrees where typical borrowing is low (they cite Ed.D./MSW as examples) and argue the narrower list targets loan relief to the most capital‑intensive fields [5]. Higher‑education associations, professional schools, and unions counter that the rule disproportionately harms essential service professions and that the department’s procedural choices (CIP code use, doctoral‑level emphasis) reflect fiscal restraint priorities in OBBBA implementation and could be driven by political aims to shrink Grad PLUS reach [5] [4] [2].
6. What remains unclear and what reporting does not show
Reporting documents the criteria and examples and quotes advocacy responses, but none of the provided sources publishes the department’s final, exhaustive table of included versus excluded degree program codes — meaning the exact universe of “non‑professional” degree titles is not publicly listed in these pieces [1] [2]. Available sources do not mention a completed, official Department of Education list enumerating every specific degree labeled non‑professional; that appears to await the formal Notice of Proposed Rulemaking and published regulatory text [12].
7. What to watch next
Expect the department’s Notice of Proposed Rulemaking to publish the full regulatory text and CIP‑code lists and to open a 30‑day comment period; that text will provide the definitive list and allow calculation of which specific degree programs lose higher loan access [12] [2]. Opposition from nursing, social work, and other associations signals likely public comments and legal challenges, meaning the final implementation could change before it becomes binding [3] [4].