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Were any graduate or doctoral programs included in the Department of Education's 2025 non-professional reclassification?

Checked on November 23, 2025
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Executive summary

The Department of Education’s recent rulemaking would sharply narrow which programs count as “professional degrees” for federal loan purposes, and multiple outlets report that many graduate and doctoral programs — notably nursing, physician assistant, occupational therapy, audiology, public health and other advanced health and education degrees — would be reclassified out of the “professional” category (e.g., only medicine, law, dentistry and pharmacy would clearly remain) [1] [2]. Negotiated-rulemaking summaries and higher-education groups say the department and its RISE committee limited the list to roughly 11 primary programs plus “some doctoral” programs, shrinking a list that historically covered many more graduate credentials [3] [4].

1. What the proposed reclassification does and why it matters

The practical effect of the Department of Education’s proposal is to restrict which graduate and doctoral programs are eligible for the higher loan limits and legacy benefits tied to “professional” status under the One Big Beautiful Bill (OBBBA); under the law graduate borrowing is capped differently depending on whether a program is “professional,” and the Grad PLUS program is being eliminated for new borrowers — changes that make the professional/non‑professional label financially consequential for graduate students [5] [6]. News outlets and advocacy groups describe the rule as reducing the set of recognized professional degrees from roughly 2,000 program titles to under 600, and say that loan ceilings and program access will shift accordingly [7] [8].

2. Which graduate/doctoral programs reporters say would be reclassified

Journalists and policy commentators report that commonly graduate‑level clinical and allied health programs such as advanced nursing degrees (MSN, DNP, APRN and specializations), physician assistant, occupational therapy, audiology, public health and certain education and counseling programs appear on lists of programs slated to lose “professional” status under the draft rule [1] [2] [9]. Several outlets and professional organizations highlighted nursing as a high‑profile example of a field the department’s new definition would exclude from “professional” status for loan purposes [8] [6].

3. What the department and rulemaking process have said (and what’s still pending)

Negotiated‑rulemaking notes indicate the RISE committee debated a new definition that emphasizes doctoral‑level training and six years of postsecondary education as markers of “professional” programs, creating ambiguity over which graduate programs qualify [4]. The Association of American Universities reports that by the end of sessions the department and RISE agreed to recognize only 11 primary programs and some doctoral programs as “professional,” and that the department plans to publish regulatory text and accept public comment before finalizing rules [3]. Reporting and fact checks warn that the proposal is not a final reclassification until the rulemaking concludes and regulations are published [10].

4. Conflicting framings and who’s pushing back

Higher‑education groups, professional associations (especially nursing organizations), and university leaders frame the change as a threat to workforce pipelines and graduate access, arguing that removing loan flexibility will deter students from critical professions and strain healthcare and education systems [11] [8] [9]. Conversely, pro‑reform advocates and some commentators characterize the move as an attempt to tighten a broadly applied regulatory example from 1965 and to limit high graduate borrowing; the department’s proposed definition seeks a narrower, more uniform test for “professional” status [10] [4].

5. Financial specifics anchored in reporting

Under OBBBA’s new statutory structure summarized in reporting, graduate students in non‑professional programs would face lower lifetime/annual caps (examples cited include a $100,000 graduate cap vs. higher limits for professional students, and some outlets cite $20,500 annual caps for certain borrowers), and the Grad PLUS pathway for graduate/professional borrowing would be ended for new borrowers — all of which makes program classification decisive for how much federal borrowing a student can access [5] [2] [6].

6. Limitations, unanswered questions, and next steps

Available sources show intense reporting and advocacy but also note the rule is in negotiation: the proposal’s text, the final published regulatory language, and any formal department determination remain subject to the negotiated‑rulemaking process, public comment, and final agency action [10] [3]. Sources do not provide a definitive, final government list of every graduate or doctoral program being reclassified; instead they report examples, committee outcomes, and stakeholder responses [10] [3].

Summary assessment: multiple news outlets, policy groups, and professional organizations agree that many graduate and doctoral programs — especially in nursing and allied health fields — are slated to be excluded from the narrower “professional” category under the DOE’s proposal, with concrete loan‑access consequences; the regulation is still in rulemaking, so the final scope and exact program list will be resolved through published regulatory text and the public comment process [1] [3] [10].

Want to dive deeper?
Which specific degree levels were affected by the Department of Education's 2025 non-professional reclassification?
Did the 2025 reclassification change eligibility for Title IV federal student aid for graduate or doctoral programs?
Which institutions or program types lobbied for exclusion or inclusion of graduate programs in the 2025 rule?
How did the Department of Education define 'non-professional' in the 2025 reclassification and did that definition cover graduate/doctoral degrees?
Are there ongoing legal challenges or appeals related to whether graduate or doctoral programs were included in the 2025 reclassification?