Which graduate programs did the Department of Education propose to keep as "professional" in its 2025 notice of proposed rulemaking?
Executive summary
The Department of Education’s negotiated-rulemaking output and related agency materials indicate the agency proposed to reserve the higher “professional” loan limits principally for traditionally high-cost, licensure-driven programs—explicitly naming medicine (M.D.), dentistry (D.D.S./D.M.D.), and law (L.L.B./J.D.), and adding clinical psychology to the list—within a package that the Department says ultimately covers eleven programs in its draft proposal [1] [2] [3]. The text pending publication and public comment reflects a narrower definition than many professional and health-care stakeholders expected, but the agency has stressed the proposal is not final and remains subject to change through notice-and-comment [1] [4].
1. What the Department explicitly proposed to keep as “professional”
The Department’s outreach and FAQ materials describe a consensus-driven definition that treats traditional high-cost, licensure-entry fields as “professional degree” programs, explicitly citing Medicine (M.D.), Dentistry (D.D.S./D.M.D.), and Law (L.L.B./J.D.) as examples that would qualify for the higher professional loan limits, and noting the negotiated rulemaking added clinical psychology to the set [1] [3]. Multiple press accounts summarize the Department’s draft as identifying eleven programs that meet the proposed criteria—although public summaries and Department statements name only a subset of those programs in readily available materials [2] [5]. The draft regulatory language the Department circulated during negotiated rulemaking frames a “professional degree” around completion of academic requirements for beginning practice and a level of professional skill beyond a bachelor’s degree, which the Department used to justify the narrower list [2].
2. Which graduate programs were being excluded or left off that list
Reporting and fact-checking of the Department’s draft show that a wide set of post-baccalaureate programs commonly treated as “professional” by educators and employers—examples include nursing (MSN, DNP), social work (MSW, DSW), public health (MPH, DrPH), physician assistant, occupational therapy, physical therapy, audiology, speech-language pathology, many education master’s degrees, and certain counseling degrees—were not included in the Department’s proposed “professional degree” classification for loan-limit purposes [6] [7] [3]. Professional organizations and associations have flagged that exclusion as impactful for student borrowing and workforce pipelines, highlighting a substantial divergence between the Department’s draft regulatory scope and historical practice or sector expectations [8] [3].
3. How the proposal was developed and where it stands in the rulemaking process
The proposed definition emerged from a negotiated rulemaking committee convened by the Department to implement the statute’s new borrowing caps, and the Department has emphasized that the committee’s consensus language must be published for public comment but that the agency has not yet issued a final rule and could modify the language in response to that input [4] [1] [9]. The Department’s own “myth vs. fact” guidance reiterates that the agency has not published a final definition and that public comment will factor into the final regulation [1]. Snopes and other trackers note the Department advanced a draft excluding many programs while also stressing historical precedent and that final rules remained forthcoming [7] [6].
4. Reactions, stakes, and who’s pushing back
Hospitals, health-care associations, and higher-education groups have warned that narrowing the “professional” label will restrict loan access, strain pipelines for clinicians and faculty, and spur widespread advocacy during the comment period—examples include the American Hospital Association urging a broader definition to preserve access for many health professions and AcademyHealth calling the changes catastrophic for certain fields [8] [10]. Accounting and other professional organizations likewise lobbied to preserve their fields’ eligibility after draft language suggested excluding accounting graduate programs from the “professional” bucket [11]. These responses reflect competing agendas: the Department and some fiscal policymakers pressed for tighter statutory fidelity and borrowing caps, while professional groups argue workforce and access harms if their fields lose “professional” status [5] [10].
5. Bottom line and limits of available reporting
Based on the Department’s published FAQ, negotiated-rulemaking materials, and contemporaneous press coverage, the Department proposed keeping core licensure-focused fields such as medicine, dentistry, law, and clinical psychology within the “professional” category and described a total set of eleven programs under that rubric in its draft materials, while excluding many other health and professional fields that historically regarded themselves as professional programs; however, the Department has not yet issued a final rule and the complete, itemized eleven-program list is not exhaustively set out in the sources provided here, so final determinations remain subject to public comment and agency revision [1] [2] [5] [7].