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What criteria did the Department of Education use in 2025 to distinguish professional vs. non-professional graduate degrees?
Executive summary
The Department of Education’s 2025 proposal and negotiated-rulemaking settled on a narrow, multi-part definition to decide which post‑baccalaureate programs count as “professional” for the loan limits created by the One Big Beautiful Bill Act (OBBBA): programs must signify preparation for beginning practice, require skills beyond a bachelor’s degree, be doctoral in level (with a narrow master’s exception), include at least six years of academic instruction (two post‑baccalaureate), and fall in specified 4‑digit CIP codes tied to a short list of professions — a formula that led many common health, education, and social‑service degrees to be excluded in initial lists and proposals (see [4], [6], [8]1). Coverage is rich on the negotiated rulemaking language and the professions excluded by the department’s roll‑out, but reporting also shows strong pushback from professional associations worried about workforce impacts [1] [2] [3].
1. “What ED proposed” — a multi‑part, categorical test
The department’s working definition requires a program to (a) signify students have the skills to begin practice in a profession, (b) require skill beyond a bachelor’s degree, (c) be a doctoral level program except a Master of Divinity, (d) require at least six years of academic instruction with at least two beyond the bachelor’s, and (e) be in the same four‑digit CIP code as one of a short, enumerated list of professions — in short, a rules‑based, categorical gatekeeping test rather than a broad functional definition [4] [5].
2. Why CIP codes and years of instruction matter — administrative clarity and narrowness
ED’s insistence on four‑digit Classification of Instructional Programs (CIP) codes and a six‑year minimum is intended to create administrable bright lines so eligibility can be applied consistently across institutions; critics say this converts varied professional preparation into a checkbox exercise that excludes legitimate pathways and shorter programs [4] [6]. Using CIP codes can limit inclusion to historically coded programs — which may freeze in place older bureaucratic classifications rather than contemporary practice [7].
3. Who the department explicitly included and excluded — the practical fallout
Under the department’s final or working language, a narrow list of fields (e.g., certain clinical degrees traditionally named in older regs) and any program sharing those 4‑digit CIP codes would qualify; many high‑need fields — nursing (MSN, DNP), social work (MSW, DSW), public health (MPH, DrPH), audiology, speech‑language pathology, counseling, and several allied health programs — were reported as left out of ED’s classification or initial lists, prompting public uproar [8] [2] [3] [9].
4. Department vs. advocates — competing rationales and consequences
ED framed the approach as returning to an older regulatory definition in order to implement statutory loan caps under OBBBA and to limit who qualifies for the higher $50,000 annual / $200,000 lifetime professional‑student borrowing amounts [7] [8]. Professional associations (nursing, public health, social work, audiology/SLP) argue those programs meet the stated criteria — licensure, clinical practice, and post‑baccalaureate rigor — and that exclusion will make crucial graduate education unaffordable and harm workforce pipelines [1] [6] [3] [9].
5. Negotiated rulemaking and internal debate — the shape of compromise
Negotiators on the RISE committee debated alternatives: one competing proposal would have required only that a program meet the practice‑preparation and time‑in‑training tests and include at least 80 credit hours (a broader approach), while ED’s proposal added the doctoral threshold and the CIP‑code gate, which many stakeholders called more restrictive [4] [5]. The record shows the department sought consensus but moved forward with language some committee members opposed [5].
6. What’s clear and what the reporting does not (limits of available sources)
Available reporting clearly documents the specific elements ED used in its working definition and lists of degrees flagged as excluded [4] [7] [8]. Available sources do not mention the department’s internal empirical studies, if any, showing that the CIP‑code/six‑year test better predicts workforce needs, nor do they include final regulatory text implementing every detail after public comment periods (not found in current reporting) [1] [4].
7. Immediate stakes and likely next steps
Because OBBBA ties loan caps to the professional‑degree classification, the department’s definition has immediate financial consequences: most graduate students would face lower annual and aggregate loan limits unless their program meets ED’s test; professional associations are mobilizing public comment and legal scrutiny, and the department expected a Notice of Proposed Rulemaking followed by a 30‑day comment window, so the definition could be contested and possibly revised before final rules [1] [7].
Bottom line: ED’s 2025 criteria convert “professional degree” into a tightly defined, multi‑part regulatory category anchored to doctoral level, multi‑year programs and CIP codes — a clear, administrable standard that critics say is excessively narrow and risks excluding many licensure‑based graduate programs central to public health, nursing, social work, and allied professions [4] [1] [6].