What criteria and regulatory changes did the Department of Education use to determine professional vs. non-professional degree status in 2025?

1. What ED wrote into the new “professional degree” test

ED’s regulatory text—developed during RISE negotiated rulemaking—explicitly lists multiple objective criteria: the program must signify completion of academic requirements for beginning practice and a level of professional skill beyond a bachelor’s; is generally at the doctoral level and “requires at least six academic years of postsecondary education coursework for completion, including at least two years of post‑baccalaureate level coursework”; generally requires professional licensure to begin practice; and must have a 4‑digit CIP code as assigned by the institution or determined by the Secretary ^{[1] [5]}. Negotiators also agreed to a short list of about 11 primary fields (plus clinical psychology) that serve as anchor CIP groups; other programs qualify only if they share a 4‑digit CIP with those fields ^[2].

2. How the CIP code rule functions as a gatekeeper

ED’s approach uses the Classification of Instructional Programs (CIP)—specifically 4‑digit groupings—as a mechanical way to scale which programs count as “professional.” Under the final language, a program that does not share a 4‑digit CIP with one of the designated professional fields can be excluded even if it meets licensure, doctoral‑level, and skill requirements, a point critics say makes CIP the decisive filter ^{[2] [5]}. Stakeholders warn this produces anomalies: programs that are functionally professional can lose status because of coding differences rather than substance ^[5].

3. Which programs lost status and why critics object

Multiple health and public‑service programs—reported examples include nursing, public health (MPH/DrPH), physician assistant programs, advanced nursing degrees, occupational therapy, and audiology—face reclassification or exclusion because they don’t meet the six‑year/doctoral or CIP alignment tests as ED framed them ^{[6] [1] [2]}. Nursing organizations (e.g., ANA, AACN) and public‑health advocates object that these professions clearly meet licensure, rigorous training, and workforce necessity but would be cut off from higher loan limits, a change they say jeopardizes workforce pipelines ^{[7] [4] [8]}.

4. Why ED tied this to student‑loan policy (the practical effect)

The regulatory redefinition was negotiated to implement provisions of the One Big Beautiful Bill Act (OBBBA/H.R.1), which phases out Grad PLUS and establishes new annual and aggregate loan limits that differ for “professional” versus other graduate students—e.g., professional students would have access to much higher loan limits ^[2]. By narrowing which programs count as professional, ED effectively limits who can access the larger $50,000 annual / $200,000 aggregate ceilings that the bill contemplates for professional students, tightening graduate borrowing for many fields ^{[2] [1]}.

5. Process, contention, and next steps

The definition emerged from RISE negotiated rulemaking sessions where ED staff and stakeholders reached consensus on draft regulations; NASFAA and others documented the rollout and the department’s attempt to use consistent language across HEA and OBBBA contexts ^{[9] [5]}. The department’s final language was presented as implementing the statute’s “professional” concept as of July 4, 2025, but multiple higher‑education groups and professional associations warned the cut from roughly 2,000 to well under 1,000 qualifying programs will have major downstream effects and invited legal and policy challenges ^{[2] [10]}.

6. Competing framings: consistency vs. access

ED and allies argue the CIP‑linked, doctoral‑and‑duration criteria create a clear, repeatable standard that avoids arbitrary distinctions based solely on program length or local titles ^{[3] [9]}. Opponents counter that the mechanical rule undervalues professional realities—licensure pathways and workforce need—and that using CIP codes can produce perverse exclusions, especially in nursing and public health where program structures and codes vary ^{[5] [4]}. These dueling frames—administrative clarity versus equitable workforce access—define the debate in current reporting ^{[3] [10]}.

Limitations: available sources document ED’s proposed/final negotiated language and stakeholder reactions but do not include the full, verbatim final regulation text or ED’s internal legal memos in these snippets; for the exact statutory citations or full regulatory language, current reporting does not provide the complete verbatim rule ^{[1] [2]}.