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What criteria did the Department of Education use to determine 'non-professional' versus 'professional' graduate degrees in 2025?
Executive summary
The Department of Education’s 2025 proposal to distinguish “professional” from “non‑professional” graduate degrees hinges on a set of specific criteria: the program must signify readiness for professional practice and a skill level beyond a bachelor’s, generally be at the doctoral level and require at least six years of postsecondary study (including two post‑baccalaureate years), often require licensure to practice, and be reported under a four‑digit CIP code tied to enumerated professions — a package that would limit eligibility to a narrow set of programs and affect loan caps and repayment rules [1] [2] [3]. Coverage is substantial across advocacy and higher‑education outlets but critics warn the draft definition would exclude many health and social‑service graduate programs from higher federal loan limits [4] [5] [2].
1. The rule’s core tests: what makes a degree “professional” under ED’s proposal
The department’s draft definition requires multiple conditions to be met: the degree must both signify completion of academic requirements to begin practice in a profession and represent a level of skill beyond a bachelor’s; it is “generally” a doctoral‑level credential that requires at least six years of postsecondary instruction (including at least two years post‑baccalaureate); it generally requires professional licensure to begin practice; and the program must fall under a four‑digit CIP code associated with one of a limited list of professions [1] [2] [6].
2. How the criteria work together — and why that narrows the field
The department tied the “professional” label to both educational length/level and occupational coding. Requiring doctoral‑level status plus a six‑year minimum of coursework and a matching four‑digit CIP reduces the number of programs that qualify sharply: negotiators estimated eligible programs would fall from thousands to roughly several hundred, with many clinical and allied health fields potentially excluded [2] [3] [1].
3. Practical consequence: who loses access to larger loan limits
Under the One Big Beautiful Bill Act (OBBBA) implementation, programs labeled “professional” are eligible for higher lifetime borrowing caps; the ED’s proposal would therefore deny those larger caps to students in excluded programs. Groups representing nursing, social work, and public health warn the change would limit graduate students’ access to federal financing and could create workforce impacts for health and human services [3] [4] [7] [5].
4. Points of internal debate and legal caution inside rulemaking
Committee negotiators flagged legal and definitional concerns. Some negotiators praised the new definition as addressing earlier legal risks about what constitutes a “program of study,” while others pressed ED for clarity and raised questions about how many programs would actually meet the full criteria [6]. That pushback helped shape the more prescriptive, multi‑part definition now circulating [6] [1].
5. Alternative drafts and competing proposals: less‑restrictive options that were discussed
A competing approach (associated with negotiator Holt) would have leaned mainly on meeting competency and duration tests (e.g., two post‑baccalaureate years) and required fewer prescriptive thresholds such as doctoral‑level status or tight CIP‑code alignment; Holt’s version would have been more inclusive, and some committee members supported it — but ED’s draft is the more restrictive outcome of the negotiation [1] [6].
6. Numbers and timing: caps, guardrails, and the rulemaking calendar
OBBBA eliminated the Graduate PLUS program for future borrowers and set new post‑graduation borrowing limits; the department and the Reimagining and Improving Student Education (RISE) committee reached consensus on regulatory language in November and plan to publish a Notice of Proposed Rulemaking for public comment soon, meaning institutions and stakeholders will have an opportunity to weigh in before final rules are issued [8] [3] [2].
7. What proponents and critics emphasize — competing perspectives
Proponents argue the definition creates “clear and consistent” criteria to target federal loan generosity to programs that directly prepare practitioners (NASFAA reporting on ED’s intent) while critics — including professional associations for social work, nursing, and public health — say the definition arbitrarily discriminates against many clinical and service professions by focusing on degree title, length, and CIP coding rather than workforce need or program rigor [6] [4] [7] [5].
8. Limits of current reporting and what isn’t said
Available sources document the criteria ED proposed and stakeholder reactions, but do not publish the final regulatory text or a complete list of the 11 primary professions ED intends to recognize, nor do they provide ED’s full legal rationale or an exhaustive program‑by‑program eligibility list; those details are expected in the NPRM and institutional guidance to follow [1] [3] [2].
Bottom line: the Department of Education’s 2025 approach defines “professional” graduate degrees with a layered, prescriptive test (doctoral/length/licensure/CIP) that shrinks the set of programs eligible for higher loan caps; alternative, more inclusive definitions were debated during rulemaking and stakeholders will have a window to comment once the NPRM is published [1] [6] [8].