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Which degree programs (e.g., JD, MD, PharmD) are reclassified under the DOE's 2026 guidance compared to prior rules?

Checked on November 22, 2025
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Executive summary

Available reporting shows the Department of Education’s 2026 effort to redefine “professional degree” will substantially narrow which programs qualify for higher loan limits — cutting the list from roughly 2,000 programs to under 600 and recognizing a far smaller set of “primary” professional programs (about 11 primary programs plus some doctoral programs) [1] [2]. Multiple outlets and professional groups report that nursing, many advanced health professions (audiology, speech‑language pathology, physician assistant, advanced nursing degrees, occupational therapy, public health, physical therapy, etc.), and other previously eligible programs may be excluded under the proposal, with organizations already mobilizing comments [1] [3] [4] [5] [6].

1. What changed — a big shrink in “professional degree” coverage

Reporting and advocacy summaries characterize the DOE/RISE committee proposal as a major retrenchment: the department proposed a tighter definition that would reduce the number of programs labeled “professional” from about 2,000 to fewer than 600, and the consensus draft limits eligibility for the larger loan cap to roughly 11 primary program types plus certain doctoral programs [1] [2]. That is the central factual frame offered across the materials [1] [2].

2. Which common degrees are explicitly reported as losing status

Multiple sources and professional associations identify health‑related programs that would lose “professional” classification in the draft: nursing programs (including graduate nursing/advanced practice) are widely reported excluded [6] [7] [5], and advocacy groups say audiology and speech‑language pathology would be left out of the proposed definition [3]. Broader lists compiled in social and trade reporting include physician assistant programs, occupational therapy, some advanced nursing degrees, and doctor of physical therapy among those at risk [1] [5].

3. Programs that remain or are singled out as “primary”

Coverage indicates the committee reached consensus to recognize about 11 “primary” professional programs and to include some doctoral programs as professional — though the exact list of the 11 primary fields is not enumerated in the provided snippets. The AAU summary emphasizes that only a small, specific set of programs would be treated as professional for the higher $200,000 loan cap under H.R.1 implementation [2].

4. Professional associations are contesting exclusions

Trade groups and professional schools are already responding. The American Speech‑Language‑Hearing Association (ASHA) is preparing comments arguing audiology and speech‑language pathology should be included [3]. The Association of Schools and Programs of Public Health (ASPPH) expressly warns public health degrees were excluded and is mobilizing advocacy [4]. Nursing organizations and nursing press report the DOE’s move removes nursing from the professional definition and warn of consequences for enrollment and workforce pipelines [6] [7] [5].

5. Practical consequence tied to loan limits and timing

The reporting links the definitional change to the student‑loan architecture in H.R.1 / the One Big Beautiful Bill Act: under the new system, professional students would have higher borrowing limits (e.g., referenced as up to $50,000 annually or a $200,000 aggregate professional cap in different summaries), while elimination of Grad PLUS and other changes take effect July 1, 2026 — making the definition consequential for students starting then [2] [5] [3]. Several pieces note current loan limits remain for students enrolled and continuing in the same program as of June 30, 2026 [3].

6. Where reporting is thin or silent

Available sources do not publish a complete, authoritative list of the 11 “primary” programs or a definitive roster saying “these exact degrees are reclassified and those remain.” They also do not provide the final regulatory text in the snippets provided; the materials are summaries, advocacy responses, and social commentary rather than the formal DOE final rule [2] [1] [3]. Therefore, precise statements like “JD or MD kept/removed” are not found in current reporting and cannot be asserted here without that rule text (not found in current reporting).

7. Competing perspectives and implicit agendas

Advocacy groups (ASHA, ASPPH, nursing organizations, university associations) frame exclusions as threats to workforce capacity and student access; their motive is protecting members’ training pipelines and financial aid access [3] [4] [6]. Conversely, the DOE/RISE committee framing—reported by AAU and NASFAA coverage—presents the change as implementing statutory loan caps and narrowing eligibility to align with H.R.1’s intent on limiting professional loan access [2] [8]. Both sides are acting from clear institutional interests: professional schools seek inclusion; DOE aims to translate statute into a manageable definition.

8. What to watch next

Watch for the DOE’s Dear Colleague letter, formal proposed rule, or final regulatory text (mentioned as the planned vehicle for guidance in NASFAA coverage) and the public comment docket; those documents will list the specific program codes or named degrees that remain or are reclassified [8] [3]. Until those primary source texts are published, reporting provides strong signals about which health and allied‑health programs are at risk but does not supply a definitive, exhaustive list [8] [3].

Want to dive deeper?
Which specific professional degrees are newly classified as undergraduate or graduate under the DOE's 2026 guidance?
How does the 2026 DOE guidance change Title IV eligibility for JD, MD, PharmD, and other professional programs?
What rationale and legal authority did the DOE cite for reclassifying degree programs in the 2026 guidance?
How will reclassification under the 2026 guidance affect federal student aid, loan limits, and Pell eligibility for professional students?
Which institutions or programs are most impacted by the DOE's 2026 reclassification and are any lawsuits or state responses underway?