Which criteria did the Department of Education use to designate degrees as non-professional in 2025?
Executive summary
The Department of Education’s 2025 proposal narrows “professional degree” status to a small list of programs and sets criteria focused on advanced post-baccalaureate credentials, licensure and a higher “level of professional skill” than a bachelor’s degree; the agency identified 11 fields as clearly professional and said roughly 44 other fields could qualify if they meet those criteria [1] [2]. Critics and professional groups say many historically professional fields — nursing, education, public health, social work, architecture and others — would be excluded unless they meet the department’s narrower tests, with potentially large effects on borrowing limits under the One Big Beautiful Bill [3] [4] [1].
1. What the Department of Education says the criteria are
The DOE’s published language emphasizes three linked elements: the program generally must confer a level of professional skill beyond what a bachelor’s provides, typically be a doctoral-level credential in practice, and require professional licensure to begin practice; the agency used those elements to list 11 fields that automatically meet the standard while saying roughly 44 other fields could qualify if they satisfy the tests [2] [1].
2. How the DOE applied the definition in practice
In the negotiated rulemaking and subsequent communications the Department limited automatic “professional” status to medicine, pharmacy, dentistry, optometry, law, veterinary medicine, osteopathy, podiatry, chiropractic, theology and clinical psychology — a much narrower set than many academic and professional stakeholders expected [1]. The agency framed the approach as reviving a 1965 regulatory definition but using a stricter interpretation focused on doctoral-level training and licensure [2] [5].
3. Immediate policy consequence: borrowing limits and who gains or loses
Under the One Big Beautiful Bill the reclassification matters because “professional students” can borrow up to $50,000 per year (with a $200,000 lifetime cap) while non‑professional graduate students face substantially lower caps; excluding fields traditionally treated as professional thus reduces federal borrowing available to students in those programs [6] [1] [7].
4. Where advocates and unions say the DOE’s tests fall short
Nursing organizations (AACN, ANA), public‑health schools and other professional groups argue nursing, public health, education, social work and allied‑health degrees meet the DOE’s own stated features—rigorous advanced preparation and licensure—yet were still excluded in the department’s narrower list; those groups say the practical workforce implications and precedent in higher‑education classification were ignored [3] [4] [8].
5. The department’s stated flexibility and institutional responsibility
The DOE and some reporting emphasize institutions retain responsibility to demonstrate that a program meets the professional‑degree requirements; the agency also noted that at least 44 other fields could qualify if they show a level of professional skill beyond the bachelor’s and licensure requirements — a pathway for institutions to seek recognition even as the baseline list shrinks [2].
6. Disagreement over precedent and interpretation
Some outlets and fact‑checks say the department claims it is applying a long‑standing federal definition but critics call the interpretation unusually narrow compared with historical practice; fact‑checking coverage highlights that while the regulatory text dates to 1965, the department’s modern application is more restrictive [6] [2].
7. Broader implications and contested motives
Analysts warn the change could reduce enrollment in certain professions and worsen workforce shortages by making costly graduate training less affordable; opponents frame the move as politically driven re‑prioritization of which professions merit federal support, while the department frames it as technical clarification to align loan policy with the statute [7] [1] [3].
8. Limits of current reporting and where answers remain incomplete
Available sources document the DOE’s criteria as centered on licensure, doctoral‑level norms and “skill beyond a bachelor’s” and list fields the agency treats as professional or not, but available sources do not mention every procedural detail for how institutions will petition for professional status or the specific evidentiary standard the agency will enforce in individual cases [2] [1].
Bottom line: the 2025 designation rests on a tighter reading of “professional degree” — doctoral orientation, licensure and demonstrable skill beyond the bachelor’s — applied to a short list of fields while leaving many historically professional programs to seek case‑by‑case recognition; professional groups dispute that approach and warn of real financial and workforce consequences [2] [3] [4].