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What criteria did the Department of Education use to determine professional vs. non-professional degrees?
Executive summary
The Department of Education’s recent rulemaking ties the definition of a “professional degree” to several concrete criteria: it must award a professional degree on completion, signify preparation for beginning practice in a profession and require skills beyond a bachelor’s, be at the doctoral level (with a Master of Divinity exception) and meet a minimum of six years of academic instruction (at least two post‑baccalaureate), and generally reside in specified four‑digit CIP codes tied to 11 professions — with some final language expanding included fields to 11 (adding Clinical Psychology) and allowing other programs in the same four‑digit CIP codes to qualify [1] [2]. Coverage is limited and stakeholders (nursing, social work, public health) say those criteria exclude important fields and urge changes [3] [4] [5].
1. What the Department wrote — a checklist for “professional” status
The Department’s negotiated proposal frames a professional degree as a program that (a) assures students have skills to begin practice in a particular profession and requires skill beyond a bachelor’s, (b) is a doctoral‑level degree (except the Master of Divinity), (c) requires at least six years of academic instruction with at least two post‑baccalaureate years, and (d) is included in the same four‑digit CIP code as one of 11 listed professions — a structure intended to determine eligibility for the higher loan caps under OBBBA [1] [2].
2. How CIP codes are being used as a gatekeeper
The Department relies heavily on the NCES Classification of Instructional Programs (CIP) to map which programs count as professional: programs in the same four‑digit CIP code as the enumerated professions are treated as professional degrees, and the Department’s final language broadens inclusion to any program within those same four‑digit codes [2] [6]. This makes a coding decision — not just curriculum or licensure — consequential for federal loan access [6] [1].
3. Which fields explicitly made the cut — and who pushed back
In the Department’s final language, the list includes 10 traditional fields plus Clinical Psychology (bringing the total effectively to 11), and any program sharing a four‑digit CIP code with those fields may qualify [2]. Professional associations representing nursing, social work, and public health criticized the definitions for excluding their fields; the American Nurses Association urged ED to include nursing, CSWE warned social work would be limited under the initial framework, and public health organizations noted exclusionary impacts [3] [4] [5].
4. Stakes: loan caps and practical consequences
Under the One Big Beautiful Bill Act implementation, graduate students generally face annual loan limits of $20,500 and aggregates of $100,000, while students in programs classified as awarding a “professional degree” would have higher limits (annual and aggregate amounts for professional degrees reported as $50,000 and $200,000 in related coverage) — so inclusion or exclusion of a field has direct financial consequences for students pursuing those careers [2].
5. Points of contention among negotiators and interest groups
Negotiators debated whether length or CIP codes should be decisive; one alternative proposal would have required fewer gatekeeping conditions (Alex Holt’s approach would have required first two criteria plus 80 credits and two‑digit CIP codes), while ED’s approach is narrower and more prescriptive, prompting institutions and professional groups to press for broader CIP coverage and recognition of varied program structures [1] [7] [4].
6. Limitations in available reporting and open questions
Reporting in these sources focuses on the negotiated rulemaking text and stakeholder responses; they do not provide the final published regulatory text, exhaustive lists of all 11 included professions, nor implementation guidance on edge cases (e.g., dual‑degree programs, competency‑based tracks). Available sources do not mention how appeals or recoding of CIP assignments will be handled administratively [1] [2] [6].
7. What stakeholders are urging next
Professional bodies and schools are urging ED to broaden which CIP codes qualify (for example, using broader health professions groupings rather than narrow four‑digit codes), to reconsider the strict six‑year/doctoral requirement for fields where master’s pathways lead to licensure, and to consult workforce data to avoid shrinking pipelines in critical services like nursing and social work [4] [3] [5].
Bottom line: the Department’s criteria combine educational level, program length, professional practice intent, and CIP coding to draw a line between “professional” and “non‑professional” graduate degrees — a line that directly affects loan eligibility and that professional groups say is excluding many frontline health and service programs [1] [2] [4] [3].