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Which graduate programs are classified as professional degrees by DOE (e.g., JD, MD, MBA, MSW)?
Executive summary
The Department of Education (ED) has proposed a tighter definition of “professional degree” that would cut the number of programs so categorized—from roughly 2,000 to fewer than 600 in some accounts—and in practice would strip many health and service graduate programs (nursing, social work, public health, PA, OT, audiology, etc.) of higher federal loan eligibility and Grad PLUS protections [1] [2]. Multiple professional associations (nursing, social work, public health, academic research groups) say the ED proposal would limit student loan access for critical workforce programs and are mobilizing comments and objections [3] [4] [5] [2].
1. What the Department of Education is proposing — a dramatic narrowing
The RISE committee convened by ED has drafted a new definition of “professional degree programs” as part of implementing the One Big Beautiful Bill Act (OBBBA/H.R.1), and reporting from advocacy groups and commentators says the draft would reduce the list of eligible programs substantially — from roughly 2,000 down to fewer than 600 — which would exclude many health and service-oriented graduate programs from “professional” status and related loan limits and Grad PLUS eligibility [1] [2].
2. Which programs are explicitly threatened in reporting
Coverage and advocacy statements cite a set of clinical and service professions likely to be affected if the narrower definition stands: advanced nursing degrees (NP, DNP, nurse anesthetist), physician assistant programs, occupational therapy, audiology, social work, and public health degrees (MPH, DrPH) are repeatedly named as examples of programs that could lose professional status under the ED definition [1] [4] [5] [6].
3. Why classification matters — loan limits, Grad PLUS and RAP mechanics
Under OBBBA and the related regulatory work, “professional” status affects eligibility for the higher loan limits and the phaseout or restructuring of Grad PLUS. The new rules would cap graduate borrowing differently and create a Repayment Assistance Plan (RAP) tied to “professional” status; if a program loses that label, students would face lower borrowing caps and fewer federal loan options, a point emphasized by nursing and university groups [6] [2].
4. Reactions from sector associations — alarm and advocacy
Major professional organizations have publicly criticized the ED approach: the American Association of Colleges of Nursing (AACN) and the American Nurses Association framed the change as a threat to nursing pipelines and patient care [3] [7], the Council on Social Work Education warned about limits on social work education access [4], and the Association of Schools and Programs of Public Health urged inclusion of MPH/DrPH programs and planned public comment [5]. The Association of American Universities (AAU) warned broadly that the proposal limits access and could harm workforce development [2].
5. ED process and timeline — negotiated rulemaking, NPRM expected
Reporting and association posts describe the matter as part of negotiated rulemaking by ED’s RISE committee; ED is expected to issue a Notice of Proposed Rulemaking (NPRM) opening a public comment period, and advocates are preparing to submit data and comment to alter or block exclusions [5] [8]. NASFAA coverage shows ED officials unveiled the new definition during RISE sessions and that committee members raised legal and programmatic concerns [8].
6. Points of dispute and missing specifics
There is disagreement about the scope and rationale: ED staff argue it is creating “clear and consistent criteria,” while universities and professional groups say the criteria unjustifiably exclude lengthy, rigorous programs and ignore workforce needs [4] [2]. Precise lists of which CIP codes or program titles will remain “professional” versus excluded are not uniformly published in these sources; available sources do not provide the ED’s final codified list or the exact regulatory text [8] [1].
7. Where to watch next — advocacy, comment period, and legal risk
The immediate next steps are the NPRM and the 30-day public comment window flagged by public health advocates; stakeholders (schools, associations, students) will use that period to press ED to revise the definition or restore legacy provisions for programs currently eligible under HEAL/previous rules. Observers also flag potential legal challenges if ED’s definition leaves ambiguous “program of study” boundaries or runs counter to statutory intent [5] [8] [2].
Limitations: this analysis draws only on the provided reporting and association statements; the actual ED notice of proposed rulemaking and full regulatory text are not included among the supplied sources, so exact statutory language, the final program list, and ED’s internal justification are not found in current reporting [1] [8].