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Did the Department of Education update definitions of 'professional' degrees in 2024–2026 guidance?
Executive summary
The Department of Education (ED) proposed and circulated a new, narrower definition of “professional degree” in late 2025 tied to implementing loan limits from the One Big Beautiful Bill Act (OBBBA); the draft would shrink the set of programs classed as professional to roughly a small list of fields and would exclude many health and education graduate programs such as nursing, public health, audiology and speech‑language pathology, which critics say risks lower federal loan caps for affected students [1] [2] [3]. Multiple higher‑education groups, professional associations and news outlets report the change as a proposed reclassification under ED rulemaking, and ED and supporters say the language reflects a long‑standing legal approach — but the debate is ongoing and the rulemaking process is not finished [4] [5] [6].
1. What ED proposed and why it matters: a loan‑cap lever
ED’s draft definition links “professional degree” status to a short list of professions and strict academic criteria — for example, doctoral‑level programs, years of post‑baccalaureate study, and specific CIP codes — and associates that status with higher borrowing limits ($50,000–$200,000 ranges in reporting tied to professional programs versus lower caps for other graduate study) [1] [2]. That connection explains why reclassifying programs matters: programs omitted from ED’s definition would generally face lower federal loan caps under OBBBA’s framework, potentially limiting students’ ability to finance graduate training [2] [7].
2. Who is being excluded, according to reporting
Multiple outlets and professional groups say the draft or committee consensus excludes a wide set of fields often thought of as “professional,” including nursing (MSN, DNP), physician assistant, many allied‑health programs, public health (MPH, DrPH), audiology and speech‑language pathology, education degrees, social work, and others; ASHA and nursing organizations singled out audiology, speech‑language pathology and nursing as specifically excluded in the proposed language [3] [7] [2] [8].
3. Where this language came from: rulemaking and the RISE committee
The definition emerged from ED’s negotiated rulemaking work with the Reimagining and Improving Student Education (RISE) committee, where ED officials presented draft regulatory language and a consensus or near‑consensus narrowed list of professions; negotiators and ED staff emphasized that they were translating statutory loan provisions into regulatory text [5] [6] [1]. Inside Higher Ed and NASFAA coverage notes that the department framed the definition to implement the OBBBA loan limits and to clarify legacy eligibility lines in Title IV regulations [5] [1].
4. Pushback from professional groups and universities
National associations including the American Association of Colleges of Nursing (AACN), the American Nurses Association, ASHA and research universities warned the narrower definition would reduce access to funding for essential health‑care and education pipelines and urged ED to expand or modify the designation in final rules [9] [3] [6] [10]. These organizations argue the change conflicts with licensure‑based understandings of professional programs and threatens workforce supply [9] [10].
5. ED’s public responses and claims of continuity
ED spokespeople and some reporting state that the department presented the draft definition as aligning with long‑standing regulatory approaches and committee consensus rather than a novel, arbitrary cut — and ED contested some media framings as inaccurate, telling Newsweek that certain headlines amounted to “fake news” while also saying the department would put forward the proposed rule [4]. Available sources do not mention a final, enacted regulation taking effect; reporting describes proposals, committee drafts and an upcoming Notice of Proposed Rulemaking [7] [4].
6. Where this stands legally and procedurally
The proposal is part of a formal rulemaking path: ED’s draft language was circulated in committee sessions and reporting indicates an NPRM and public comment period were expected before any final rule takes effect; some cited effective dates tied to OBBBA provisions (e.g., July 1, 2026 for loan limit changes) but the rule is not yet final in the sources provided [7] [2] [1]. That means stakeholders still have avenues to press ED, Congress or courts depending on the final text and timing [7] [6].
7. How to interpret disputes and next steps
Reporting shows a clear dispute: professional associations and universities warn of workforce harm and want broader inclusion, while ED and proponents argue the draft reflects statutory intent and consistent regulatory practice; final outcomes depend on the NPRM, public comments and possible revisions [6] [4] [10]. For readers: watch for ED’s formal Notice of Proposed Rulemaking, the 30‑day comment window cited by ASPPH, and any final rule or litigation updates to know whether and when definitions and loan limits become binding [7] [1].
Limitations: this summary relies only on the publicly reported committee drafts, advocacy statements and news coverage provided; available sources do not mention a finalized, enacted ED regulation changing the “professional degree” definition into law as of the cited reports [7] [1].