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A list of the degrees the Department of Education will reclassify and no longer consider professional degrees:
Executive summary
The Department of Education’s negotiated-rulemaking (RISE) draft sharply narrows which graduate programs count as “professional degrees,” recognizing roughly 11 primary professions and a subset of doctoral programs — a change that would cut the universe of programs eligible for the higher OBBBA loan caps from thousands to a few hundred according to advocates [1] [2]. Multiple higher-education and professional groups warn the proposal would exclude nursing advanced degrees, public health (MPH/DrPH), social work, physician assistants and other healthcare and service professions from “professional” status, reducing students’ access to higher federal loan limits [3] [4] [5].
1. What the Department drafted: a tight, mostly doctoral list
The draft definition the Department presented to the RISE committee would limit “professional degree” status to a short, explicit list of primary programs (medicine, law, dentistry, pharmacy, theology, etc.) and some doctoral-level programs that meet criteria tied to degree level, years of instruction, licensure, and 4-digit CIP codes — effectively requiring doctoral-level credentials (with one narrow Master’s exception) and inclusion in certain CIP codes to qualify [6] [7] [8].
2. The scale of the change and who loses “professional” status
Advocacy groups say the rule reduces programs called professional from roughly 2,000 to under 600, and that many health and service professions — advanced nursing (MSN, DNP), physician assistant programs, occupational therapy, audiology, clinical psychology, social work, and public health (MPH/DrPH) — could be excluded from the higher loan buckets under the draft [2] [9] [5] [3] [4]. The Association of American Universities reports negotiators agreed to recognize only 11 primary programs plus some doctorates as professional, which would curtail the set of programs eligible for the larger loan caps Congress established in H.R.1/OBBBA [1].
3. Why the distinction matters: loan caps and student access
OBBBA creates two graduate borrowing tiers: higher caps for students in professional programs (e.g., $50,000 annual, $200,000 aggregate under the enacted timeline referenced in reporting) versus lower caps for other graduate students (e.g., $20,500 annual, $100,000 aggregate) — so whether a degree is labeled “professional” has direct financial consequences for students’ federal borrowing options [10] [11]. NewAmerica and Forbes summarize that these loan limits take effect in mid-2026 and that the department’s narrower definition could force students into private loans or deter enrollment in excluded but costly programs [10] [11].
4. Arguments from affected professions and higher-ed groups
Nursing leaders (AACN) and the Council on Social Work Education explicitly criticized the draft for excluding their fields and warned that eliminating professional status and Grad PLUS availability would make graduate education less attainable in critical service professions [5] [4]. Public health organizations expressed “deep concern” that excluding MPH/DrPH would reduce access to federal loan limits and weaken workforce pipelines [3]. The Association of American Universities framed the rule as a limitation on the number of programs that can be considered professional, raising questions about workforce and equity impacts [1].
5. Department’s rationale and negotiating dynamics
ED’s proposal ties professional status to clear, administrable criteria — degree level, instruction length, CIP alignment and licensure pathways — which the department argues creates consistency rather than ad hoc listings; negotiators reportedly debated alternatives that would have been more inclusive [6] [12]. Reporting indicates ED pressed for a limited list and warned it could reverse concessions if consensus failed, underscoring a political negotiating posture during neg reg [11].
6. Disagreements, uncertainties, and likely next steps
There’s clear disagreement between ED’s narrower, administrable definition and multiple professional groups that say the rule ignores longstanding precedents and practical workforce needs [6] [3] [4]. Sources note the committee reached a consensus draft but the rulemaking process continues: the department can publish a Notice of Proposed Rulemaking and stakeholders will have a public-comment window — so the final regulatory text and legal challenges remain uncertain [7] [10].
7. What reporting does not (yet) say
Available sources do not mention the final text of an NPRM, any court filings or litigation outcomes, nor the department’s full list of the “11” professions in a single, definitive place within these excerpts — readers should consult the forthcoming NPRM or ED press releases for the exact enumerated degrees and the formal regulatory language (not found in current reporting) [8] [7].
Bottom line: the Department’s draft sharply narrows which degrees qualify for the higher OBBBA loan caps, and multiple professional and academic organizations warn the change would exclude many health and service graduate programs — with major implications for student financing and workforce pipelines — while ED maintains the narrowed definition creates consistent, enforceable rules [1] [5] [6].