Which professional degrees were removed from the DOE list in 2025–2026 and why?
Executive summary
The Department of Education’s late‑2025 proposal would remove hundreds of programs from its internal “professional degree” list—cutting the list from roughly 2,000 programs to under 600—and specifically excludes widely used healthcare and education credentials such as advanced nursing (MSN, DNP), physician assistant, occupational and physical therapy, audiology, speech‑language pathology, public health (MPH, DrPH), many counseling and social‑work degrees, architecture, and some accounting/education programs [1] [2] [3]. The practical reason the agency gives is applying a narrower, decades‑old regulatory definition tied to loan caps created by the 2025 One Big Beautiful Bill Act (OBBBA): defining which programs qualify for higher graduate borrowing limits and thereby reducing Grad PLUS usage [1] [4] [5].
1. What was removed — a snapshot of the fields
Multiple outlets and professional groups report that the department’s negotiated rulemaking and proposed list omit numerous programs that previously were treated as “professional” for loan‑cap purposes: advanced nursing degrees (MSN, DNP and related nurse practitioner credentials), physician assistant programs, occupational and physical therapy, audiology, speech‑language pathology, counseling and therapy fields, public‑health degrees (MPH, DrPH), education (including teaching master’s degrees), social work (MSW, DSW), architecture, accounting and some business programs, and others [1] [2] [3] [6]. Industry briefings and advocacy groups (architecture, nursing, public health) confirm those exclusions in the current proposal [7] [8] [9].
2. Why the DOE is doing this — regulatory and fiscal framing
The department says it is resurrecting a narrower interpretation of the 1965 regulatory definition of “professional degree” to determine which programs can access the higher borrowing tier created by OBBBA: “professional” programs will be those meeting criteria such as providing a level of professional skill beyond a bachelor’s degree, often culminating in doctoral‑level credentials or requiring licensure [1] [4]. The practical driver is finance: OBBBA ends Grad PLUS loans and caps borrowing for new graduate borrowers beginning July 1, 2026—$50,000 per year (up to $200,000) for programs the DOE deems “professional,” versus $20,500 per year (up to $100,000) for other graduate programs—so which degrees are on the list determines loan access [5] [10].
3. Consequences on students and workforce — contested impacts
Nursing and public‑health groups warn that restricting higher loan limits could make advanced training cost‑prohibitive and worsen workforce shortages; nursing organizations fear fewer entrants into MSN/DNP programs and say the change could weaken a workforce already under strain [9] [10]. Architecture and other licensure‑based professions argue the exclusion will limit the financing available to students despite licensure pathways remaining unchanged, creating a gap between licensure standards and federal loan policy [7] [3].
4. DOE’s counterarguments and legal footing
The department emphasizes that it did not invent a new definition but is applying the existing regulatory text and that the list is an internal, loan‑administration tool, not a value judgment on professions [1] [4]. Department spokespeople and fact sheets stress institutions retain responsibility to show whether programs meet the criteria and the change aligns with historical precedent in the 34 CFR 668.2 regulation [1] [4].
5. Where the debate is headed — timing, rules and open questions
The negotiated rulemaking concluded in November 2025 and the DOE expects a formal Notice of Proposed Rulemaking and public comment window before final rules; the new loan caps take effect July 1, 2026 for new borrowers, but final program lists and determinations could shift during the rulemaking and comment process [1] [7]. Many outlets note the lists published so far are proposals or committee outcomes rather than immutable law; advocacy groups (AACN, ASPPH, AIA) are mobilizing comment and petitions [8] [9] [7].
6. What reporting does and does not show — limitations and disputed claims
Reporting consistently shows nursing and multiple allied‑health, education, architecture and some business degrees on the excluded list in current proposals [9] [3] [6], and that the policy is tied to loan‑cap changes in OBBBA [5]. Available sources do not mention any final, binding federal rule that has permanently and irrevocably delisted these programs beyond the proposed/negotiated‑rule stage; the DOE’s public fact sheets and spokesperson comments indicate the final rules and program lists will be released after public comment and could change [1] [4].
Bottom line: for students and institutions the immediate effect is uncertainty. The DOE frames this as technical alignment with an older regulatory standard tied to new borrowing caps; professional associations call it a financially consequential reclassification that risks constricting pipelines for critical professions unless rulemaking or congressional fixes intervene [1] [9] [7].