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What criteria or definitions did the Education Department apply to label degrees as professional versus non-professional in 2025?
Executive summary
The Department of Education’s 2025 proposal narrows the label “professional degree” using a multi-part test tied to: specific fields listed in longstanding federal regulation, matching 4‑digit CIP codes, doctoral‑level timing/years in some formulations, and a requirement that programs lead to professional licensure or “beginning practice” in a profession — a change that may exclude many nursing, public health, social work and allied‑health programs from higher loan limits (see examples and reactions below) [1] [2] [3] [4]. Coverage is concentrated on rulemaking documents and industry reactions; available sources do not publish a single, simple one‑sentence definition but describe a composite test and its likely consequences [1] [2].
1. What the Department framed as the gatekeepers: fields, CIP codes and licensure
The Department’s working definition builds on an older 1965 regulatory framing but operationalizes it by (a) listing specific fields (e.g., pharmacy, dentistry, clinical psychology among an initial set) and (b) including any other programs that share the same four‑digit Classification of Instructional Programs (CIP) code as those listed — thereby using CIP codes to group which programs “count” as professional [1]. The Department also connects the label to whether the program includes a path to professional licensure or “completion of the academic requirements for beginning practice,” language cited by the Council on Social Work Education as part of ED’s framework [2] [1].
2. Degree level and time‑in‑school as part of the test
One strand of the Department’s formulation emphasizes program level and duration: the New America analysis cites a criterion that a qualifying program is at the doctoral level, requiring about six years of higher education with at least two years post‑baccalaureate — language that would limit the pool of programs that meet the “professional” label [1]. This shows the Department is not treating “professional” as simply mission or licensing but also tying it to educational stage and length [1].
3. Practical consequence: which programs are being excluded in practice
Several reporting outlets and professional groups say the immediate effect of the proposal would be to exclude nursing (MSN, DNP), many public health degrees (MPH, DrPH), social work master’s/doctoral programs (MSW, DSW), audiology and speech‑language pathology, and other allied health programs from the “professional” category — thereby reducing who is eligible for the higher lifetime loan cap reserved for “professional students” [5] [6] [7] [3] [4]. News outlets list fields removed from earlier expectations, and professional associations (e.g., AACN, ASPPH, ASHA, CSWE) have publicly warned about exclusions and consequences [6] [3] [4] [2].
4. Where the rulemaking comes from: statute plus regulatory interpretation
The change ties to the One Big Beautiful Bill Act (OBBBA), enacted July 4, 2025, which created new loan caps and directed the Department to define “professional students” for access to the larger $200,000 lifetime borrowing limit versus lower caps for other graduates [5] [8]. The Department says it is relying on the existing regulatory definition in 34 CFR 668.2 as the baseline but is interpreting it more narrowly and translating it into a multi‑part technical test in rulemaking [5] [1].
5. Pushback and policy stakes: workforce and access arguments
Professional organizations warn that excluding fields such as nursing, public health, social work, audiology and speech pathology will impair workforce pipelines and make graduate education less affordable — a key reason they are urging ED to change the final rule or Congress to act [6] [3] [4] [2]. The American Association of Colleges of Nursing and other groups argue exclusion “disregards decades of progress” and conflicts with the Department’s own linkage of professional programs to licensure and direct practice [6].
6. Limits of available reporting and next steps in the process
Available sources document ED’s proposed criteria, examples of fields affected, and stakeholder reactions, but they do not publish a single finalized, plain‑language paragraph that replaces all ambiguity; the Department expected to issue final rules by spring 2026 and has indicated additional regulatory language will clarify which 4‑digit CIP codes and program characteristics qualify [5] [1]. Litigation, public comment during the Notice of Proposed Rulemaking, and further agency drafting are all likely to change the final outcome [3] [1].
Conclusion: The Department’s 2025 approach is technical and multi‑part — tying the “professional” label to enumerated fields, CIP codes, licensure pathways and in some explanations to doctoral‑level timing — and that formulation has prompted widespread pushback because it appears to exclude many graduate programs previously assumed to be “professional,” with significant loan and workforce implications [1] [2] [6] [3].