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Which degrees did the U.S. Department of Education reclassify as non-professional in 2025 and what criteria were used?
Executive summary
The Department of Education’s 2025 negotiated rulemaking (the RISE committee) sharply narrowed which graduate programs count as “professional degrees,” excluding several health and social-service fields—most notably nursing—from that category; the committee agreed to recognize roughly 11 primary program areas and some doctorates as “professional” under the new framework [1] [2]. The department’s proposed criteria tie “professional” status to program characteristics such as multi‑year post‑baccalaureate coursework (generally at the doctoral level or at least two years post‑bac), a clear path to professional licensure, and a discrete CIP code —changes that critics say will remove access to higher federal loan limits for excluded programs [2] [3] [1].
1. What the department reclassified — the headlines
Negotiated rulemaking in November 2025 produced a much tighter definition of “professional degree,” shrinking the universe of programs that qualify for higher loan caps to about 11 primary program types plus some doctoral programs; major fields that previously enjoyed “professional” status have been left out of that list, with nursing singled out in multiple coverage pieces as being excluded under the draft framework [1] [4] [5].
2. The rulemaking vehicle and legal context
These changes emerged from the Department’s Reimagining and Improving Student Education (RISE) committee as part of implementing H.R. 1 / the One Big Beautiful Bill Act (OBBBA). The department used negotiated rulemaking to define who counts as a “professional student” for new loan limits in the statute, and officials relied on an earlier 2023 regulatory baseline while carving out the new criteria [6]" target="blank" rel="noopener noreferrer">[6] [1].
3. The specific criteria the department set out
Under the draft definition unveiled at the RISE discussions, a “professional student” is in a program that: awards a professional degree on completion; generally involves at least six years of postsecondary education overall (or at least two years of post‑baccalaureate coursework); prepares students for a licensed occupation; and maps to a 4‑digit Classification of Instructional Programs (CIP) code —criteria intended to limit the set of qualifying programs [2] [3].
4. Who loses federal borrowing access if excluded
Observers and affected associations warn that the criteria would exclude advanced nursing degrees (MSN, DNP), social work master’s programs (MSW), some public health degrees (MPH, DrPH), physician associate/assistant and other allied‑health programs in some cases, and other applied graduate programs —meaning students in those programs would not be eligible for the higher “professional” loan limits established by OBBBA [4] [3] [5] [7].
5. Why the department and some policy analysts defend the change
Proponents argue the tighter definition prevents an overly broad set of graduate programs from accessing large additional federal borrowing and helps target higher loan caps to programs that clearly require extended, post‑baccalaureate preparation and licensure —AEI’s take praised consensus on limiting professional student loan limits and emphasized program length and licensure as sensible cutoffs [8] [2].
6. Pushback from professional organizations and potential consequences
Major associations representing nursing and social work (AACN, ANA, CSWE) have publicly objected, saying the proposed definition contradicts the professions’ licensure‑and‑practice realities and could reduce advanced‑degree enrollment at a time of workforce shortages; they warn exclusion would make graduate education less affordable and could worsen health and social‑service staffing gaps [9] [10] [3].
7. What’s still undecided or missing from coverage
Available sources do not mention a finalized federal rule or an effective date; the reporting describes negotiated rulemaking consensus and draft proposals, and the department is expected to publish a Notice of Proposed Rulemaking and open a public comment period before any binding regulation [11]" target="blank" rel="noopener noreferrer">[11] s13" target="blank" rel="noopener noreferrer">[6]" target="blank" rel="noopener noreferrer">[6]. Sources also vary on exact program lists and counts: some say “about 11” primary programs qualify while social posts and industry groups cite reductions from thousands of program labels to “less than 600,” illustrating uncertainty and competing tallies [1] [12].
8. How to follow developments and what stakeholders will watch next
Stakeholders will watch for the formal Notice of Proposed Rulemaking, the open comment period the department must run, and any changes between negotiated‑rule draft language and the department’s published rule; professional associations pledge to press for inclusion of their fields during that process, and higher‑education groups warn Congress‑level fights could follow if loan access is restricted [11]" target="blank" rel="noopener noreferrer">[11] [1] [10].
Bottom line: the department’s negotiated rulemaking narrowed “professional degree” eligibility by applying length, licensure, and CIP‑code requirements, and that draft framework excludes nursing and several other applied degrees from higher loan limits —a change that has sparked major pushback and remains not yet finalized in a published rule [2] [4] [9].