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Which specific institutions and programs were directly affected by the 2025 reclassification of professional degrees?
Executive summary
The Department of Education’s late‑2025 negotiated rulemaking narrowed which graduate programs qualify as “professional degrees,” cutting the list from roughly 2,000 to under 600 and designating only about eleven primary fields plus some doctoral programs as professional [1] [2]. That reclassification explicitly threatens access to the higher loan caps created by OBBBA for students in programs excluded—affecting nursing, public health (MPH/DrPH), social work, physician assistant programs, occupational therapy, audiology and others according to stakeholder groups and reporting [1] [3] [4] [5].
1. What the change actually did: a narrower, code‑based definition
Negotiators on the Department’s RISE committee proposed a new regulatory definition that ties “professional degree” status to a set list of fields (about eleven primary programs) and linked Classification of Instructional Programs (CIP) codes, shrinking the pool of eligible programs from roughly 2,000 to under 600 and thereby limiting which students get the higher annual and aggregate loan caps under OBBBA [1] [2] [6].
2. Specific programs and professions named by advocates and reporting
Multiple organizations and media reporting single out nursing, public health (MPH and DrPH), social work, physician assistant programs, occupational therapy, and audiology as programs that would lose or face uncertainty about “professional degree” status under the Department’s framework [1] [3] [4] [5]. Inside Higher Ed notes the department initially offered an even narrower original list of roughly 10 degrees before modestly expanding it in later sessions [7].
3. Who is sounding the alarm — and why their lists differ
Professional associations—Association of Schools and Programs of Public Health (ASPPH), Council on Social Work Education (CSWE), Association of American Universities (AAU), and nursing advocacy outlets—warn that excluding MPH/DrPH, social work, and nursing will restrict students’ access to larger loan limits and could reduce the supply of trained practitioners [3] [4] [2] [8]. Social media and some outlets also list PAs, advanced nursing degrees, occupational therapy, and audiology among those affected [1]. Differences in lists arise because the Department’s test relies on CIP codes and an enumerated set of fields rather than profession‑by‑profession determinations, so whether a given program is affected can turn on its CIP code or degree title [9] [10].
4. The financial mechanism at stake: loan caps under OBBBA
OBBBA set higher annual and aggregate loan limits for students enrolled in programs classified as professional degrees; under the new regulatory approach, only programs that meet the definition tied to the enumerated fields/CIP codes will be eligible, while other graduate programs would face lower caps and loss of Grad PLUS access—directly lowering borrowing capacity for students in excluded programs [6] [9].
5. How institutions are likely to feel the impact
Research universities and professional schools say the change will “curtail the number of programs” eligible for higher loan limits and could make recruitment, retention, and program viability more difficult for programs suddenly reclassified as non‑professional [2]. ASPPH argues excluding public‑health degrees threatens the workforce pipeline; CSWE describes limits to social work education access; nursing advocates warn of consequences for an already strained nursing workforce [3] [4] [8].
6. Departmental rationale and negotiation context
ED negotiators framed the approach as a “rational compromise” designed to create clear, consistent criteria and to avoid ad hoc judgments about program rigor, relying on existing regulatory language (as of OBBBA’s enactment date) and CIP code groupings; officials indicated they worked with institutions in the negotiated rulemaking process [10] [6] [7].
7. Uncertainties, litigation risk, and next steps
Observers note the final practical outcome remains unsettled: the Department is expected to issue a Notice of Proposed Rulemaking and a 30‑day comment period, and analysts expect litigation and further rule clarification given the high stakes for schools and students [3] [6]. Inside Higher Ed reports the department adjusted its initial list during negotiations, indicating some fluidity [7].
8. How to track whether a specific program you care about is affected
Because the rule hinges on degree titles, CIP codes, and whether a program fits one of the enumerated fields, institutions and students should check the Department’s forthcoming NPRM and compare their program’s 4‑digit CIP code and degree classifications to the list that ED publishes; NASFAA and professional associations are already preparing guidance and flowcharts [9] [10].
Limitations: available sources summarize the proposal and stakeholder reactions but do not produce a complete, authoritative list of every program name or every institution affected; the Department’s formal NPRM and final regulatory text—not yet provided in these sources—will be the definitive source for program eligibility [6] [7].