Keep Factually independent
Whether you agree or disagree with our analysis, these conversations matter for democracy. We don't take money from political groups - even a $5 donation helps us keep it that way.
What are the 11 professional categories used by the U.S. Department of Education and how are they defined?
Executive summary
The Department of Education’s recent negotiated-rulemaking work produced a proposal and rubric to determine which graduate programs count as “professional degrees” — a category that, under the One Big Beautiful Bill Act (OBBBA), qualifies students for higher loan limits (annual $50,000; lifetime $200,000) versus lower limits for other graduate students (annual $20,500; lifetime $100,000) [1] [2]. Reporting and stakeholder statements list roughly 10–11 fields that the Department has proposed or discussed as “professional” (examples repeatedly cited include pharmacy and dentistry) while also showing disagreement about which health and social‑service fields (nursing, public health, social work, etc.) should be included [1] [2] [3].
1. What the Department is trying to do: redraw “professional degree” boundaries
Under OBBBA Congress tied higher graduate loan caps to a category of students in “professional degree” programs; the Department’s RISE committee worked to define that category and released a multi‑part rubric rather than an open list, though it referenced specific fields as examples [1]. The rubric approach attempts to balance a 1965 regulatory definition with new criteria such as program credit hours, CIP codes, and licensure pathways — but negotiators disagreed over breadth and legal risk [4] [5].
2. The headline list: about 10–11 fields were named or implied in reporting
Multiple outlets and fact‑checks recount that the Department’s initial and subsequent proposals identified roughly 10–11 fields as meeting the professional degree test; earlier federal language historically cited examples such as Pharmacy (Pharm.D.) and Dentistry (D.D.S.) [1] [2]. Inside Higher Ed described a list of only 10 degrees in an earlier departmental proposal and noted the Department slightly expanded that list in later presentations, while critics said the list remained narrower than some negotiators wanted [5] [1].
3. Which specific fields appear repeatedly in coverage
Reporting and fact‑checks list education (including teaching master’s), nursing (MSN, DNP), social work (MSW, DSW), public health (MPH, DrPH), physician assistant, occupational therapy, physical therapy, audiology, speech‑language pathology, and some counseling degrees as examples of programs that the Department has moved to exclude or reconsider as “professional” in late‑2025 notices [2] [3]. Note: different pieces emphasize inclusion or exclusion depending on the draft and stage of rulemaking [2] [3].
4. How the Department defines a “professional student/program” in the proposal
The Department’s working definition, as circulated in negotiated rulemaking, ties “professional student” status to a program that (a) requires completion of academic requirements for beginning practice and skill beyond a bachelor’s degree, (b) has a 4‑digit CIP code, and (c) includes a path to professional licensure — language echoed by the Council on Social Work Education’s description of the ED’s initial framework [6]. Negotiators debated whether additional quantitative thresholds (e.g., minimum credit hours, CIP code groupings) should be required [4] [5].
5. Why stakeholders are alarmed — and why others defended the plan
Groups representing public health, nursing, and social work warned that narrowing the professional list would restrict access to higher federal loan caps and could make critical fields less affordable, weakening workforce pipelines; the Association of Schools of Public Health called exclusion of MPH/DrPH “deeply concerning” [3] [6]. The Department and some negotiators argued the proposed criteria create clearer, legally defensible limits than the prior, decades‑old regulatory examples [4] [5].
6. Disagreement and legal/technical framing in nego‑reg sessions
Negotiated rulemaking transcripts and reporting show tension: some negotiators favored a broader, credit‑hour and CIP‑based test (as Holt proposed), while the Department offered a narrower rubric to reduce legal risks; the Department later presented a slightly expanded list compared with its earlier 10‑degree outline but still left many programs in dispute [5] [4].
7. What’s certain — and what’s not found in reporting
It is certain that OBBBA sets different loan caps for “professional degree” students and that the Department’s rulemaking produced a rubric and examples to operationalize that term [1] [2]. Available sources do not mention an authoritative, single public list of exactly “11” categories published by the Department; different reports reference roughly 10–11 fields and describe evolving drafts and disputes over inclusion [5] [2] [1].
8. Bottom line for readers and institutions
The technical criteria — credit hours, alignment with CIP codes, and licensure pathways — will determine eligibility as the Department finalizes rulemaking, but stakeholders should expect further negotiation and possible legal challenge; professional organizations are actively lobbying because inclusion or exclusion has immediate financial consequences for students in healthcare, education, and social services [6] [3] [4].