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What definitions has the U.S. Department of Education historically used for professional vs. nonprofessional degrees?
Executive summary
The Department of Education (ED) has recently rewritten who counts as a “professional student” by adopting a narrower regulatory definition that ties professional degrees to specific occupations and existing regulations — a move that would shrink programs labeled professional from roughly 2,000 to under 600 and limit higher loan caps to a short list of fields including pharmacy and dentistry [1] [2]. Negotiated-rulemaking papers and reporting show ED’s working definition centers on degrees that “signify completion of the academic requirements for beginning practice,” demand professional skills beyond a bachelor’s degree, and generally require licensure — and that the agency’s draft would exclude many health and social-service programs such as nursing, social work, and public health that stakeholders argue meet those criteria [3] [4] [5].
1. What ED’s “professional degree” definition has looked like in this rulemaking cycle
ED’s draft and the RISE committee’s negotiated-rulemaking materials define a professional degree as one that demonstrates “completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree,” typically tied to programs that lead to licensure; ED also listed exemplar degrees such as Pharmacy (Pharm.D.) and Dentistry (D.D.S.) in its issue papers [3] [1]. The department’s approach frames professional status around a multi-part rubric rather than leaving the label to institutional self-designation, and it would narrow the set of programs eligible for the higher loan ceilings Congress authorized [1] [2].
2. How this differs from prior or broader understandings
Historically, more programs were treated as “professional” for student-aid purposes; ED’s new implementation would reduce that universe substantially — reporting and advocacy groups say the list of programs previously treated as professional amounted to roughly 2,000 programs and that ED’s draft would cut that to fewer than 600 [2] [6]. Rather than an expansive, CIP-code–guided approach that stakeholders say recognized many health- and service-oriented graduate programs, ED’s definition privileges a shorter, occupation-focused list and explicit licensure pathways [4] [2].
3. Who this change affects and why advocates are alarmed
Universities, professional schools, and associations representing nursing, social work, public health, and allied health professions warn that excluding those programs from “professional” status will remove access to the higher $50,000 annual / $200,000 aggregate loan limits reserved for professional students under the One Big Beautiful Bill Act and its implementation, potentially making graduate training less affordable [1] [4] [7]. Associations such as the Council on Social Work Education and public-health groups explicitly objected that the draft definition excludes their fields despite those programs’ links to licensure and practice [4] [5].
4. ED’s rationale and the rulemaking process
ED officials and the RISE negotiators framed the change as an effort to be “clear and consistent” in implementing Congress’s statutory caps and to limit very large borrowing tied to prior Graduate PLUS rules; ED used the definition in effect on July 4, 2025, as a reference point and developed a multi-part rubric after considering several alternatives during negotiations [1] [3]. The department advanced the definition through negotiated rulemaking and issue papers, and it planned a Notice of Proposed Rulemaking to open public comment [5] [3].
5. Competing perspectives and implicit interests
Higher-education and professional associations argue for broader definitions using CIP codes — which would capture many health and service programs regardless of degree length — calling ED’s narrower approach arbitrary and harmful to workforce pipelines in underserved areas [4] [2]. Conversely, taxpayer- and fiscal-concerned negotiators pushed for tighter limits to curb borrowing and simplify the loan system; ED and some negotiators framed restrictions as necessary to implement H.R.1’s loan caps and to distinguish graduate from narrowly defined professional programs [1] [8]. These positions reflect competing agendas: protecting borrower access and workforce supply versus restraining federal loan exposure and reclassifying program eligibility.
6. What’s unresolved and what to watch next
Negotiated-rulemaking reached consensus language in committee papers, but final regulatory text still requires a formal Notice of Proposed Rulemaking and public comment; stakeholders expect battles over whether to use CIP-code groupings, include specific health fields, or limit the official list to about 11 primary programs plus certain doctorates [3] [2]. Media and advocacy groups report ED’s actions have already led to public outcry and that the department may face legal and congressional pushback as rules proceed [9] [2].
Limitations: available sources are recent reporting and ED neg-reg documents reflecting draft definitions and stakeholder responses; they do not provide a comprehensive statutory history of every prior ED definition before this rulemaking, nor full final regulatory text as of these reports [1] [3].