How can institutions and employers verify whether a degree title is classified professional or nonprofessional under the 2025–2026 guidance?

1. What the Department of Education is proposing — a narrowed, criteria‑based list

ED’s recent proposal would recognize a short list of primary programs as “professional” (expanded modestly from an initial list of 10 to about 11), and it sets substantive criteria for inclusion: a program must require a level of skill beyond the bachelor’s degree and align with ED’s enumerated program groups and CIP code logic ^{[1] [2]}. The RISE committee agreed to ED’s approach that treats the 10 (plus clinical psychology) program families in 34 C.F.R. 668.2 as the baseline; other programs can qualify only if they share the same 4‑digit Classification of Instructional Programs (CIP) code as those listed or meet ED’s stated skill/degree‑level tests ^{[2] [1]}.

2. Practical steps institutions should take to verify a program’s status

Institutions should cross‑check their program’s 4‑digit CIP code against the set of program families ED treats as professional, review whether the degree requires skills beyond the bachelor’s level per ED’s criteria, and await ED’s promised Dear Colleague letter for procedural guidance ^{[2] [4]}. NASFAA reporting notes the RISE committee’s reliance on CIP‑code alignment to extend “professional” status to programs not explicitly named; Cornell’s CIP guidance underscores that institutions may need to justify program–CIP fit with curriculum and credit breakdowns ^{[2] [5]}.

3. Employers verifying degree titles for hiring or credentialing

Employers should ask applicants for degree title and the awarding institution’s program CIP code or program description and compare that information to ED’s list and criteria once the final rule or DCL is issued; current reporting indicates ED will publish guidance to institutions that can inform employer checks ^{[4] [1]}. Public reporting and advocacy materials already circulating (including lists on social media and news outlets) identify specific fields that may lose “professional” status, but those lists are second‑hand and reflect the policy debate rather than final regulatory text ^{[6] [7]}.

4. Areas of ambiguity and timing risks for 2025–26

RISE committee members flagged timing problems because institutions are already enrolling students for 2026–27 and need clearer rules sooner; ED said it will use a Dear Colleague letter rather than the slower regulatory route, which may speed implementation but leaves institutions and employers in a transitional limbo until that guidance appears ^[4]. Reporting shows disagreement about which fields will be included; advocacy groups such as the Association of American Universities argue the draft will sharply restrict the number of programs eligible for higher loan caps, indicating ongoing dispute over the final scope ^[3].

5. Stakes and competing perspectives

Advocates for a narrow definition — as reflected in ED’s proposal and the negotiated RISE language — say clearer, objective criteria (skill level, CIP alignment) constrain arbitrary expansion of “professional” status ^{[1] [2]}. Opponents, including university groups, warn that restricting “professional” designations will reduce access to graduate education in fields like nursing, social work, public health and others and could hamper students who rely on higher loan caps ^{[3] [2]}. News outlets and social posts circulate lists of programs purportedly reclassified; those lists reflect reactions and concern but are not the formal ED rule ^{[7] [6]}.

6. What verification will look like in practice once ED issues final guidance

Once ED issues the DCL or final rule, verification is likely to follow a simple checklist: ^[8] is the program’s 4‑digit CIP code one ED treats as professional or identical to an enumerated professional CIP?; ^[9] does the credential demonstrably require skills beyond a bachelor’s degree per ED’s criteria?; and ^[10] does ED specifically list the program family as eligible for the higher loan cap? NASFAA and institutional compliance offices will be primary interpreters of that guidance for employers and registrars ^{[2] [1] [4]}. Available sources do not yet provide a sample verification form or step‑by‑step employer workflow beyond these elements (not found in current reporting).

Conclusion: For now, institutions and employers should prepare by mapping program CIP codes, gathering curricular documentation that shows degree‑level skills, and watching for ED’s Dear Colleague letter and final rule text — those documents will supply the definitive checklist for classifying a degree as professional in 2025–2026 ^{[2] [4] [1]}.