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Where can I find the full text of the Department of Education's 2025 guidance memo on degree classifications?
Executive summary
You will not find a single publicly posted “2025 guidance memo” text in the materials here; available reporting describes the Department of Education proposing and circulating revised definitions of “professional degree” in issue papers, negotiated‑rulemaking materials, and through planned Dear Colleague guidance rather than a single memo [1] [2]. The RISE committee and groups like NASFAA, CSWE and POLITICO summarize that ED’s proposal narrows which programs count as “professional,” ties eligibility to 4‑digit CIP codes and often to doctoral‑level or six‑year pathways, and that some health and public‑service programs would be excluded under that framework [1] [3] [4].
1. Where the “guidance” language appears — rulemaking papers and a DCL, not one public memo
The Department has released issue papers and proposals as part of the RISE negotiated rulemaking process; NASFAA’s reporting and the issue papers summarize ED’s proposed interim and revised definitions rather than pointing to a single posted “guidance memo” file [1] [2]. Negotiators were told ED intends to provide clarifying language through a Dear Colleague Letter (DCL) and through the Notice of Proposed Rulemaking (NPRM), not necessarily a standalone formal “guidance memo” published separately [2].
2. What the Department’s proposal would do — tighter criteria tied to CIP codes and program length
ED’s new framing would define a professional degree by multiple criteria: it must signify completion of requirements for beginning practice, demand a level of professional skill beyond a bachelor’s degree, generally be at the doctoral level or require at least six academic years of postsecondary coursework (including two post‑baccalaureate), and be in the same four‑digit CIP code as certain listed professions [1] [3]. That framework narrows the universe of programs that would qualify for the highest federal graduate loan caps compared with prior lists or broader two‑digit CIP approaches [3] [5].
3. Who is sounding the alarm — professional associations and advocates
Stakeholders such as the Council on Social Work Education (CSWE) and public‑health groups warn the ED’s proposed definition could exclude social work, public health, and other health professions from “professional degree” status, potentially reducing access to higher loan limits and causing downstream staffing and access issues in critical fields [4] [6]. NASFAA and policy observers document the RISE committee’s discussions and the implications for Parent PLUS and graduate loan legacy policies [7] [2].
4. Contrasting technical approaches debated in negotiations
Committee members debated alternatives: one approach from negotiator Alex Holt would have required fewer hoops (e.g., 80 credit hours and a two‑digit CIP alignment), while ED’s proposal emphasizes doctoral level and four‑digit CIP alignment — a narrower technical standard that the department argues better ties loan policy to entry‑to‑practice credentials [3]. These are not mere semantics; the difference in CIP granularity and credit/degree thresholds materially changes which programs qualify [3] [1].
5. Reported scope and numbers — headline figures, with caveats
Some commentators and social posts state the list of “professional degrees” would fall from roughly 2,000 programs to fewer than 600; those figures appear in advocacy and social posts cited here but are not traced to an ED‑published consolidated list in the materials provided — treat the counts as reported claims rather than an ED‑published inventory [8] [9]. NASFAA and POLITICO emphasize that the department’s examples come from CFR 668.2 plus Clinical Psychology and programs sharing four‑digit CIP codes with listed professions [7] [10].
6. How to get the primary text if you want it
Based on available reporting, the primary ED materials you should seek are: the RISE negotiated‑rulemaking issue papers and meeting materials, ED’s forthcoming Notice of Proposed Rulemaking (NPRM), and any Dear Colleague Letter the department issues — these are the vehicles referenced by ED and negotiators for the formal text and implementation details [1] [2]. The current sources do not publish a single “2025 guidance memo” file or link; available sources do not mention a standalone memo by that exact name [2] [1].
7. What to watch next and why the framing matters
Watch for the NPRM and any DCL for the department’s exact wording and lists; the legal distinction between regulation (CFR language), negotiated‑rulemaking consensus, and agency guidance affects whether the changes withstand legal challenge and how institutions and students will be treated [1] [7]. Stakeholders from higher‑ed groups, health professions, and taxpayer advocates are already contesting the technical choices because the CIP‑and‑degree‑level approach concentrates fiscal consequences on specific program types [4] [3].
Limitations: reporting in these sources summarizes ED proposals, stakeholder reactions and neg‑reg discussions but does not attach a single published “guidance memo” text; if you want the primary document, consult the Department’s RISE neg‑reg materials, any NPRM, and forthcoming Dear Colleague Letter as referenced in NASFAA and neg‑reg reporting [2] [1].