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What specific degree programs and course components were identified as non-professional?
Executive summary
The Department of Education’s negotiated proposal would narrow the set of graduate programs eligible as “professional” — excluding many public‑health, social‑work, nursing and some other health programs — by tying the label to specific criteria (doctoral level, six years of instruction, same 4‑digit CIP code as 11 named professions, and an explicit path to licensure) [1] [2]. Multiple associations for social work, public health, and nursing warn those exclusions would limit students’ access to higher federal loan caps and say important programs such as the MSW, MPH/DrPH, and post‑baccalaureate nursing degrees were left out of the consensus [2] [3] [4].
1. What the department’s proposal actually lists as “professional” rules
The Education Department’s draft establishes several concrete gates: typically a program must be doctoral level (with a few narrow exceptions), represent at least six years of academic instruction (including at least two post‑baccalaureate), indicate readiness for beginning professional practice and require skill beyond a bachelor’s degree, and fall into the same four‑digit CIP code as one of 11 professions explicitly named in the rule [1]. The proposal also links the definition to licensure pathways [2].
2. Specific programs and components critics say were excluded
Professional‑education groups say that the negotiated consensus excludes whole categories of public‑service and health professions. The Council on Social Work Education reports social work programs (e.g., MSW) were left out of the professional classification in the draft, a change CSWE argues is inconsistent with licensure requirements and program rigor [2]. The Association of Schools and Programs of Public Health says the MPH and DrPH were excluded from the professional category [3]. Nursing organizations — including the American Association of Colleges of Nursing and state nursing leaders — say post‑baccalaureate nursing programs were excluded under the proposal [4] [5]. Commenters frame these as substantive exclusions of MSW, MPH/DrPH, and many nursing graduate degrees [2] [3] [4] [5].
3. Why those programs fall outside the draft’s technical gates
Advocates for the proposal argue the department adopted a narrow, technical framing tied to degree level, total years of instruction and CIP code membership; programs that are primarily master’s‑level (MSW, MPH, many nursing degrees) or don’t align with one of the 11 explicit CIP‑coded professions therefore fail the draft’s bright‑line tests [1]. The Council on Social Work Education points out the rule’s reliance on specific CIP codes and licensure language can systematically exclude programs that nonetheless lead to licensed practice [2].
4. Financial and workforce implications flagged by professional groups
CSWE warns that excluding social work from the “professional” category — compounded by the planned phaseout of Graduate PLUS loans — could make social‑work graduate education less affordable and shrink a workforce for public services [2]. ASPPH says excluding MPH and DrPH programs risks reducing public‑health training capacity at a time of growing threats to population health [3]. Nursing leaders and AACN call the move “alarming,” arguing that cutting loan access will impede nurses’ ability to pursue advanced credentials and harm workforce pipelines [4] [5].
5. Alternate views and the policy logic behind limits
Some analysts and commentators (for example, an AEI piece summarizing the negotiated rulemaking) support narrower definitions to avoid extending high loan caps to lower‑wage graduate programs, arguing that a small set of high‑borrowing programs should receive higher limits; they note many degrees (e.g., Ed.D., MSW) have borrowing patterns that fall within standard limits and so should be excluded from an expanded “professional” loan category [6]. That logic frames the draft as an attempt to target larger loan limits to fields with extreme tuition and predictable lower repayment risk [6].
6. Procedural context and what’s next
The RISE negotiated rulemaking committee reached a preliminary consensus on the draft definition and a compact list of 11 primary professions that would count — but the outcome remains a proposed regulation; affected organizations are mobilizing comment letters and advocacy to reverse exclusions before the rule is finalized [7] [2] [3]. Inside Higher Ed summarizes the criteria that produced these exclusions and notes the rule’s heavy reliance on CIP codes and degree‑length thresholds [1].
Limitations and open questions: available sources do not mention the full list of the 11 named professions, a complete roster of every program classed as non‑professional, or precise numerical enrollment counts for all excluded programs; those details were not published in the materials provided here [7] [1] [2].