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Which specific degrees are being reclassified and what federal rules govern their classification?
Executive summary
The Department of Education’s recent negotiated-rulemaking work would narrow which graduate programs qualify as “professional degrees,” preserving explicit examples like M.D., J.D., M.Div., Pharm.D., D.D.S., D.V.M., O.D., D.O., D.P.M., and D.M.D. and tying new loan caps to that definition; the RISE committee reached consensus language to implement H.R. 1/OBBBA and expects formal rule publication in the Federal Register early next year [1] [2]. Advocacy groups warn this will exclude many fields such as public health, nursing, and some graduate programs from higher federal loan limits, a change that could reduce access and affect workforce pipelines [3] [4] [2].
1. What the draft rules actually target: a tighter “professional degree” category
The negotiated-rulemaking (RISE) process set out to translate H.R. 1/OBBBA’s higher loan limits into regulations and focused heavily on defining “professional degree” and distinguishing it from graduate degrees; the bill and committee work anchored the professional-degree definition to the regulatory list in effect on July 4, 2025, which explicitly lists ten fields (medicine, law, pharmacy, dentistry, veterinary, chiropractic, optometry, osteopathy, podiatry, and theology) as examples [1] [5].
2. Which specific degree types are likely to be reclassified or excluded
Several reporting and institutional reactions indicate that degrees long treated as “professional” by schools—most notably MPH and DrPH public‑health degrees and various nursing advanced degrees—are at risk of being excluded from the professional bucket under the new implementation, which would make them ineligible for the higher “professional degree” loan caps [3] [4]. Advocacy groups such as the Association of Schools and Programs of Public Health and nursing commentators have explicitly raised alarm about MPH/DrPH and nursing programs being left out [3] [4].
3. The federal rules and statutory anchor governing classification
The committee used the existing regulatory definition found at 34 CFR 668.2 as of the OBBBA enactment date to determine which programs count as professional degrees; that statutory/regulatory framework is the legal anchor for eligibility for OBBBA’s higher loan limits and was the central reference point in the RISE negotiations [1] [5]. The Department of Education’s negotiated-rulemaking webpage explains the RISE committee’s role in changing Title IV regulations and signals forthcoming Notices of Proposed Rulemaking and public comment [6].
4. How program elements will be judged under the proposed approach
ED negotiators and summaries indicate the department plans to consider program characteristics beyond CIP code alone—factors noted in rulemaking include program length (generally doctoral-level, at least six academic years postsecondary coursework in the committee’s framing) and whether professional licensure is generally required to begin practice; ED suggested that while CIP could flag up to 44 potential programs, licensure and length requirements will reduce the number that actually qualify [5].
5. Practical consequences: loan caps and workforce concerns
If a program is not classified as a “professional degree” under the finalized rules, students in that program would face lower federal graduate loan limits; institutions and associations warn that capped borrowing—coupled with high professional education costs—could reduce access to fields like medicine, dentistry, public health, and nursing and worsen workforce shortages [2] [3]. The Association of American Universities and others explicitly say the proposed limit of $200,000 for professional programs plus a small eligible program list could reduce access to advanced degrees and strain certain professions [2].
6. Competing viewpoints and institutional advocacy
Universities and professional schools argue for broader inclusion—citing workforce needs and cost realities—while the Department and some negotiators are attempting to impose clearer, narrower legal criteria to implement OBBBA’s mechanics; reporting notes the RISE committee reached consensus draft language but the department will still publish proposed rules for public comment early next year, allowing institutions and stakeholders to press their cases [2] [1] [6].
7. What remains uncertain and next steps for stakeholders
Final regulatory language has not yet been published in the Federal Register; stakeholders should watch for the Notice of Proposed Rulemaking and a 30‑day public comment window the Department plans to open, and institutions are already preparing advocacy and comment strategies [3] [6]. Available sources do not mention the precise final list of included or excluded programs because the department has not yet issued the formal proposed rule text [1] [6].
Limitations: this analysis relies solely on the cited reporting and institutional statements about the RISE negotiations and OBBBA implementation; the final regulatory text and any agency responses to public comments will determine exact classifications and legal obligations [1] [6].