Keep Factually independent
Whether you agree or disagree with our analysis, these conversations matter for democracy. We don't take money from political groups - even a $5 donation helps us keep it that way.
Which specific degrees were reclassified and why did that change student loan eligibility?
Executive summary
The One Big Beautiful Bill Act (OBBBA) and subsequent Education Department rulemaking reclassified which graduate programs count as “professional” versus “graduate,” using the CFR 668.2 regulatory definition and Classification of Instructional Program (CIP) codes; that reclassification matters because professional programs qualify for much higher annual ($50,000) and lifetime ($200,000) unsubsidized borrowing caps while the Graduate PLUS program was eliminated for new borrowers [1] [2] [3]. Available sources say the Department and negotiators produced a multi-part rubric and relied on existing regulatory text as of July 4, 2025 to determine which fields qualify, but they also note the final list and practical effects remain uncertain and likely narrower in practice [4] [1] [3].
1. Why “professional” vs. “graduate” classification suddenly matters
The statute and negotiated rulemaking attach very different loan limits to “professional” programs: professional students can access substantially larger unsubsidized loan caps (examples cited include $50,000 per year and $200,000 lifetime), whereas ordinary graduate programs face much lower caps and the long-standing Grad PLUS option was eliminated for new borrowers after July 1, 2026 — so which bucket a degree falls into directly changes how much federal borrowing a student can legally do [2] [3] [5].
2. How the Department defined professional degrees in practice
Rather than a freewheeling list, the Department anchored the professional-degree definition to the existing regulatory definition at CFR 668.2 as it stood on July 4, 2025 and supplemented that with a multi-part rubric developed during negotiated rulemaking; that rubric was intended to limit professional status to fields that “generally require licensure” or skills beyond the baccalaureate, and negotiators even proposed interim language during talks [1] [4].
3. CIP codes, examples, and why some programs get excluded
Sources report the Classification of Instructional Program (CIP) code is a key practical determinant: only programs that share certain 4-digit CIP codes with the eleven designated fields or otherwise meet the regulatory criteria are likely to qualify. NASFAA and others flagged that degrees such as Pharmacy (Pharm.D.) and Dentistry (D.D.S.) are examples given in regulatory text, while similarly vocational or clinically focused programs might be excluded if their CIP doesn’t match the designated list [1] [6].
4. Numbers tossed around — but expect fewer students to actually qualify
The Education Department reportedly estimated roughly 44 degree programs could qualify under the consensus definitions, but analysts warn the actual number of students who will realize expanded loan limits will be lower once the rubric’s other requirements and accountability measures are applied [3] [4]. Bipartisan Policy Center noted historically high average borrowing for some professional degrees (medical ~ $185,000; dental > $250,000), which explains why the law targets those fields [7].
5. The practical effects and remaining uncertainties for students
Institutions and financial-aid offices must still interpret how dual degrees, program changes, and legacy eligibility work (for example, phase‑in rules let some current graduate students keep Grad PLUS access for up to three years), and Harvard and others flagged vagueness around phrases like “not limited to” or “generally requires licensure,” meaning borrowers still lack definitive answers until ED issues final lists and guidance [2] [4].
6. Accountability rules change the stakes for program eligibility
Beyond classification, programs now face new accountability metrics comparing post‑completion median earnings with those of working adults with only a high school diploma (for undergrads) or a bachelor’s degree (for graduate programs); programs that fail these outcome tests can lose Direct Loan eligibility — so reclassification interacts with outcome-based cutoffs that could remove borrowing access entirely for some programs [8] [9].
7. Competing perspectives and hidden agendas
Supporters argue the change reins in unlimited Grad PLUS borrowing that often funded high tuition in low‑return programs; critics — including higher‑ed institutions and debt‑access advocates — warn that limiting borrowing will make certain graduate degrees unaffordable, especially for low‑ and middle‑income students, and that the CIP-based approach may arbitrarily exclude programs that function like professional degrees [7] [1] [3]. Negotiators’ use of pre‑existing regulatory text and CIP codes reflects an implicit administrative preference for a rule‑based gate rather than case‑by‑case discretion [1] [4].
8. What reporters and students should watch next
Watch for Education Department publication of final regulatory text, any lists or flowcharts from NASFAA and institutions that map CIP codes to eligibility, and forthcoming guidance on dual degrees, legacy Grad PLUS phase‑in, and appeals — sources are explicit that many technical questions remain unanswered and that litigation is likely, which could further alter outcomes [1] [4] [2].
Limitations: available sources describe the rubric, CIP-code approach, example professions, and headline caps, but they do not publish a definitive, exhaustive list of every reclassified degree in the final rule — that list “is to be determined” by ED and therefore is not found in current reporting [2] [1].