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Which Department of Education memo or rule announced the 2025 reclassification of degrees as non-professional?

Checked on November 21, 2025
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Executive summary

Available reporting shows the Department of Education and its RISE committee have proposed narrowing which graduate programs count as “professional degrees” as part of implementing the One Big Beautiful Bill Act (OBBBA/H.R.1); several outlets report that nursing, public health, and other health and education master’s and doctoral programs would be excluded under that proposal [1] [2] [3]. The change is tied to implementing new loan limits that take effect in 2026 and to draft regulations the department’s RISE committee reached consensus on in November 2025 [4] [1].

1. What exactly announced the 2025 reclassification — a memo, a rule, or a committee draft?

The items in the public record point to consensus draft regulations produced by the Department of Education’s Reimagining and Improving Student Education (RISE) committee as the proximate vehicle for changing which programs count as “professional degree” programs; trade and higher‑education organizations describe the RISE committee’s consensus draft of regulations implementing H.R.1 / OBBBA as the origin of the reclassification [1] [5]. News outlets and advocacy groups frame this as the Department “decid[ing] to change the definition” while reporting that the department or its committee circulated proposed language that would narrow the professional‑degree list [2] [6].

2. What formal document is in the available reporting?

Available sources repeatedly reference a “consensus draft” or “proposed definition” from the RISE committee and expect a Notice of Proposed Rulemaking to follow—i.e., an advance regulatory proposal rather than a final regulation or single one‑line memo [6] [1] [4]. The Association of American Universities and NASFAA both describe committee draft regulations that would recognize only a short list of programs as professional degrees [1] [7]. ASPPH specifically says the Department is “expected to issue a Notice of Proposed Rulemaking in the coming weeks,” indicating a formal rulemaking step was anticipated but not yet published at the time of those reports [6].

3. Which programs are reported to be reclassified?

Multiple news and sector outlets report that nursing (MSN, DNP, advanced practice), public health (MPH, DrPH), social work (MSW), certain allied‑health programs (PA, OT, PT, audiology, SLP), education master’s, and other degrees would lose professional‑degree status under the draft definitions; social posts and trade sites list many of these programs as affected [8] [3] [9] [2]. The AAU and other higher‑education outlets summarize the committee outcome as recognizing roughly 11 primary programs (plus some doctoral programs) as professional degrees, substantially narrowing the set previously treated as such [1].

4. Why does this matter — link to loan limits and timing

The reclassification is explicitly tied to loan eligibility and caps built into OBBBA: the statute and subsequent regulatory work set different annual and aggregate graduate loan limits for students in programs defined as “professional.” Reporting notes that by July 1, 2026, graduate programs generally would face lower annual ($20,500) and aggregate ($100,000) limits unless the program is counted as a professional degree, in which case higher limits ($50,000 annually, $200,000 aggregate) apply—so the classification has direct financial consequences [4]. Sector groups warn that excluding many health and education programs could reduce access to advanced training at a time of workforce shortages [3] [2].

5. Where the record is thin or unclear

No single source in the provided set quotes a specific signed Department of Education “memo” or a published Federal Register final rule that says “effective November X, 2025, these degrees are reclassified.” Instead, available reporting describes committee draft regulations, proposed definitions, and the expectation of a Notice of Proposed Rulemaking [6] [1]. If you are looking for a formal, final rule or a departmental memo with a date and signature, available sources do not mention the text of such a final document or its Federal Register citation.

6. Competing perspectives and implicit agendas

Higher‑education associations and nursing/public‑health organizations portray the change as an administrative narrowing that will harm workforce pipelines and access to graduate education [1] [3] [2]. The Department of Education’s broader agenda—consolidating or moving programs and reshaping federal roles under the Trump administration—is documented elsewhere in press releases and reporting about shifting agency functions, suggesting the reclassification aligns with a wider push to downsize or reframe federal education policy [10] [11] [12]. Advocates for the change argue implementing OBBBA’s loan caps requires a tighter statutory or regulatory definition; critics counter that relying on CIP codes and a short list undermines professions that meet professional‑degree criteria [7] [1].

If you want a definitive document (the Notice of Proposed Rulemaking or a signed departmental memo/final rule), I can continue searching specifically for the department’s published NPRM or Federal Register entry; current reporting shows draft regulations from the RISE committee and expectations of formal rulemaking but does not reproduce a final departmental rule text [6] [1].

Want to dive deeper?
Which specific Dept. of Education memo or Federal Register notice reclassified certain degrees as 'non-professional' in 2025?
What criteria did the Department of Education use in 2025 to determine a degree was 'non-professional'?
How does the 2025 reclassification affect federal financial aid eligibility for graduate and professional programs?
Were there any legal challenges or court decisions filed in response to the 2025 reclassification rule?
Which academic fields or degree titles were most impacted by the 2025 reclassification and how did universities respond?