Which institutions initiated the reclassification of certain degrees as professional degrees?

1. Who started the reclassification? — Department‑led rulemaking, not Congress alone

The immediate action to redefine “professional degree” came not from a new statute alone but from the U.S. Department of Education’s rulemaking process: a Department‑convened committee negotiated draft regulations to implement student‑loan provisions in H.R. 1 / OBBBA and reached consensus on limiting the set of degrees that count as professional ^{[2] [3]}. Reporting from the Association of Schools and Programs of Public Health (ASPPH) names the Department’s RISE committee as reaching a preliminary consensus on the proposed professional‑degree definition ^[1]. New America and NASFAA reporting also tie the definitional work to the Department’s negotiators translating OBBBA into regulatory text ^{[3] [4]}.

2. What mechanism did they use? — Negotiated rulemaking and an expected NPRM

The Department’s committee produced consensus draft regulatory language that the agency plans to publish in the Federal Register as a Notice of Proposed Rulemaking (NPRM), opening a public comment window; institutions and the public will then be able to respond before rules are finalized ^{[1] [2]}. NASFAA’s coverage explains these discussions were part of ongoing negotiated regulatory sessions on loan limits, “program of study,” legacy provisions and the professional degree definition ^[4].

3. Which institutions and groups are reacting — universities, professional associations, and advocates

Major higher‑education and professional groups are publicly opposing or raising concerns. The Association of American Universities (AAU) warned that the Department‑convened committee’s draft would “limit the number of degree programs that can be considered as ‘professional,’” shrinking access to higher loan limits ^[2]. ASPPH flagged exclusion of public‑health degrees as alarming and urged institutions to submit comments; nursing outlets and unions likewise reported nursing organizations objecting to the Department’s apparent decision to exclude nursing from the professional‑degree category ^{[1] [5] [6]}.

4. How broad is the reclassification expected to be? — Lists and examples circulate, but final scope is pending

Media and social posts circulating lists of programs slated for reclassification — from nursing and public health to education, social work, business and engineering master’s degrees — reflect concern about a sweeping narrowing, but those lists appear to be compilations or reposts rather than final regulatory text ^[7]. AAU and New America emphasize the Department’s draft would limit eligible professional programs, but the exact program list will be clarified in the NPRM that the Department plans to publish ^{[2] [3]}.

5. Stakes and perspectives — loans, workforce, and institutional strategy

Advocates for keeping broad professional‑degree coverage argue that narrower federal definitions will reduce access to higher loan limits, make graduate education less affordable, and could impede workforce pipelines in fields such as medicine, nursing, public health and education ^{[1] [2]}. On the other hand, the Department and supporters of OBBBA are implementing statutory loan‑limit changes enacted by Congress and seeking to codify a definition of “professional degree” that aligns with the law as written; negotiated rulemaking is the standard mechanism to translate those statutory choices into operational rules ^{[3] [4]}.

6. What to watch next — NPRM, public comments, and potential congressional pushback

The Department is expected to publish the draft regulatory language in the Federal Register and open a comment period; AAU and ASPPH explicitly encourage institutions to submit comments during that process ^{[1] [2]}. Reporting also notes institutions may lobby Congress for changes to OBBBA or seek delays in implementation if the new definition threatens program finances and enrollment ^[3]. NASFAA and trade associations are tracking related negotiated rulemaking sessions and planning guidance for institutions ^[4].

Limitations and caveats: available sources document that the Department’s convened committee (the RISE committee or Department‑convened negotiators) produced draft regulatory language and that higher‑education and professional groups are reacting; sources do not provide the final text of the reclassification or a definitive, exhaustive list of programs that will be excluded — that will be made public in the NPRM ^{[1] [2] [3]}.