Which programs retained professional status and what criteria distinguished them?

1. What the Department proposed — a narrower, code‑based test

The Department of Education’s draft ties “professional” designation to discrete classification rules: to qualify for the highest federal loan caps, a degree program must meet several criteria including being included in the same four‑digit CIP code as one of 11 professions explicitly mentioned in the proposed regulation ^[1]. Inside Higher Ed frames this as a more restrictive, measureable test than an alternative plan circulating on the committee that would have required only the first two criteria plus inclusion in the same two‑digit CIP code ^[1].

2. How that differs from the Holt committee suggestion

Committee member Holt’s plan, which reportedly had near‑unanimous committee support prior to the department’s pushback, would have required fewer thresholds: the first two criteria plus a program length floor of at least 80 credit hours and alignment at the broader two‑digit CIP level rather than the narrower four‑digit level ^[1]. That distinction matters because two‑digit CIP groupings bundle many subfields together; four‑digit CIP alignment isolates programs more precisely and can exclude closely related but differently coded majors ^[1].

3. What those criteria mean in practice — precision and exclusion

A four‑digit CIP requirement is a precision tool: it limits the label to programs coded identically to the listed professions, reducing ambiguity and likely shrinking the set of programs eligible for the top loan caps ^[1]. Inside Higher Ed’s reporting implies that the department’s approach intentionally narrows eligibility compared with Holt’s broader, credit‑hour and two‑digit coding test ^[1]. The tradeoff is clarity for institutions and students versus the risk of excluding programs that perform similar professional functions but sit in adjacent CIP codes ^[1].

4. What the reporting does not say — gaps you should know

Available sources do not enumerate the 11 professions named in the draft, do not list which specific institutional programs were or were not deemed “professional” under the draft, and do not provide detail on the other criteria besides the CIP‑code requirement (not found in current reporting). The Inside Higher Ed piece focuses on the regulatory mechanics and the committee’s competing proposals rather than case lists of retained or excluded programs ^[1].

5. Stakes and likely effects — who gains and who loses

If the Department adopts the four‑digit CIP requirement, programs with professional outcomes that are coded differently could lose access to the highest federal loan limits; conversely, programs squarely matching the coded professions would preserve or gain access ^[1]. Supporters of the department’s move can argue it prevents arbitrary expansions of “professional” status; critics—as signaled by committee members favoring Holt’s approach—would argue it is overly rigid and could penalize legitimate professional pathways that sit in neighboring codes ^[1].

6. What to watch next — where further reporting should go

Future coverage should publish the full text of the department’s draft (including the list of 11 professions), examples of programs affected, and the department’s justification for four‑digit versus two‑digit alignment; those specifics are not in the reporting cited here and are necessary to judge real‑world impact (not found in current reporting). Also watch for formal public comment periods, agency responses to committee concerns, and any higher‑education institution analyses quantifying students and programs subject to the change ^[1].

Sources referenced in this note are limited to Inside Higher Ed’s coverage of the Education Department’s proposal and related committee debate ^[1]. Other documents in the supplied search results address unrelated program or eligibility topics and do not discuss this rulemaking (not found in current reporting).