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Why did the Department of Education add these 11 professional degrees and what criteria were used?
Executive summary
The Department of Education (ED) proposed narrowing its working definition of “professional degree” as part of implementing the One Big Beautiful Bill Act (OBBBA), which would cut the number of programs classed as professional from roughly 2,000 to under 600 and restrict higher graduate loan limits to a much smaller set of degree categories (reports cite caps of $50,000/year for professional students vs. $20,500 for other graduate students) [1] [2]. The move follows negotiated-rulemaking language that ED says tracks long‑standing regulatory text and aims to curb borrower costs and hold institutions accountable; critics — especially in nursing, public health, speech and audiology, and other health fields — say the narrower list will make advanced health degrees less affordable and harm workforce pipelines [3] [4] [5].
1. What the Department of Education says it is doing and why
ED frames the change as an administrative step to implement OBBBA’s new loan caps and to align with historical regulatory definitions of “professional degree,” arguing the negotiated language will “drive a sea change” by pressuring tuition and improving return on investment for borrowers [6] [3]. Officials at ED and allies in higher‑education leadership describe the reforms as reforms to protect taxpayers and borrowers by limiting very large graduate borrowing and increasing accountability for program outcomes [7] [2].
2. The practical effect: fewer programs get higher loan limits
Reporting and advocacy groups say the proposed redefinition would drastically shrink the roster of programs eligible for the larger graduate/professional borrowing cap, moving many clinical and public‑health degrees into lower loan tiers. Multiple outlets and posts list excluded programs — nursing (MSN, DNP), social work, public health (MPH, DrPH), physician assistant, occupational/physical therapy, audiology, speech‑language pathology, counseling, education masters, and more — and note the change would reduce access to the $50,000/year professional‑student cap, instead subjecting many students to the lower graduate cap [3] [1] [8].
3. The criteria ED says it used
ED’s stated criterion centers on an older regulatory definition: a “professional degree” typically requires a professional license to practice and is generally at the doctoral level or involves an extended program of study that includes two post‑baccalaureate years — language ED says is consistent with historical precedent [2] [3]. Negotiated‑rulemaking participants reportedly agreed on “consensus language” designed to identify programs already listed as examples in regulatory text rather than thousands of disparate graduate credentials [5] [6].
4. Critics’ counterpoint: health and education workforce harms
Nursing, public‑health, speech and audiology associations and other stakeholders argue the department’s narrow reading ignores the reality of licensure and direct practice across many advanced health and human‑services degrees; they warn exclusions will make graduate training unaffordable, weaken workforce pipelines, and contradict the department’s own claim that professional programs are those leading to licensure and direct practice [9] [4] [5]. Professional groups have mobilized lobbying, coalition letters, and Capitol Hill advocacy to insist their fields meet the functional tests ED cites [5].
5. How advocates and reporters describe the political and policy context
Observers link the change to broader OBBBA reforms that capped graduate borrowing, eliminated the GRAD PLUS program, and created a new Repayment Assistance Plan; ED’s move is framed as part of a larger push by the administration to reduce federal higher‑education spending and “right‑size” the department’s role [2] [7]. Some outlets place ED’s proposal in the wider context of the administration’s goal to shrink the department and overhaul federal higher‑education policy [10] [11].
6. Conflicting narratives and transparency questions
ED asserts continuity with decades‑old regulation and says its interpretation aligns with historical precedent [3]. Opponents say the application of that text is narrow and sudden, and they point out ED’s preliminary “negotiated” lists omit widely accepted professional programs; professional associations note ED’s process will proceed through rulemaking and a public comment period, leaving room for challenge or revision [5] [4] [3].
7. What’s next in the rulemaking process
ED is expected to issue a Notice of Proposed Rulemaking (NPRM), open a public comment period, and finalize rules (ED has signaled final rules by spring 2026 in some statements), meaning affected professions and institutions will have formal opportunities to submit evidence and lobby for inclusion — and to contest ED’s interpretation [4] [3].
Limitations: available sources do not include the full ED rule text in this packet, so this summary relies on news and association reporting and ED statements referenced in those accounts; specific, final regulatory language and ED’s complete justification will be found in the NPRM and federal register notices when published [4] [3].