Which Trump-era memo or rule reclassified nursing as nonprofessional work?

Checked on November 29, 2025
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Executive summary

The change traced in reporting stems from the Department of Education’s implementation of student‑loan provisions in President Trump’s “One Big Beautiful Bill Act,” which narrows which graduate programs count as “professional degrees” and—if finalized—will exclude many nursing programs from that category, triggering lower loan limits for affected students [1] [2]. Several major outlets report the Education Department moved to exclude nursing from the professional‑degree list as part of negotiated rulemaking tied to the bill; at least one fact‑check says the proposal had not yet legally reclassified programs when it was first reported [3] [4].

1. What change is at issue — and where it came from

The reported shift originates in the Department of Education’s implementation of student‑loan provisions in the One Big Beautiful Bill Act (OBBBA), a Trump administration spending and student‑loan overhaul; news outlets say the department has “excluded” nursing from its revamped definition of “professional degree” programs, a move tied to new graduate borrowing limits under the law [1] [2] [5].

2. Which Trump‑era memo or rule did this — the short answer

Available sources point to the Department of Education’s negotiated rulemaking and implementation of the OBBBA’s loan provisions rather than a single, widely publicized standalone “memo.” Outlets describe the change as produced by the Education Department’s redefinition in the course of implementing the OBBBA and related negotiated rulemaking sessions [3] [6]. Snopes frames the action as a proposal or interpretation emerging from that process, not a one‑page memo [4].

3. How the change affects nursing students financially

Under reporting about the OBBBA, only programs counted as “professional degrees” would qualify for the higher borrowing caps (reported figures include a $200,000 professional‑degree cap versus a $100,000 cap for other graduate students in some stories); excluding nursing from the professional category therefore limits how much federal borrowing some aspiring or advanced nurses can access and may restrict who can access certain loan forgiveness or repayment programs [7] [2] [8].

4. Where the reporting differs — proposal vs. final rule

There is a key disagreement in the coverage: multiple news outlets reported that the department has “excluded” nursing under its new definition and that changes are being implemented [1] [9] [10], while a fact‑check from Snopes says that, at the time of its writing, the agency’s action was part of a proposal/negotiated‑rulemaking process and had not legally completed a formal reclassification [4]. The Washington Post likewise frames controversy around a “proposal” that has spawned misinformation and debate [3].

5. Which parts of higher education were narrowed into or out of the category

Some reporting and advocacy outlets say the department narrowed the professional‑degree list sharply — excluding fields beyond nursing such as teaching, social work, many allied‑health advanced degrees, and others — and in at least one account a small list of traditionally clinical degrees was retained as “professional” [6] [9]. The World Socialist Web Site claims the negotiated rulemaking narrowed the list to about eleven fields, though that is an advocacy outlet’s framing and should be weighed alongside mainstream reporting [6].

6. Reactions from nursing groups and policy implications

Nursing organizations expressed alarm, warning the change threatens access to graduate training and could worsen workforce shortages; state nursing associations and the American Association of Colleges of Nursing reportedly urged the Education Secretary to reverse the interpretation [1] [5] [2]. Critics also frame the change as disproportionately affecting fields with higher shares of women, raising equity concerns [8].

7. What the sources do not settle or do not mention

Available sources do not produce a single named “memo” document with a formal title that unambiguously enacted the reclassification; they attribute the change to the Department of Education’s rulemaking and OBBBA implementation [4] [3]. Sources do not provide the full text of the final regulation in these excerpts, nor do they uniformly agree on whether the action was legally finalized at the moments they reported [4] [3].

8. How to follow up and verify the precise legal action

To confirm whether a formal rule or final regulation has been issued and to read its language, consult the Department of Education’s official rulemaking releases and the Federal Register notice tied to OBBBA implementation; the news items cited here locate the change in DOE negotiated rulemaking and OBBBA implementation but differ on whether an enforceable final rule had been posted at the time of reporting [3] [4].

Limitations: reporting in the sources mixes newsroom headlines, advocacy framing and a Snopes fact‑check that distinguishes proposal from final action; readers should consult the agency’s Federal Register rule and the Department of Education’s press releases for the definitive legal text [3] [4].

Want to dive deeper?
Which specific 2018-2020 Trump policy reclassified nursing as nonprofessional work?
Which federal agency issued the memo or rule about nursing classification under the Trump administration?
How did the 2018-2020 reclassification affect certified nursing assistants versus licensed nurses?
Were any courts or states that blocked or overturned the Trump-era nursing reclassification?
What were the stated motivations and critics' responses to the Trump-era reclassification of nursing?