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Which professions are likely excluded by the OBBBA's definition and on what textual grounds?

Checked on November 20, 2025
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Executive summary

The Department of Education RISE Committee’s preliminary proposal for a “professional degree” definition under the One Big Beautiful Bill Act (OBBBA) appears to exclude several public‑health and other health professions, which stakeholders warn would cut students off from higher federal loan limits and harm workforce pipelines [1] [2]. Professional associations and schools of nursing explicitly urged a broader definition, arguing a narrow, standards‑oriented test would fragment interprofessional training and exclude degrees like the MPH and DrPH [2] [1].

1. What the controversial text aims to do — a narrow, standards‑based test

Advocates opposing the RISE Committee’s draft say the proposed definition leans on narrowly framed textual criteria tied to traditional licensing and duration rather than the role a degree plays in practice; that shift is the basis for excluding certain health and public‑health programs from “professional degree” status [1] [2]. The Coalition of providers argues Congress intended a broad, inclusive definition and that a new ED rule leaning on narrow standards would contradict that legislative purpose [2].

2. Who is most likely excluded — public health and some health professions

The Association of Schools and Programs of Public Health (ASPPH) flagged that the proposal would exclude the MPH and DrPH and “several other health professions,” with immediate consequences for federal loan limits and financial access for students [1]. Nursing and allied health organizations echoed that narrow textual tests risk leaving out programs essential to the health workforce [2].

3. Why it matters: student aid and workforce pipeline effects

ASPPH frames the exclusion as not merely semantic: losing “professional degree” classification could reduce students’ access to higher federal loan limits, making degree paths less financially attainable and potentially weakening future public‑health capacity [1]. The nursing coalition warns a fragmented repayment eligibility approach would undermine interprofessional education and strain an already stressed health workforce [2].

4. Competing textual readings and implicit agendas

Two readings are in play: one that reads “professional degree” narrowly (linked to licensure, specific duration, or traditional professional standards) and one that reads it broadly to capture degrees that prepare for practice across a profession [2] [1]. Stakeholders with institutional and workforce preservation agendas — schools, professional associations, and programs reliant on federal student aid — press for the broad reading; the RISE Committee’s textual approach, as criticized, may reflect an administrative agenda to limit federal aid exposure or to standardize definitions across programs [2] [1].

5. What sources explicitly say is excluded — MPH and DrPH named

ASPPH explicitly states the preliminary proposal would exclude the MPH and DrPH from the “professional degree” category, and notes “several other health professions” would likewise be at risk; the nursing coalition similarly warns of exclusions if ED adopts a narrow definition [1] [2]. Those are the concrete program‑level claims present in the available reporting.

6. What the sources don’t say — absence of a full ED text or complete list

Available sources do not publish the RISE Committee’s full draft regulatory text or a comprehensive list of every profession excluded, so reporting cannot confirm an exhaustive list of affected degrees or the exact statutory language being applied [1] [2]. The specific regulatory phrasing and any finalized ED guidance are not found in current reporting.

7. Practical next steps and rulemaking risks

Coalitions recommend ED adopt a broad, inclusive definition in rulemaking to preserve access and interprofessional training; they warn that a narrow definition would “deepen the health workforce” shortages and fragment repayment eligibility [2]. Absent changes, schools and programs could face downstream impacts on enrollment, affordability, and workforce supply [1] [2].

8. Bottom line for readers

The immediate, documented threats are exclusions of public‑health degrees (MPH, DrPH) and unspecified “other health professions” under the RISE Committee’s draft, with stakeholders urging ED to reframe the textual test to match Congressional intent for broad inclusion so federal aid and workforce stability are preserved [1] [2]. Because the full regulatory language and final ED decision are not published in the cited materials, outcomes will depend on forthcoming rulemaking and whether ED heeds the broad‑definition advocacy [2] [1].

Want to dive deeper?
What is the full text of the OBBBA definition referenced and where is it published?
Which occupations are explicitly listed as included or excluded in the OBBBA statute or guidance?
How have courts interpreted the OBBBA’s definition in past rulings about professional coverage?
What textual features (phrasing, exceptions, cross-references) typically indicate exclusion of professions under statutes like the OBBBA?
How would regulatory agencies or advisory opinions determine whether a given profession falls outside the OBBBA’s definition?