Issue Summary
Redefining Professional Student Degrees
Under the Higher Education Act (HEA), a professional student degree is a post-bachelor’s degree in fields that typically require advanced certification or licensure and lead to practice in each profession. Unlike academic degrees focusing on original research or theory, they emphasize practical skills, clinical experience, and real-world application.
WHAT CHANGED?
Federal loan limit reforms under the One Big Beautiful Bill Act (OBBB) and the corresponding “redefinition” of professional degrees during recent negotiated rulemaking sessions.
The Reimagining and Improving Student Education (RISE) committee adopted the Department of Education’s (ED) narrower definition of a professional degree, which revised the original HEA regulatory language and replaced it with a list of 11 approved degree programs. Covered programs must:
- Require a degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor’s degree
- Have a Classification of Instructional Programs (CIP) code matching the existing list of covered programs
- Require a license to practice
Impact on Regional Public Universities (RPUs)
Under the OBBB, federal loan limits now vary by degree type:
PROFESSIONAL PROGRAMS
$200K total/$50K annually
OTHER GRADUATE PROGRAMS
$100K total/$20.5K annually
For RPUs, which enroll large numbers of first-generation and lower-income students, narrowing the definition creates significant challenges:
Program Classification RiskS
RPUs awarding graduate degrees outside the revised definition or CIP codes will lose professional designation, affecting student borrowing limits and undermining access.
Competitive Imbalance and Compliance Burdens
RPUs generally receive less government funding than other public four-year institutions, which could make compliance with stricter CIP oversight more burdensome. Other better-resourced universities are more likely to offer programs that are already recognized as professional degrees (e.g., medicine, dentistry, law) and have larger endowments than those at RPUs, enabling greater institutional flexibility and aid.
Workforce Impacts
Educational organizations, health care and nursing associations, and professional groups (e.g., physician assistants, social work, nursing advocates) have criticized the narrow definition, arguing it excludes many fields requiring licensure and creates affordability barriers that will limit graduate pipelines and workforce development.
Enrollment DECLINE
RPUs expand access to education for underserved and lower-income communities. Lower borrowing limits could force students to delay or decline enrollment in professional graduate programs. Some may choose shorter or cheaper certificate programs as an alternative to a full degree.
Why It Matters
ED Has Released a Final Rule
In January 2026, the Department of Education released a Notice of Proposed Rulemaking based on the consensus reached during the RISE negotiations. The final rule was published on May 1, codifying the consensus definition that distinguishes between graduate and professional degrees.
Graduate Degrees Granted “Professional” Designation Under New Regulations
RISE Committee Consensus Definition
- Chiropractic (D.C. or D.C.M.)
- Clinical Psychology (Psy.D. or Ph.D.)
- Dentistry (D.D.S./D.M.D.)
- Law (L.L.B./J.D.)
- Optometry (O.D.)
- Osteopathic Medicine (D.O.)
- Pharmacy (Pharm.D.)
- Podiatry (D.P.M., D.P., or Pod.D.)
- Medicine (M.D.)
- Theology (M.Div., or M.H.L.)
- Veterinary Medicine (D.V.M.)
Court Order Expands
List of Eligible Degrees
Per the deadlines set in the OBBB, the Department was required to implement regulatory provisions to support the new loan limits by July 1, the statutory enactment date.
On June 25, a federal judge in Washington, D.C., blocked the Department’s definition and list. Following the court order, the Department updated its list of Classification of Instructional Programs (CIP) codes for professional degrees to include previously omitted fields, with further changes expected as court proceedings advance. The 18 additions focus heavily on healthcare-related fields that were previously restricted by the Department’s narrow doctoral-level and six-year education requirements.
COURT-ORDERED ADDITIONS
- Anesthesiologist Assistant (CAA)
- Athletic Training/Trainer (MSAT; MAT)
- Audiology/Audiologist (AuD)
- Counseling Psychology (Psy.D.)
- Clinical Child Psychology (Psy.D.)
- Clinical, Counseling and Applied Psychology, Other (Psy.D.)
- Divinity/Ministry (M.Div.)**
- Family Psychology (Psy.D.)
- Forensic Psychology (Psy.D.)
- Health/Medical Psychology (Psy.D.)
- Nurse Anesthetist (DNAP)
- Nursing Practice (DNP)*
- Occupational Therapy/Therapist (OT; MSOT; OTD)
- Physician Associate/Assistant (MSPA; PA)
- Physical Therapy/Therapist (PT; DPT)
- Rabbinical Studies (M.H.L.)**
- Registered Nursing/Registered Nurse (MSN)*
- School Psychology (Psy.D.)
- Speech-Language Pathology/Pathologist (SLP)
* Includes any program within the same four-digit CIP code, as assigned by the institution or determined by the Secretary, provided it awards the same credential.
**Listed as Theology in the original RISE committee consensus definition list but partitioned by the court order.
Next Steps:
Legislative Alternatives
AASCU-ENDORSED
H.R. 6718 – Professional Student Degree Act (Lawler, R-NY)
Amends the HEA to broaden the federal definition of “professional degree,” allowing 13 additional graduate programs, many among the most popular RPU graduate programs, to qualify for higher federal student-loan borrowing limits.
RISE Committee Consensus Definition
- Chiropractic (D.C. or D.C.M.)
- Clinical Psychology (Psy.D. or Ph.D.)
- Dentistry (D.D.S./D.M.D.)
- Law (L.L.B./J.D.)
- Optometry (O.D.)
- Osteopathic Medicine (D.O.)
- Pharmacy (Pharm.D.)
- Podiatry (D.P.M., D.P., or Pod.D.)
- Medicine (M.D.)
- Theology (M.Div., or M.H.L.)
- Veterinary Medicine (D.V.M.)
H.R. 6718 Expanded List
- Accounting (M.Acc. or M.S.A.
- Architecture (M.Arch.)
- Audiology (Au.D.)
- Business Administration and Management, General (M.B.A. or D.B.A.)
- Education (M.A., M.S., M.A.T., M.Ed.)
- Ministry (D.Min.)
- Nursing (M.S.N., D.N.P., or Ph.D.)
- Occupational Therapy (M.O.T. of O.T.D.).
- Physician Assistant/Associate (M.P.A.S., M.S.P.A.S., M.M.S., or M.S.)
- Physical Therapy (D.P.T.)
- Public Health (M.P.H.)
- Social Work (M.S.W. or D.S.W.)
- Special Education (M.Ed. or M.S.Ed.)
Other Bills
H.R. 6574 – Loan Equity for Advanced Professionals Act (Kennedy, D-NY)
Standardizes loan caps at $50,000 annually and $200,000 total in federal Direct Unsubsidized Loans for all professional and graduate students.
H.R. 6677 – Professional Degree Access Restoration Act (Torres, D-NY)
Reverses OBBB changes that eliminated Federal Direct PLUS Loans and implemented loan limits on graduate students.
H.R. 6739 – Clarity in Professional Degree Act (Dingell, D-MI)
Expands HEA’s professional degree list to include 10 additional degrees.
Questions about professional degrees? Let us know.
"*" indicates required fields
