The definition of “Professional degree” is defined through regulatory text (34 CFR § 668.2(b)– General definitions).¹ This definition now has significant implications given the changes to the system for federal loans for higher education administered through the Department of Education (ED) as altered by the The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025.

Under the OBBA, the ED will eliminate the Grad PLUS program (a system of federal loans available to graduate and professional students), cap Parent PLUS Loans (student loans available for parents of dependent undergraduate students), sunset various student loan repayment plans, and create a new Repayment Assistance Plan (RAP) (a federal student loan income-driven repayment plan). To date, graduate students could borrow up to the cost of attendance of their program. However, beginning in July 2026, the OBBBA will cap annual loans for new borrowers at $20,500 for graduate students ($100,000 aggregate limit) and $50,000 for professional students ($200,000 aggregate limit).²

Therefore, as a result of these changes, which degrees count as “professional” versus non-professional is now a determining factor in how much financial support students will receive. The stated objective for this change is to “place commonsense limits and guardrails” to combat “unsustainable student loan borrowing,” and place “significant downward pressure on the cost of tuition.”² 

The OBBBA did not define "professional degree." Rather, it referred to the existing regulatory definition (34 CFR § 668.2(b)).¹ The ED has aimed to update the regulatory language to develop a more precise and limited definition of "professional degree" programs. As part of the regulatory process, the ED convened a negotiated rulemaking committee of stakeholders to develop draft regulations through a two-week negotiation process on which degree programs qualify for which level of loans. This Committee, called the Reimagining and Improving Student Education (RISE) Committee, reached preliminary consensus on a definition on “professional degree programs” that limited a "professional degree" to those closely related to the listed examples in the regulatory text of 34 CFR § 668.2(b). 

Under the ED's new rules, the only programs that meet “professional” criteria would be the following: Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), Theology (M.Div., or M.H.L.), and Clinical Psychology (Psy.D. or Ph.D.). 

The original language of the statute stated "Examples of a professional degree include but are not limited to." Only allowing the stated disciplines above the ED has excluded nursing (MSN, MS, MA, MN, DNP, and research-focused nursing PhDs) from the definition of “professional degree” programs under these forthcoming federal loan eligibility rules. Other excluded health professions include physician assistants, physical therapists, and audiologists. The concern surrounding this shift is that fewer students would pursue graduate nursing education if funding available through federal loans is insufficient.

The ED is expected to release a Notice of Proposed Rulemaking in January and stakeholders will have additional opportunities to comment on these changes. The Academy plans to respond to the proposed rule, collaborate with our colleagues within and outside of nursing, and support Fellows who would like to submit letters on the proposed rule The Academy will continue to engage press. 

Citations:

1. 34 CFR § 668.2(b). https://www.ecfr.gov/current/title-34/subtitle-B/chapter-VI/part-668/subpart-A/section-668.2#p-668.2(b)(Professional%20degree) 
   34 CFR § 668.2(b): “Professional degree: 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. Professional licensure is also generally required. Examples of a professional degree include but are not limited to Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), and Theology (M.Div., or M.H.L.).”
2. U.S. Department of Education. (2025, November 6). U. S. Department of Education concludes negotiated rulemaking session to implement the One Big Beautiful Bill Act’s loan provisions. https://www.ed.gov/about/news/press-release/us-department-of-education-concludes-negotiated-rulemaking-session-implement-one-big-beautiful-bill-acts-loan-provisions.

American Academy of Nursing Echoes Grave Concerns Regarding Patient Outcomes if Nursing is Not Recognized as a Professional Degree

Washington, DC (November 24, 2025) — The American Academy of Nursing (Academy) has closely followed the actions of the Department of Education’s Reimagining and Improving Student Education (RISE) Committee that came to preliminary consensus on a definition for “professional degree programs,” that excludes nursing. 

This recommendation, if adopted, could place a dire strain on the health care system related to access and quality of care. First, and foremost, the nursing profession is a scientific discipline that is foundational to improved patient outcomes. Over the decades, nursing innovations have ushered in monumental improvements to how care is provided at the bedside and in the community. To not recognize nursing as a professional degree would be short-sighted and could have long-term implications on the nation’s health.

“The gravity of this proposal, should it move forward, is severe. At a time when the complexity of the health care system continues to grow and costs rise, nurses who are highly-educated, skilled professionals driven by evidence, are essential to meeting the challenges of a rapidly evolving environment,” said Debra J. Barksdale, PhD, FNP-BC, FAANP, ANEF, FAAN, Academy President. 

The Academy will be working with our colleagues both within and outside the profession to share our deep concerns with the Department of Education when the Notice of Proposed Rulemaking is released. It will be vital that the Department of Education understands the role of nurses within the health care system, their leadership within it, and the value they bring to patients and families every day. If this definition were written into final regulations, it could establish a harmful precedent that would have far-reaching consequences for not only the growth of the nursing profession, but the future of health care delivery.