The Department of Education is once again in the spotlight, and this time it is for proposed changes on how professional career fields will be categorized and defined as it relates to education loans. Looking deeper, it stems from Trump’s administration One Big Beautiful Bill Act (OBBBA) to apply annual limits to certain education loans. Part of that is clearly defining who is included as professionally degreed individuals.
At the macro level, too many Americans are drowning in education debt. While there are different schools of thought on root causes, most would argue that our system of education loan amounts to be repaid, forgiven, or canceled needs an overhaul.
One Big Beautiful Act: Breakdown of Higher Education Changes
The One Big Beautiful Bill Act signed on July 4 2025 mandated the establishment of loan limits for graduate and professional students and parent borrowers and termination of graduate and professional plus loans under SEC. 81001. By amending the Higher Education Act of 1965, it applies a maximum annual amount of loans, such as the Federal Direct Unsubsidized Stafford and Federal Direct PLUS loans, among other stipulations involving expected times to receive credentials, undergraduate programs, and income-based repayment assistance plans. The OBBBA removed the partial financial hardship requirement for the repayment plan, thus widening eligibility.
Here are some of the terms within the OBBBA as an example. Graduate and professional annual and aggregate limits for federal direct unsubsidized Stafford loans beginning July 1, 2026: “(A) Annual limits beginning July 1, 2026. Subject to paragraphs (7)(A) and (8), beginning on July 1, 2026, the maximum annual amount of Federal Direct Unsubsidized Stafford loans:
- “a graduate student, who is not a professional student, may borrow in any academic year or its equivalent shall be $20,500”
- “a professional student may borrow in any academic year or its equivalent shall be $50,000.”
Revisions to Loan Repayment
The proposal outlines revisions to loan repayment plans to borrowers with loans made on or after July 1, 2026 and expands the Department’s authority to use Federal Tax information to determine eligibility for to repay Direct Loans under income-based repayment plans. In terms of Pell Grant eligibility, it restricts or makes ineligible students with high student aid index (capacity to pay for college) and ability to pay with other means effective in the academic year 2026-2027. This will not only change who is eligible for the grant but how much aid is received. However, this may also help combat financial losses due to fraud, in which the Department of Education recently reported nearly $90 million incorrectly disbursed.
Safeguarding student aid and strengthening a system of accountability matters. Be sure to fully read the OBBBA sections on higher education and Department of Education’s proposals under the Negotiated Rulemaking for Higher Education 2025 section to draw your informed conclusions.
The Language of Eligibility
The Department of Education and Reimagining and Improving Student Education (RISE) committee reviewed definitions of a professional degree for the purposes of loan eligibility. According to the OBBA, the term ‘graduate student’ means a student enrolled in a program of study that awards a graduate credential (other than a professional degree) upon completion of the program. The term ‘professional student’ means a student enrolled in a program of study that awards a professional degree, as defined under section 668.2 of title 34, Code of Federal Regulations upon completion of the program. The biggest worry is that the proposed changes may preclude other important professional fields, including nursing and education, based on what seems like a technicality or interpretation of terminology.
The RISE committee met this Fall to discuss the definition of professional students in relation to loan limits and submission of legally justified alternative proposed language, which was noted as an outstanding item by Ms. Abernathy, Director, Policy Coordination Group, Office of Postsecondary Education in October. Based on the session transcripts and Issue Paper: Loan Limits Provisions and Definitions, recommendations included using “Examples of a professional degree include but are not limited to” language to preserve regulatory continuity and avoid the exclusion of critical health professions.
Professional student: A student enrolled in a program of study that awards a professional degree upon completion of the program; (1) A professional degree is 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, where professional licensure is also generally required. Examples of a professional degree includes but are not limited to the following degrees 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 any other degrees designated by the Secretary through rulemaking, as required by 20 U.S.C. 1098a and 5 U.S.C. 553. other degrees designated as professional degrees by the Secretary in a notice published in the FEDERAL REGISTER, with updates to that list published as needed.
Moving Forward
Publicly available information and materials from the November sessions are forthcoming on the Department of Education’s Negotiated Rulemaking for Higher Education site. The potential reclassifications are rightly leaving many questions in the air as the administration’s accelerated pace of change continues to cause anxiety for many. As changes to whom and how education will be financed are underway, organizations like ACE are advocating to ensure the language regarding the list of professional degrees is comprehensive and clearly understood.
The Accountability in Higher Education and Access Through Demand-driven Workforce Pell (AHEAD) Committee will be holding a public session December 8-12 in Washington, DC both in-person and live stream.
For general information about the Department of Education, see Agency Profile: The Department of Education.
