ED Releases Proposal for Defining Professional Programs

November 6, 2025
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The Department of Education released its latest proposal Wednesday for determining which post-baccalaureate degree programs get access to what amount of federal loans under Congress’ One Big Beautiful Bill Act

And while at face value the new plan largely mirrors a separate proposal submitted by one of the committee members, Alex Holt, earlier in the negotiation process, it includes a few key differences. (Holt represents taxpayers and the public interest.)

The new plan, presented by Under Secretary Nicholas Kent, still slightly expands the list of degree programs eligible for higher loan caps compared to the department’s original proposal—a list of only 10 degrees. But higher education experts say it’s less inclusive than the plan put forward by Holt. 

It’s unclear whether the committee will agree to the department’s plan. If they don’t reach consensus, the department is free to issue its own proposal.

Under ED’s latest proposal, in order for a degree program to count as “professional” and gain access to the highest amount of federal loans it must:

  • Signify that students have the skills to begin practice in a particular profession
  • Require a level of skill beyond that of a bachelor’s degree
  • Be a doctoral level degree (with the exception of a Masters in Divinity)
  • Require at least six years of academic instruction (at least two of which are post-baccalaurette) 
  • Involve a profession that requires licensure
  • Be included in the same four-digit identification code as one of 11 professions explicitly mentioned in the regulation

By comparison, Holt’s proposal—which had appeared to gain support from all committee members except the department—only required a program to meet the first two criteria, include at least 80 credit hours and be in the same two-digit identification code. These looser requirements, particularly when it came to credit hours and identification codes, opened the door to higher loan caps for a number of high-demand health care careers including occupational therapy, audiology, physicians assistants and nurse practitioners. 

A pulse check at the end of Wednesday’s meeting showed that only four of the nine non-federal committee members expressed support for the latest draft. Three, including the committee member representing state systems, said they were undecided. And two who represent public and private non-profit institutions didn’t support it.



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