The Department of Education has temporarily widened the types of degree programs that qualify for the higher professional-student loan limits, adding fields like physician assistant, physical therapy, occupational therapy, audiology, and several advanced nursing degrees while the agency's narrower rule is paused in court.
In Electronic Announcement GENERAL-26-42, posted June 29, ED published an updated list of Classification of Instructional Programs (CIP) codes that schools must treat as professional degree programs for federal loan limit purposes. The list now covers 29 six-digit CIP codes, well beyond the 11 fields ED originally named in its Reimagining and Improving Student Education (RISE) final rule.
The change is a direct response to a court order. On June 24, the U.S. District Court for the District of Columbia preliminarily stayed part of ED's professional degree definition just days before the rule's July 1 effective date.
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Why It Matters
The dollar gap between the two tiers is large. Under the One Big Beautiful Bill Act, professional students can borrow up to $50,000 a year and $200,000 in aggregate in Direct Unsubsidized loans. Graduate students are capped at $20,500 a year and $100,000 aggregate.
Whether a program sits on the professional list determines how much a student can borrow.
The Details
The 29 recognized programs span the long-standing professional fields plus the additions that drove the litigation. Programs must award the specific degree ED lists to qualify:
- Veterinary medicine (D.V.M.)
- Law (J.D., LL.B.)
- Divinity/ministry (M.Div.) and rabbinical studies (M.H.L.)
- Clinical, counseling, school, child, health, family, and forensic psychology (Psy.D.)
- Chiropractic (D.C.)
- Audiology (AuD) and speech-language pathology (SLP)
- Dentistry (D.D.S., D.M.D.)
- Anesthesiologist assistant (CAA)
- Physician associate/assistant (PA)
- Athletic training (MSAT, MAT)
- Medicine (M.D.) and osteopathic medicine (D.O.)
- Podiatry (D.P.M.)
- Optometry (O.D.)
- Pharmacy (Pharm.D.)
- Occupational therapy (OTD) and physical therapy (DPT)
- Advanced nursing: registered nursing (MSN), nurse anesthetist (DNAP), and nursing practice (DNP)
ED also removed 25 programs that share a four-digit CIP family with a professional degree but differ at the six-digit level. Schools that previously treated those as professional degrees can no longer originate at the higher limit. The temporarily excluded fields include:
- Theology, pre-theology/pre-ministerial, and other theological and ministerial studies
- Applied psychology specialties: community, industrial/organizational, educational, environmental, geropsychology, applied behavior analysis, sport, somatic, and transpersonal psychology
- "Medicine, Other"
- Roughly a dozen pharmaceutical sciences, pharmacy administration, and drug-development programs
What Schools Have To Do
For students in newly eligible programs, institutions report one of three professional grade levels in the Common Origination and Disbursement system, then either raise the existing loan or originate a new loan for the difference up to the professional cap. For dropped programs, ED says schools need not claw back funds already disbursed before the announcement, but future disbursements must use graduate-level limits.
ED also flagged a hedge: because institutions can set program-level loan caps starting July 1 under the Working Families Tax Cuts Act, schools "may wish to consider" holding affected programs to graduate-level limits to avoid whipsawing borrowers if the litigation reverses course.
How This Connects
The expanded list grows directly out of the fight The College Investor covered when a federal judge blocked the professional degree rule days before the loan caps hit. That challenge (brought by the American Association of Nurse Practitioners, the PA Education Association, and others) argued ED's narrow definition wrongly cut nurses, PAs, and physical therapists out of the higher tier, an objection echoed by 23 states that sued over the upcoming graduate loan caps.
The RISE rule still reshapes graduate borrowing in ways unaffected by the stay, including the end of the Grad PLUS program and ED's confirmation that Grad PLUS balances count toward the $257,500 lifetime cap. For borrowers weighing what these tiers mean in practice, see our breakdown of graduate vs. professional degrees for student loans and the full graduate student loan limits for 2026.
The Department of Education was blunt that this is temporary. The agency said it remains "confident that the professional degree definition in the RISE Final Rule is lawful and will continue to defend it," calling the expanded list an "interim administrative" posture that "may change as litigation in the case proceeds."
A final ruling could shrink the list again.
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Editor: Colin Graves
Robert Farrington is the founder of The College Investor and is widely recognized as one of the nation’s leading voices on student loan debt and saving for college. He holds an MBA from UC San Diego Rady School of Management and has spent over 15 years researching, writing, and advising on student loans, 529 plans, financial aid programs, and saving and investing for young professionals.
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