
Key Points
- The Department of Education added Doctor of Naturopathy and Doctor of Naturopathic Medicine programs to its professional degree list on October 23, 2026, after a federal court order.
- Students in these programs can now borrow up to $50,000 a year and $200,000 total in Direct Unsubsidized Loans, up from $20,500 and $100,000.
- The designation is temporary while the lawsuit continues. Schools may still cap these loans at the lower graduate limits.
The Department of Education updated its list of professional degree programs on October 23, 2026, to include naturopathic medicine. A Federal Student Aid electronic announcement now treats Doctor of Naturopathy (N.D.) and Doctor of Naturopathic Medicine (N.M.D.) programs under CIP code 51.3303 as professional degrees.
That brings the interim list to 30 programs, one more than the 29 the Department published after a June court stay expanded the professional degree list.
The update follows a preliminary injunction issued October 16 by Judge Michael Simon of the U.S. District Court for the District of Oregon. In a 60-page opinion (PDF File), Simon found the Department likely broke the law by applying criteria outside the statute when it classified the N.D. as a graduate degree.
He also found the agency treated the N.D. inconsistently with other degrees that made the list. Law firm Thompson Coburn says it’s the first ruling to grant professional status to a specific degree under the new professional student loan caps.
Would you like to save this?
Why It Matters
Professional status more than doubles the annual amount a naturopathic student can borrow in federal loans. Under the graduate student loan limits that took effect July 1, 2026, a graduate student can borrow $20,500 a year and $100,000 total in Direct Unsubsidized Loans. A professional student can borrow $50,000 a year and $200,000 total.
A student in a four-year N.D. program capped at $20,500 a year could borrow $82,000 in federal loans. At the professional limit, that same student could borrow up to $200,000, or $118,000 more. Without the change, that difference would have to come from savings, school aid or private health professional student loans.
| Limit | Graduate Student | Professional Student |
|---|---|---|
| Annual Limit | $20,500 | $50,000 |
| Aggregate Limit | $100,000 | $200,000 |
| Four Years At The Annual Cap | $82,000 | $200,000 |
Which Programs Count As Professional Degrees Now?
Thirty programs are treated as professional degrees while the court orders remain in place. The October update adds CIP code 51.3303, and it covers any program in the same four-digit CIP code that awards the N.D. or N.M.D. credential. The Department used the same four-digit approach in July, when it added more nursing and psychology programs to the list.
Here’s how the list got to 30:
- The RISE final rule, published May 1, 2026, named 11 fields as professional degrees.
- A June 24 stay from the U.S. District Court for the District of Columbia expanded the interim list to 29 programs, including nursing, physician assistant and physical therapy degrees.
- That stay also left several theology, psychology and pharmaceutical science programs off the list.
- The Oregon injunction added naturopathy as the 30th program, effective “until further guidance is provided,” per Federal Student Aid.
The full interim list is below. Programs must award the degree shown to qualify.
| CIP Code | Program | Qualifying Degree |
|---|---|---|
| 01.8001 | Veterinary Medicine | D.V.M. |
| 22.0101 | Law | L.L.B., J.D. |
| 39.0602 | Divinity/Ministry | M.Div. |
| 39.0605 | Rabbinical Studies | M.H.L. |
| 42.2801 | Clinical Psychology | Ph.D., Psy.D. |
| 42.2803 | Counseling Psychology | Psy.D. |
| 42.2805 | School Psychology | Psy.D. |
| 42.2807 | Clinical Child Psychology | Psy.D. |
| 42.2810 | Health/Medical Psychology | Psy.D. |
| 42.2811 | Family Psychology | Psy.D. |
| 42.2812 | Forensic Psychology | Psy.D. |
| 42.2899 | Clinical, Counseling And Applied Psychology, Other | Psy.D. |
| 51.0101 | Chiropractic | D.C., D.C.M. |
| 51.0202 | Audiology | AuD |
| 51.0203 | Speech-Language Pathology | SLP |
| 51.0401 | Dentistry | D.D.S., D.M.D. |
| 51.0809 | Anesthesiologist Assistant | CAA |
| 51.0912 | Physician Associate/Assistant | MSPA, PA |
| 51.0913 | Athletic Training | MSAT, MAT |
| 51.1201 | Medicine | M.D. |
| 51.1202 | Osteopathic Medicine | D.O. |
| 51.1203 | Podiatry | D.P.M., D.P., Pod.D. |
| 51.1701 | Optometry | O.D. |
| 51.2001 | Pharmacy | Pharm.D. |
| 51.2306 | Occupational Therapy | OT, MSOT, OTD |
| 51.2308 | Physical Therapy | PT, DPT |
| 51.3303 | Naturopathy/Naturopathic Medicine (New) | N.D., N.M.D. |
| 51.3801 | Registered Nursing | MSN |
| 51.3804 | Nurse Anesthetist | DNAP |
| 51.3818 | Nursing Practice | DNP |
How Do Schools Apply The Higher Limit?
Schools can raise loans that were already made at the graduate level this year. Federal Student Aid says a school with a 2026–27 loan coded at the graduate level can update the student level code and raise the amount to the professional limit. The school can also originate a second loan for the difference. That level code is what separates a graduate degree from a professional degree in the federal loan system.
The higher limit isn’t automatic, though. Federal Student Aid told schools they can set program-level loan limits and suggested some keep these programs at graduate caps while the litigation plays out.
The Association of Accredited Naturopathic Medical Colleges advises students not to make borrowing decisions based on the announcement alone and to work with their aid office instead. Students who borrow more should also run the numbers on repayment under the new Repayment Assistance Plan before accepting the full amount.
The reversal risk is real. If the designation is reversed, Federal Student Aid says schools don’t have to adjust amounts already disbursed. Any later disbursements would drop back to the graduate limit, which could leave a student short in the middle of a program. That’s the same planning problem medical students face when federal loans fall short of medical school costs.
Students should also realize that just because they can borrow more doesn’t mean that they can afford it after graduation. Degrees like naturopathic medicine can be challenging to repay significant amounts of student loan debt because there is not easy pathway to loan forgiveness programs that can help.
How This Connects
The naturopathic ruling is one piece of a larger legal fight over which degrees count as professional. At least five other pending cases challenge the RISE rule’s definition, including the lawsuit from 23 states over graduate loan caps and a union lawsuit over nursing and social work borrowing.
Each case seeks relief only for the degrees it names. Congress is also weighing changes, with a House bill that would make graduate nursing a professional degree.
The injunction itself covers the three plaintiff groups and their members. Those are the Association of Accredited Naturopathic Medical Colleges, the Naturopathic Medical Student Association and the American Association of Naturopathic Physicians. Federal Student Aid added the CIP code to its general list, which is what schools use when they process loans under the July 2026 federal student loan changes.
What’s Next
The Department says it will keep defending the RISE rule, and it can appeal the injunction to the Ninth Circuit or seek an expedited summary judgment ruling. Judge Simon denied the Department’s request for a stay pending appeal, so the higher limit stands for now.
Several of the other professional degree cases finish summary judgment briefing before the end of 2026, which could reshape the list again. Borrowers should watch those rulings alongside the other major student loan changes from 2026.
Editor: Colin Graves
