The Department of Education’s Proposed Rule to Define “Professional Student” - Frequently Asked Questions - Updated February 24, 2026

Oct 15, 2026

A frequently asked questions briefing explains the U.S. Department of Education’s proposed rule implementing changes from Title VIII of P.L. 119-21 to the Higher Education Act of 1965, focusing on how “professional student” and “graduate student” are defined for Direct Loan limits. It describes why Direct PLUS Loans for graduate and professional students will be eliminated in future years, outlines general eligibility distinctions effective for individuals not enrolled as of June 30, 2026, and details how “professional degree” is determined. It further covers comment timing, the proposed use of CIP codes, and which fields may be excluded from the professional degree definition.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages22

Reading Time55 min

AccessFree to download

Introduction

Background on Direct Loan Types and Limits to Graduate and Professional Students

What types of Direct Loans currently are available to graduate and professional students and what are the current borrowing limits?

What changes did P.L. 119-21 make to the types and loan limits of Direct Loans available to graduate and professional students?

Were distinctions in loan limits made between graduate and professional students prior to enactment of P.L. 119-21?

ED Rulemaking to Implement P.L. 119-21’s Amendments to Loan Limits

How would the proposed rule define “graduate student” and “professional student” for purposes of the new loan limits?

What is a CIP Code?

What CIP Codes apply to the 11 fields in which a professional degree may be awarded under the proposed definition?

What types of programs of study would be excluded from the definition of “professional degree” under the proposed definition?

The Department of Education’s Proposed Rule to Define “Professional Student”: Frequently Asked Questions Updated February 24, 2026 Congressional Research Service [https://crsreports.congress.gov](https://crsreports.congress.gov)[ ](https://crsreports.congress.gov)R48768 The Department of Education’s Proposed Rule to Define “Professional Student”: Frequently Asked Questions Title VIII of P.L. 119-21 (also referred to as the FY2025 budget reconciliation law) amended the Higher Education Act of 1965 (HEA) to update several aspects of the William D. Ford Federal Direct Loan (Direct Loan) program, which is the single largest source of federal financial assistance to support students’ postsecondary education pursuits. R48768 February 24, 2026 Alexandra Hegji Specialist in Social Policy Among other changes, P.L. 119-21 eliminates the availability of Direct PLUS Loans to graduate and professional students in future years and specifies one set of annual and aggregate loan limits for graduate students and a separate set of such limits, in higher amounts, for professional students. In general, these changes are applicable to individuals who, as of June 30, 2026, are not enrolled in a program of study for which they received a Direct Loan. Prior to P.L. 119-21, Direct Loan limits generally did not distinguish between graduate students and professional students, with the exception of certain health professions programs (e.g., Doctor of Allopathic Medicine, Doctor of Dentistry) for which the Secretary of Education invoked previous HEA authority to raise limits because such students were “engaged in specialized training requiring exceptionally high costs of education.” On January 30, 2026, the U.S. Department of Education published a Notice of Proposed Rulemaking with proposed regulatory text to implement the P.L. 119-21 amendments to the Direct Loan program. This proposed regulatory text reflects draft regulatory text on which a negotiated rulemaking committee reached consensus and includes definitions of “graduate student” and “professional student.” Under the proposed rule,“professional student” would be defined as a “student enrolled in a program of study that awards a professional degree,” and“graduate student” would be defined as a “student enrolled in a program of study that is above the baccalaureate level and awards a graduate credential (other than a professional degree).” “Professional degree” would be defined as one that • “signifies completion of the academic requirements for beginning practice” in a particular profession and“a level of professional skill beyond that normally required for a bachelor’s degree”; • is “generally at the doctoral level …requires at least six academic years of postsecondary education coursework for completion,” at least two years of which must be postbaccalaureate level coursework; • “generally requires professional licensure to begin practice”; and • includes a four-digit program Classification of Instructional Programs (CIP) Code (as assigned by the institution of higher education or determined by the Secretary of Education) in the same “intermediate group” as 11 fields identified in regulation. The 11 fields in which a professional degree could be awarded, under the consensus definition, are (1) Pharmacy (Pharm.D.),(2) Dentistry (D.D.S. or D.M.D.), (3) Veterinary Medicine (D.V.M.), (4) Chiropractic (D.C. or D.C.M.), (5) Law (L.L.B. or J.D.), (6) Medicine (M.D.),(7) Optometry (O.D.),(8) Osteopathic Medicine (D.O.), (9) Podiatry (D.P.M., D.P., or Pod.D.),(10) Theology (M.Div., or M.H.L.), and (11) Clinical Psychology (Psy.D. or Ph.D.) . Based on these definitions, numerous programs of study covering a range of fields would be excluded from the definition of “professional degree.” These include, for example, programs of study for architecture, engineering, business, rehabilitation and therapeutic professions (e.g., occupational therapy and physical therapy), and nursing

FAQs

What legal changes does P.L. 119-21 make to Direct Loan programs for graduate and professional students?

P.L. 119-21 eliminates the availability of Direct PLUS Loans to graduate and professional students in future years and establishes separate annual and aggregate loan limits for graduate versus professional students.

How does the proposed rule define “professional student” and “graduate student”?

The proposed rule defines “professional student” as a student enrolled in a program of study that awards a professional degree, and “graduate student” as a student enrolled in a program above the baccalaureate level that awards a graduate credential other than a professional degree.

What fields could qualify for professional degrees under the consensus definition?

Under the consensus definition, professional degrees may be awarded in 11 fields: Pharmacy, Dentistry, Veterinary Medicine, Chiropractic, Law, Medicine, Optometry, Osteopathic Medicine, Podiatry, Theology, and Clinical Psychology.

Oct 15, 2026

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