crs_reports: R48768

Congressional Research Service reports with summaries, authors, and topic classifications.

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R48768 The Department of Education’s Proposed Rule to Define “Professional Student”: Frequently Asked Questions 2026-02-24T05:00:00Z 2026-02-25T16:37:51Z Active Reports Alexandra Hegji Postsecondary Education 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. 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. Thus, students enrolled in such programs would be considered graduate students for purposes of Direct Loan borrowing limits and would therefore have lower borrowing limits compared to individuals who are considered professional students. Members of the public may comment on the proposed rule on or before March 2, 2026. https://www.congress.gov/crs_external_products/R/PDF/R48768/R48768.6.pdf https://www.congress.gov/crs_external_products/R/HTML/R48768.html

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