Following Legal Action, ED Temporarily Adds New CIP Codes Eligible for Professional Degree Designation, Removes Others
By Megan Walter, Senior Policy Analyst
Less than a week after a federal court temporarily halted (or “stayed”) key parts of the Department of Education’s (ED) narrowed professional degree definition, ED issued an Electronic Announcement (EA) (GENERAL-26-42) clarifying how schools should treat professional degree programs for loan limit purposes. The guidance includes an updated list of Classification of Instructional Programs (CIP) codes that are temporarily eligible for the higher professional degree program loan limits during the stay, until the case is heard in full and a final ruling is made, as well as a list of programs that may have been previously eligible but have been temporarily removed from eligibility.
As a reminder, the One Big Beautiful Bill Act created a distinction between graduate and professional degree programs for Direct Unsubsidized loan limits: professional students can now borrow up to $50,000 annually and $200,000 in the aggregate, while graduate students remain capped at $20,500 annually, with an aggregate limit of $100,000.
As previously reported, a federal court on June 23 paused two pieces of ED's Reimagining and Improving Student Education (RISE) final rule just days before its July 1, 2026, effective date. That ruling temporarily suspends part of the professional degree definition at 34 CFR 685.102, which contained ED's new, narrower test for what qualifies as a professional degree program, and the provision (which appeared in the rule's preamble) that a program is not considered a professional degree program if its graduates are required to work under another professional’s supervision.
The EA identifies which additional fields now temporarily qualify for the higher professional degree loan limits during the stay. ED identified eligible programs at the 6-digit CIP code level, with a total of 29 6-digit CIPs now meeting the professional degree criteria, including physician assistant (associate), occupational therapy, physical therapy, several advanced nursing degrees, speech-language pathology, athletic training, and audiology.
The 6-digit CIP codes that are temporarily eligible for professional degree loan limits are:
6-digit CIP |
6-digit CIP Title (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 (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/Audiologist (AuD) |
|
51.0203 |
Speech-Language Pathology/Pathologist (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/Trainer (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/Therapist (OT; MSOT; OTD) |
|
51.2308 |
Physical Therapy/Therapist (PT; DPT) |
|
51.3801 |
Registered Nursing/Registered Nurse (MSN) |
|
51.3804 |
Nurse Anesthetist (DNAP) |
|
51.3818 |
Nursing Practice (DNP) |
ED appears to imply that schools must originate loans at the higher professional degree limit for the newly-identified, temporarily eligible programs unless they choose to apply lower institutional loan limits, stating in the EA that, “During the pendency of the ongoing litigation, institutions may wish to consider, for programs now temporarily classified as awarding professional degrees pursuant to the Court’s order, limiting loan amounts to the graduate-level caps to mitigate potential disruption to student borrowers resulting from changes in program classification that may arise from the ongoing litigation.” Institutions should review the published CIP list against their affected programs and consult their own legal counsel before making packaging decisions.
The EA provides operational guidance for increasing individual students’ loans from the graduate level to the professional level, which involves changing the Student Level Code in the Common Origination and Disbursement (COD) system to one of the three Professional Grade Levels, and either increasing the existing loan or originating a new loan for the difference between the graduate and professional loan limit amounts.
ED also explicitly excluded 25 programs that share a 4-digit CIP code with a professional degree program but differ at the 6-digit CIP code level. This means that programs institutions had previously determined to be qualified for the higher professional degree loan limits may no longer be eligible for those loan limits until a final decision is issued by the court. Programs temporarily excluded from the professional degree designation are:
6-digit CIP |
6-digit CIP Title (Degree) |
|
39.0601 |
Theology/Theological Studies |
|
39.0604 |
Pre-Theology/Pre-Ministerial Studies |
|
39.0699 |
Theological and Ministerial Studies, Other |
|
42.2802 |
Community Psychology |
|
42.2804 |
Industrial and Organizational Psychology |
|
42.2806 |
Educational Psychology |
|
42.2808 |
Environmental Psychology |
|
42.2809 |
Geropsychology |
|
42.2813 |
Applied Psychology |
|
42.2814 |
Applied Behavior Analysis |
|
42.2815 |
Performance and Sport Psychology |
|
42.2816 |
Somatic Psychology |
|
42.2817 |
Transpersonal/Spiritual Psychology |
|
51.1299 |
Medicine, Other |
|
51.2002 |
Pharmacy Administration and Pharmacy Policy and Regulatory Affairs |
|
51.2003 |
Pharmaceutics and Drug Design |
|
51.2004 |
Medicinal and Pharmaceutical Chemistry |
|
51.2005 |
Natural Products Chemistry and Pharmacognosy |
|
51.2006 |
Clinical and Industrial Drug Development |
|
51.2007 |
Pharmacoeconomics/Pharmaceutical Economics |
|
51.2008 |
Clinical, Hospital, and Managed Care Pharmacy |
|
51.2009 |
Industrial and Physical Pharmacy and Cosmetic Sciences |
|
51.2010 |
Pharmaceutical Sciences |
|
51.2011 |
Pharmaceutical Marketing and Management |
|
51.2099 |
Pharmacy, Pharmaceutical Sciences, and Administration, Other |
ED indicated that institutions would not be required to return funds already disbursed prior to the publication of the EA for students whose programs were previously considered professional degrees, but would have to make adjustments to future disbursements for students enrolled in these programs
The EA is explicit that these designations are temporary. ED stated in the announcement:
"Although the Department is confident that the professional degree definition in the RISE Final Rule is lawful and will continue to defend it, we are, nonetheless, for the duration of the Court's preliminary stay, based on the Department's understanding of the Court's ruling, treating the programs listed below as awarding professional degrees for the purpose of administering statutory loan limits. These interim administrative designations are provided solely to facilitate implementation of the Court's order and may change as litigation in the case proceeds."
In other words, this is not a permanent rule change and was not done through negotiated rulemaking. It is ED's interim compliance posture for the duration of the stay, until the case is heard in full and a final ruling is made. The department has signaled it expects to revert to its narrower definition if it prevails in the litigation.
NASFAA will continue to monitor this case and the department's response and will report on further developments in Today's News.
Publication Date: 6/30/2026
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