ED Adds Professional Degree CIP Codes for Nursing, Psychology
By Megan Walter, Senior Policy Analyst
The Department of Education (ED) has revised Electronic Announcement (EA) (GENERAL 26-42), updating the list of Classification of Instructional Programs (CIP) codes temporarily eligible for professional degree loan limits by adding degree programs not included in its original June 29 guidance. This revision comes one day after the plaintiffs in the lawsuit filed by nurse practitioner (NP) and physician associate (PA) groups against ED were told that ED was “actively considering updates to the technical guidance.”
As a reminder, on June 24, Judge Beryl Howell granted the plaintiffs' request for preliminary relief, pausing part of the department's narrowed definition of professional degrees under the Reimagining and Improving Student Education (RISE) final rule, as well as the provision excluding programs whose graduates are required to work under another professional's supervision.
In response, ED published an EA on June 29, identifying 29 6-digit CIP codes as temporarily eligible for the higher professional degree loan limits. NP plaintiffs subsequently argued that this list did not cover all of their members' relevant degree programs, noting that some advanced nursing degrees, including more specialized Doctor of Nursing Practice tracks, are classified under separate 6-digit CIP codes that share the same 4-digit CIP code family (51.38) as other eligible programs but were left off ED's list entirely. Plaintiffs asked ED to clarify whether the list was exhaustive and whether it would be updated; PA plaintiffs raised similar questions about the scope as it applies to physician associate/assistant programs. On July 9, rather than filing a proposed briefing schedule as previously ordered, the parties jointly requested a one-week extension to July 16 to allow time to assess ED's forthcoming updated guidance, which it published on July 10 as a revision to the original June 29 EA.
The revised EA, updated on July 10, clarifies that the 6-digit CIP codes for the Registered Nursing/Registered Nurse (MSN) (51.3801) and Nursing Practice (DNP) (51.3818) now include any program within the same four-digit CIP code, as assigned by the institution or determined by ED, provided it awards the same credential. ED also amended the CIP code list of eligible professional degree programs, adding Clinical Psychology Ph.D. programs with CIP code 42.2801 that were inadvertently omitted from the initial list.
ED did not make changes to eligible CIP codes for physician associate/assistant programs.
As with the eligible CIP codes in the June 29 guidance, these designations remain interim: ED has been clear that it intends to continue defending the RISE final rule's narrower professional degree definition and could revert to that definition if the department prevails in the ongoing litigation. Related, ED has not yet appealed the court order, a path they can still pursue. Institutions should review the updated CIP list against their affected programs and work with institutional legal counsel to decide how to proceed.
ED and the plaintiffs are due to file a joint status report, including a proposed briefing schedule for the full case hearing, by July 16. NASFAA will continue to monitor the case and will report on further developments in Today's News.
Publication Date: 7/10/2026
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