With Republicans’ massive spending and tax bill, known as the One Big Beautiful Bill Act, set to take effect this summer, the U.S. Department of Education is tasked with crafting regulations that will fill in some of the details of the law’s enforcement.
Those details could have big consequences for colleges and students. Among them is what graduate programs the department will consider “professional,” a designation that will qualify enrolled students for larger loans under new federal lending caps.
The issue has been contentious since the Education Department agreed on regulatory language that would limit “professional” programs to 11 fields, excluding certain graduate programs that often require licensure including education.
The department acknowledged the controversy in the formal proposal, released in late January. Its summary stated that the designation “does not reflect a value judgment by the Department regarding whether a borrower graduating from the program is considered a ‘professional.’”
Rather, the department added, it “only” interprets the term for the purpose of applying the new loan limits.
But that’s a pretty big “only.” The difference for students deemed “professional” and those deemed “graduate” is the availability of an additional $100,000 in federal student loans for their education. That’s because the cap for professional students — $200,000 — is double that of graduate students under OBBBA’s lending limits.
The public comment period for the proposal ended Monday. The proposal and others tied to OBBBA’s implementation drew roughly 65,000 comments. The Education Department is required to review all comments before issuing final regulations.
Many commenters expressed concerns that the regulations' narrow definition of “professional student” could limit entry into critical professions by dramatically reducing the aid available, which could in turn have workforce ramifications.
Concerns over the education field
In a public comment, American Association of Colleges for Teacher Education President Cheryl Holcomb-McCoy called for the Education Department to expand the definition of a professional student to include those pursuing post-baccalaureate degrees and certificates in education. She added that reduced borrowing limits for part-time graduate students will also worsen shortages in key positions like special educators and school administrators.
“We seek this change to address significant affordability concerns for education students and to counter the negative message that their exclusion sends about the professionalism of teachers, school administrators, specialized instructional support personnel, and other educators,” Holcomb-McCoy said.
Holcomb-McCoy also pointed to the proposed rule’s justification for excluding education as a professional degree. Specifically, the proposal said the Education Department determined that education master’s and doctoral degrees “are not required for entrance into a specific profession and are not required for licensure,” such as teaching.
The department’s interpretation that education is a singular profession with classroom teachers being the entry level for all roles is “incorrect,” Holcomb-McCoy said.
“The broad field of education includes many professional roles that do not have teaching as a mandatory prerequisite and that require a graduate degree for licensure and/or hiring,” she said. Some of those positions include licensed school counselors, principals and superintendents — all of which require a graduate degree.
AACTE’s public comment was also submitted on behalf of several K-12 education groups including the Association of School Business Officials and AASA, The School Superintendents Association.
The Education Department told K-12 Dive in December, citing its own data, that 90% of education graduate students borrow below the annual loan limit and would not be impacted by the proposed loan caps.
Excluded professions
The Education Department and Republican backers of the new law say the loan caps will reduce excessive student borrowing and force colleges to reduce their costs.
At a recent higher education conference in Washington, D.C., Under Secretary Nicholas Kent, the top Education Department official overseeing higher education, said OBBBA’s policies would put “downward pressure on colleges to lower costs, increase efficiencies and prioritize high-quality programs.”
But many stakeholders worry the law’s lending limits will limit access to education.
In a memo to stakeholders about commenting on the rules, the American Council on Education called the Education Department’s proposal an “extremely narrow definition of professional degrees” that doesn’t align with the “much broader definition” included in the OBBBA and excludes “hundreds of thousands of students from additional loan eligibility.”
According to ACE, 28% of all student loan borrowers require amounts exceeding the new lending limits.
“Forcing students out of the many professional degree programs that exist outside of the 11 programs will have a detrimental impact on student loan borrowers,” ACE President Ted Mitchell said on behalf of over three dozen other higher education organizations in a comment to the Education Department filed Monday. “This problem is most acute for professional programs in fields such as health, education, architecture, and business administration.”
The organizations flagged 17 additional fields for the department that they believed should be deemed “professional” based on stakeholder feedback, including nursing, physician assistance, audiology, physical therapy, public health, social work, architecture, accounting and special education.
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