ED: Professional Degree Programs Interim List to Include Nursing and More

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These changes come in response to a court order on the Reimagining and Improving Student Education (RISE) Final Rule.

The Department of Education (ED) on June 29, 2026, issued an updated interim list of programs treated as granting professional degrees in response to a court order relating to ED's Reimagining and Improving Student Education (RISE) final rule.

ED issued the RISE final rule on May 1, 2026, which implemented changes from HR 1 to federal student loan limits for graduate and professional degree programs. HR 1 established two tiers of loan caps: students enrolled in graduate programs may borrow up to $20,500 annually with a $100,000 lifetime limit, while students in programs classified as awarding a "professional degree" may access up to $50,000 annually and $200,000 total. Because the RISE final rule defines what constitutes a "professional degree," it directly affects which students qualify for the higher borrowing limits.

LeadingAge in March comments expressed concerns that the rule's approach to redefining "professional degree" would result in significant harm to the aging services workforce, as the definition excluded several critical fields, including nursing, physical and occupational therapy, physicians' assistants, and social work. The RISE final rule subsequently faced legal challenges in several federal district courts. On June 24, the U.S. District Court for the District of Columbia issued an order to preliminarily set aside and stay certain aspects of the definition of "professional degree" in the RISE final rule, while the case is being decided on its merits.

The ED, in turn, issued Electronic Announcement (GENERAL-26-42) Update to List of Professional Degree Programs Due to Court Order, which states that, for the duration of the court's preliminary stay, the department was treating an interim list of programs as awarding professional degrees for the purpose of administering statutory loan limits. This interim list of programs includes audiology/audiologist, speech-language pathology/pathologist, physical therapy/therapist, occupational therapy/therapist, physician associate/assistant, and registered nursing/registered nurse. The ED also provided a list of programs that are not considered programs that award professional degrees for the duration of the stay, which include geropsychology.

ED stressed that it will continue to defend the definition of "professional degree" in the RISE final rule and that "[t]hese interim administrative designations are provided solely to facilitate implementation of the Court's order and may change as litigation in the case proceeds." Additionally, the agency advised institutions "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."

LeadingAge will continue to monitor any developments relating to this litigation.