Submitted by Cheryl Dowd on
Federal Regulation

Definitions of Graduate Student and Professional Student Affecting Loan Limits

Description 

This regulation is developed to implement provisions in the One Big Beautiful Bill Act (OB3), enacted on July 4, 2025, which amended the Higher Education Act of 1965 to establish separate annual and aggregate loan limits for graduate and professional students. The statute defines a professional student as one enrolled in a program leading to a professional degree, as defined in 34 CFR 668.2, which indicates a designated group of programs, such as law, medicine, pharmacy, or theology. In contrast, graduate students are enrolled in programs leading to other types of graduate credentials, such as master’s or doctoral degrees in academic or research disciplines. This distinction significantly affects borrowing eligibility and total loan amounts, making the regulatory definition of a professional student a key issue in the current negotiated rulemaking process.

In the final days of the negotiated rulemaking, the U.S. Department of Education proposed a draft definition of a professional program that would include all programs already in the 34 CFR 668.2 list, as well as clinical psychology and any program that (1) requires a doctoral degree, (2) shares a four-digit Classification of Instructional Programs (CIP) code with a program already on the list, and (3) requires a license. The Department explained that clinical psychology fits within existing regulatory rationale and that this approach would add 44 additional degree programs within the same CIP codes.

The rulemaking committee reached consensus on all elements of the regulatory package, and the consensus language will be published as proposed regulations for public comment.

 

Action to be taken

  • Understand the effect of this change and its impact on the institution related to programs and loans.
  • Track the rulemaking process closely.
  • Share information across the institution to manage possible process changes.
  • Coordinate with associations to provide joint public comments, ensuring that any sector-wide concerns are represented.

Effective Date

  • Negotiated Rulemaking began in September 2025.

Resources

Regulation progress: Step 3 of 8

  1. Step 1 Notice of Intent to Establish a Rulemaking with Public Comment Period.
  2. Step 2. Negotiated Rulemaking Committee Nominations and Schedule of Committee Meetings with Public Nominations.
  3. Step 3. Negotiated Rulemaking Committee Meetings
  4. Step 4 Office of Management & Budget, Office of Information and Regulatory Affairs Review of Proposed Regulations
  5. Step 5 Notice of Proposed Rulemaking (NPRM) and Public Comment Period (release of proposed regulations)
  6. Step 6 Office of Management & Budget, Office of Information and Regulatory Affairs Review of Final Regulations
  7. Step 7 Release of Final Regulations
  8. Step 8 Effective Date