FAQs: What You Need to Know

These FAQs outline the current status of ED’s “professional degrees” proposal under OBBBA, its potential impact on student aid access, and key advocacy deadlines. Learn more about the issue.

Frequently Asked Questions

What is changing, and why is this relevant now?

Under the recently passed One Big Beautiful Bill Act (OBBBA), the U.S. Department of Education (ED) is redefining what counts as a “professional degree program.” The initial definition being advanced by ED’s RISE Committee excludes public health degrees (e.g., Master of Public Health (MPH), Doctor of Public Health (DrPH), and several other health professions degrees.

The Department of Education (ED) indicated that the change is part of a broader effort to standardize federal lending categories. According to an ED press release, Myth vs. Fact: The Definition of Professional Degrees, “Since 2007, graduate and professional students have been able to borrow up to the full cost of attendance. This has allowed colleges and universities to dramatically increase tuition rates, even for credentials with modest earnings potential, which has saddled too many borrowers with debts they find difficult to repay. The Act’s annual federal loan caps are already reining in inflated prices at graduate programs across the country.”

This matters because the classification affects eligibility for higher federal loan limits under OBBBA, potentially making public health degrees significantly more expensive for many students who rely on federal aid.

According to reports on the proposed OBBBA implementation, the new loan caps will take effect starting July 1, 2026.

What does “professional degree” mean under the new rules, and how is that different from today’s classification?

Under longstanding federal regulations (reflected in the Code of Federal Regulations (CFR)), a “professional degree” traditionally signified a credential that: (1) represented completion of the academic requirements for beginning practice in a given profession, (2) required a level of professional skill beyond a bachelor’s degree, often involving licensure, and (3) is generally associated with doctoral- or advanced-level education.

However, the new proposal from ED narrows the definition only to a limited set of fields listed as examples in the CFR, such as medicine, law, dentistry, pharmacy, etc., that would qualify. Many fields historically considered “professional,” including public health, nursing, social work, allied health, and others, would be excluded.

That means that under the proposed rule, a degree like an MPH or DrPH, which has historically been considered “professional” and intended to prepare practitioners, leaders, and workforce for public health practice, might now be treated as a standard graduate degree.

It is important to note that the proposed changes do not reflect a judgment of the value, importance, or rigor of public health degrees. Rather, the redefinition is purely regulatory, affecting eligibility for certain federal loan limits. ED itself has clarified that the new definition “has no bearing on whether a program is professional in nature or not.”

The exclusion is about loan policy, not a statement about the legitimacy or professionalism of public health degrees.

That said, many in the public health field, including ASPPH, argue that this redefinition undermines decades of precedent and jeopardizes the public health workforce pipeline.

Which degrees are currently designated “professional,” and which are excluded under the new draft definitions?

Included (as “professional degree”):

Chiropractic Medicine (D.C.)
Clinical Psychology (Psy.D., Ph.D.)
Dentistry (D.D.S., D.M.D.)
Law (J.D., L.L.B.)
Medicine (M.D.)
Optometry (O.D.)
Osteopathic Medicine (D.O.)
Pharmacy (Pharm.D.)
Podiatry (D.P.M., Pod.D.)
Theology (M.Div., M.H.L.)
Veterinary Medicine (D.V.M.)

Excluded (or at risk):

Public health (MPH, DrPH)
Nursing (MSN, DNP), allied-health, social work, physician assistant, occupational/physical therapy, certain education and therapy master’s/phd degrees, among others.

Because the definition relies on a narrow enumerated list plus the Classification of Instructional Programs (CIP)-code rubric, many non-included fields risk defaulting to the lower “graduate” loan tier.

What will happen to federal student loans for public health students if the proposal becomes final?

If public health degrees (e.g., MPH, DrPH) are excluded from the “professional degree” category:

Students would no longer be eligible for the higher loan caps reserved for “professional” students.
Instead, they would be subject to the lower “graduate student” loan limits under OBBBA: $20,500 per year and a lifetime aggregate limit of $100,000.
By contrast, students in programs that are designated “professional” would have access to $50,000 per year and up to $200,000 total.

Because the program eliminates Grad PLUS loans, a funding source many graduate students rely on, the reclassification effectively reduces the amount of federal funding available to many public health students. And since most MPH and DrPH students currently rely on borrowing levels well above the graduate caps, the policy could sharply restrict access to affordable loans.

This could lead to increased reliance on private loans or alternative funding sources, or force students to scale back or delay their education.

Will this affect current students or only future cohorts?

The latest proposal would apply beginning July 1, 2026, meaning:

Students already enrolled in MPH/DrPH programs could lose access to loan amounts they anticipated when starting their degree.
Students starting after July 2026 would be fully subject to the lower limits.

ASPPH is advocating for transitional protections and for public health degrees to remain classified as professional

How much do public health students currently borrow?

A 2024 ASPPH study, “Federal Student Loan Debt in Public Health and the Opportunities for Loan Repayment Programs,” found that the median federal student loan debt among public health graduates was US$ 33,366.

The study (based on 2018–2019 data) used national datasets (IPEDS + NCES / College Scorecard) to estimate that result as representative across degree levels (bachelor’s, master’s, doctoral) for public-health awardees.

Will students be forced to take private loans?

Possibly, yes.

If federal borrowing no longer covers tuition and living expenses, students may need to seek additional funding sources, such as:

Private education loans, which typically have higher interest rates and fewer repayment protections
Institutional scholarships
Employer tuition support
Part-time enrollment
Fellowships or assistantships

What could be the broader consequences for students, public health programs, and the workforce?

According to public health advocates:

Excluding public health degrees from the “professional” classification would limit access to federal financial aid, making public health education less accessible, particularly for students from low-income or historically excluded backgrounds.
This could reduce enrollment in MPH, DrPH, and related programs, especially at institutions serving rural or underserved communities.
Over time, this poses a risk to the public health workforce pipeline, undermining the ability to train the professionals needed to respond to public health emergencies, chronic disease, health inequities, environmental health threats, and more.
It could particularly affect diversity, equity, and inclusion efforts: higher financial barriers may disproportionately deter students from underrepresented backgrounds from entering public health.

Will this increase inequities in public health education?

Very likely.

Barriers include:

Reduced affordability for low-income students
Fewer students able to attend full-time
Greater obstacles for students without family financial support
Potential decreases in racial, ethnic, socioeconomic, and geographic diversity within the profession

What should students and members do now, or what should they know while this is being decided?

Stay informed: The proposed definition is not yet final. The RISE Committee’s recommendation will lead to a Notice of Proposed Rulemaking (NPRM), followed by a public comment period. Once the NPRM is posted, we recommend submitting comments to ED. Stay informed through ASPPH updates.

Consider adding your voice: As a member or student, you can support advocacy efforts by writing to your Congressional representatives, participating in public comment when the NPRM is released, or joining coalition and social media efforts through ASPPH and related organizations. Share your personal stories with ASPPH to help strengthen advocacy materials.

Explore alternative funding options: Scholarships, institutional aid, private scholarships, work–study or employment-based funding, employer tuition support, or part-time enrollment might become more important.

What’s the status of the rulemaking process and the timeline — is this final, or could things still change?

As of late November 2025, the RISE Committee reached a preliminary consensus on the list of professional-degree programs and classification rubric.
A formal Notice of Proposed Rulemaking (NPRM) is expected in early 2026; once issued, there will be a public comment period, during which institutions, students, and other stakeholders can submit feedback.
Because the classification is not yet final, there remains a window for advocacy and possible revision before the changes take effect (projected July 1, 2026).

Next Step	Expected Timing
ED provides rationale & updates to Congress	Within 1 month of congressional inquiry (pending)
Notice of Proposed Rulemaking (NPRM)	Early 2026
Public comment period	30 days after NPRM
Final rule	By July 1, 2026
Loan cap changes take effect	July 1, 2026