Professional Degrees and Student Loans

Action: The Administration is considering narrowing the number of graduate degrees that qualify for higher student loan limits available to “professional degree” students.

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The recently passed Public Law 119-21 (H.R. 1, 2025), also referred to as the ‘One Big Beautiful Bill Act or OBBBA, eliminated the Graduate PLUS student loan program, which had allowed graduate students to borrow up to the cost of attendance. Instead, the law folded lending for graduate and professional programs into the general student loan program and established annual borrowing limits of $20,500 for graduate students and $50,000 for professional students. The law also established aggregate limits of $100,000 for graduate students and $200,000 for professional students.
OBBBA defines “professional students” as those enrolled in professional programs as defined by regulation 34 CFR 668.2(b) – “A degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor's degree. Professional licensure is also generally required.”
In September, the Department of Education (ED) convened a negotiated rulemaking committee to implement several OBBBA provisions, including the professional degree loan limits. In ED’s latest proposal, just eleven degree programs would qualify for the higher loan limits, excluding programs such as nursing, occupational therapy, special education, public health, and social work, many of which require licensure in most or all states. (Negotiated rulemaking is an alternative form of procedure to the more typical notice-and-comment regulations.)
Several professional organizations have expressed concern about the impact that the lower loan limits could have on student access and affordability. However, ED has responded that loan limits are needed to reduce climbing tuition prices and student loan debt.
ED plans to finalize the new requirements in early 2026 with a July 1, 2026 effective date.
What this means for business: Several of the occupations excluded from ED’s proposed definition of “professional degree” are experiencing severe labor shortages, including nursing. Critics of the proposal argue that lower loan limits will make it harder for students to afford these programs, which could exacerbate the shortage. However, ED has countered that 95% of nursing students, for example, borrow below the lower loan cap and would not be affected. Still, the provision raises questions for the health care industry about nursing shortages and for employers about shortages leading to rising costs of care. As many state legislative sessions begin in January, for workforce planning, companies should also track any changes to state licensure provisions for trades and professions, including possible removals of requirements or recognition of out-of-state credentials.

Professional Degrees and Student Loans

December 03, 2025

Action: The Administration is considering narrowing the number of graduate degrees that qualify for higher student loan limits available to “professional degree” students.

Trusted Insights for What's Ahead^®

The recently passed Public Law 119-21 (H.R. 1, 2025), also referred to as the ‘One Big Beautiful Bill Act or OBBBA, eliminated the Graduate PLUS student loan program, which had allowed graduate students to borrow up to the cost of attendance. Instead, the law folded lending for graduate and professional programs into the general student loan program and established annual borrowing limits of $20,500 for graduate students and $50,000 for professional students. The law also established aggregate limits of $100,000 for graduate students and $200,000 for professional students.

OBBBA defines “professional students” as those enrolled in professional programs as defined by regulation 34 CFR 668.2(b) – “A degree that signifies both completion of the academic requirements for beginning practice in a given profession and a level of professional skill beyond that normally required for a bachelor's degree. Professional licensure is also generally required.”

In September, the Department of Education (ED) convened a negotiated rulemaking committee to implement several OBBBA provisions, including the professional degree loan limits. In ED’s latest proposal, just eleven degree programs would qualify for the higher loan limits, excluding programs such as nursing, occupational therapy, special education, public health, and social work, many of which require licensure in most or all states. (Negotiated rulemaking is an alternative form of procedure to the more typical notice-and-comment regulations.)

Several professional organizations have expressed concern about the impact that the lower loan limits could have on student access and affordability. However, ED has responded that loan limits are needed to reduce climbing tuition prices and student loan debt.

ED plans to finalize the new requirements in early 2026 with a July 1, 2026 effective date.

What this means for business: Several of the occupations excluded from ED’s proposed definition of “professional degree” are experiencing severe labor shortages, including nursing. Critics of the proposal argue that lower loan limits will make it harder for students to afford these programs, which could exacerbate the shortage. However, ED has countered that 95% of nursing students, for example, borrow below the lower loan cap and would not be affected. Still, the provision raises questions for the health care industry about nursing shortages and for employers about shortages leading to rising costs of care. As many state legislative sessions begin in January, for workforce planning, companies should also track any changes to state licensure provisions for trades and professions, including possible removals of requirements or recognition of out-of-state credentials.

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