New RISE Neg Reg Issue Papers Reveal Revised Definition of Professional Student
By Maria Carrasco, NASFAA Staff Reporter
Shortly before the Reimagining and Improving Student Education (RISE) committee convened for its second session of negotiated rulemaking (neg reg), the Department of Education (ED) released a new round of issue papers on several provisions it seeks to implement, including adjustments to its definition of professional student.
The RISE committee first met in late September, with its goal of implementing several provisions of the One Big Beautiful Bill Act (OBBBA) by July 1, 2026. One of the outstanding issues brought up during the committee’s first session was the topic of new loan limits enacted under OBBBA and what this could mean for graduate and professional students and programs.
OBBBA created new annual and aggregate borrowing limits for each credential level. Currently, graduate and professional students are not treated differently under federal loan limits. However, under OBBBA, graduate students will face an aggregate cap of $100,000 with an annual limit of $20,500, while professional students will have a $200,000 aggregate limit and a $50,000 annual cap.
During the first week of negotiations in October, negotiators expressed many concerns about the definition of a professional student, including that the current definition is too limited. Although ED proposed a new interim definition of a professional student during the first session, the department stated it would revisit the issue during the second session meeting in November.
In the latest round of issue papers released by ED, the proposed definition of interim professional student is nixed.
As proposed in the issue paper, a professional student is a student enrolled in a program of study that awards a professional degree upon completion of the program.
A professional degree would be defined as “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, where professional licensure is also generally required, and includes the following degrees: Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), and Theology (M.Div., or M.H.L.).”
The latest proposal offers some additional information, but little clarity, on how student loans will be prorated for less than full-time enrollment. The committee’s upcoming session is likely to focus discussions on legacy provisions for Parent PLUS borrowers for undergraduate students who change majors, and whether certain health professions students can continue to receive the additional HEAL limits on top of the new annual unsubsidized loan limits.
The RISE committee is slated to meet in-person from November 3-7. Those interested can register to watch. Stay tuned to Today’s News for more updates on the RISE committee and negotiated rulemaking, including daily recaps on each day’s session.
Publication Date: 11/3/2025
Julia K | 11/19/2025 7:22:25 AM
What about MFTs? They are required to be licensed in order to practice.
Bee S | 11/3/2025 3:1:27 PM
How about Licensed Professional Counselors (LPC)? (Goes by different names in different states -- https://www.counseling.org/docs/default-source/licensure/appendix-f.pdf?sfvrsn=2e78562c_2&utm
Meredith S | 11/3/2025 12:26:39 PM
I am hopeful about health professions programs, like PA, PT and OT being classified as professional. I hope that our MPH students retain the HEAL extension on loan limits.
Jaime S | 11/3/2025 11:41:27 AM
I'd like to make an argument for Audiology. Entry level to the profession is an AuD degree, for which 4-years of graduate schooling is required. Students in these programs often incur debt comparable to other professional programs. This program is continually overlooked when it comes to loan limits. It would meet the definition stated above, but rarely is discussed.
Rachel E | 11/3/2025 11:12:53 AM
Why is Theology in this group? Everything else is a medical degree.
Janell V | 11/3/2025 10:38:18 AM
It could be out in left field, I believe providing a complete list of eligible programs is not what Dept of Ed is looking to do. Based upon the current definition, programs such as DPT, PA, and other like health professions would be considered eligible programs. Assistant Deputy Secretary Andrade in the last RISE session mentioned "health professions" and "licensure" in the same statement. I'm a Pollyanna, in the health professional student world, with fingers crossed on this one.
Perry D | 11/3/2025 10:6:59 AM
I agree with the DPT, and would also hope that a Physician's Assistant Degree might be included.
Brenda B | 11/3/2025 10:4:47 AM
What about a Physician Assistant ? PA ? (professional student?) I'd like more clarification on Social Work degrees also. and NURSING degrees (DPN) etc.
Brenda B | 11/3/2025 9:54:40 AM
I hope a Doctor of Physical Therapy (DPT) is included in the Prof. degree definition. (our students earn a DPT vs. a Medical Doctor (MD)
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