By Maria Carrasco, NASFAA Staff Reporter

Amid much debate over the definition of professional student, degree, and other key student aid provisions, negotiators of the Reimagining and Improving Student Education (RISE) committee on Thursday reached consensus on the entire package of 17 proposals by the Department of Education (ED) related to changes enacted under the One Big Beautiful Bill Act (OBBBA). 

Thursday morning’s session primarily focused on ED’s latest proposed definition of professional student and degree, with Under Secretary of Education Nicholas Kent joining the committee. On Wednesday, ED proposed defining a professional degree as: 

“(i) 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:

(ii) Is generally at the doctoral level, and that requires at least six academic years of postsecondary education coursework for completion, including at least two years of post-baccalaureate level coursework:

(iii) Generally requires professional licensure to begin practice; and

(iv) Includes a four-digit program CIP code, as assigned by the institution or determined by the Secretary, in the same intermediate group as the fields listed in paragraph (2) (i) of this definition.”

Negotiators had many questions on Wednesday on which higher education programs would qualify as a professional degree, and ultimately the higher annual and aggregate unsubsidized loan limits set in OBBBA.

On Thursday, Kent was joined by an official from the Office of the Chief Economist, who gave a slideshow presentation to answer some of the negotiators’ questions from the day before. In the slideshow, ED listed potentially eligible 6-digit CIP codes, along with additional statistics. 

Notably, ED’s analysis found that there are over 2,000 individual doctoral programs that have a 6-digit CIP code that falls within ED’s proposed definition for professional degree, and over 440,000 Title-IV-eligible students currently attend programs within those CIP codes. ED’s analysis also covered how the department’s previous proposals to define a professional student compare in the number of programs that could potentially be considered “professional degrees,” how many students would be considered a “professional student,” annual loan disbursements to these programs, and more.

The number of potentially eligible professional degree programs and professional students is significantly reduced, however, when the additional criterion of leading to licensure is factored in, with the 2,000 potentially-eligible programs dropping to roughly 650. Programs would also have to include at least 6 years of postsecondary study, which will further reduce the number of eligible programs. 

Kent noted that the definition of professional student, and ultimately the new loan limits set in the OBBBA, are a serious issue for students, families, and the American taxpayer, and thinks ED’s newest definition is a “fair proposal.”

“I want to reiterate this is, you know, by far not the perfect proposal,” Kent said. “We have a really challenging job in front of us, but I think what we did in our proposal is to meet you all at least halfway.” 

Kent also took time to answer questions brought to the department prior to Thursday’s meeting. For example, some negotiators had concerns that clinical psychology programs could be excluded from the professional program loan limits. Bringing this concern back to the department, Kent said that the department will write in the preamble of its regulation that a Ph.D in psychology must prepare a student for professional licensure to qualify for the professional-level limits since, in many states, the clinical psychology Ph.D is often the program that prepares students for professional practice. 

Another concern negotiators voiced within this new definition was that ED could be penalizing shorter term baccalaureate degrees that may be connected to doctoral programs. Kent said there may be some flexibility with ED, with the department possibly being amenable to removing the six-year reference. 

Following up from a conversation from Wednesday, ED also added language to the institutionally-determined loan limits section of the regulatory text to specify that, for those purposes, a program of study means an eligible program. This change was made in response to concerns that ED was defining program of study for legacy Parent PLUS eligibility as essentially the credential level, which could lead to confusion as to whether institutions could limit loans by major. ED felt that adding reference to the existing definition of eligible program would help institutions to limit loans by major. 

After lunch, the RISE committee reconvened to do a “pulse check” to see where negotiators stood on consensus. Before the “pulse check,” Kent reminded negotiators that they didn’t necessarily have to love the proposed definition of professional student, but rather be able to “live with it.” He noted that if the committee did not reach final consensus on this provision, ED will reevaluate its entire proposal on the definition of professional student – meaning ED could tweak its current proposal, go back to the original definition of professional student, or create something new entirely, without input from negotiators. 

While some negotiators held a thumbs up in support of ED’s new definition, there was still hesitation from negotiators who held their thumb sideways during this pulse check, but ED aimed to move the committee closer to consensus. 

“We believe we have developed a proposal that is logical, that can withstand legal scrutiny,” Kent said. “We believe this is a good proposal, and we hope that you will be able to support it again. You don't have to love it, but you can live with it.”

Thursday’s session also touched on other outstanding questions and provisions. Earlier this week, the committee discussed concerns about how the calculation of monthly student loan payments under the new Repayment Assistance Plan (RAP) would impact two borrowers who are married and file joint tax returns. 

Tamy Abernathy, ED’s federal negotiator, said ED is adding language that the monthly payment amounts calculated for each borrower will be proportional to their outstanding loan balance as compared to the couple’s joint indebtedness. If a borrower's adjusted monthly payment is calculated less than $10, the monthly payment will be $10. 

ED addressed other concerns negotiators raised about the RAP specific to Public Service Loan Forgiveness (PSLF), including that periods of time students spend in deferment or forbearance that would count toward forgiveness under other plans will not count under RAP. ED also clarified that borrowers enrolled in RAP would not be able to take advantage of the buy back for time spent in deferment or forbearance. 

The committee also held “pulse checks” on other provisions proposed by ED, including the loan limits issue paper and fixed payment repayment plans issue paper, in which all negotiators raised a thumbs up. 

Toward the end of Thursday's session, Abernathy said that the department would be conducting a consensus check today, one day earlier than planned, over the entire package of 17 proposals created by ED. The committee met for an hour to read through the entire package. Returning from that hour break, ED noted that minor, technical changes would be made to the final package.

Ultimately, the RISE committee reached consensus on the entire package of proposals. All negotiators held a thumbs up during the consensus check except Bob Carey, a negotiator representing student loan borrowers who are veterans, who abstained from the check. 

Kent thanked negotiators for their hard work during the entire process. 

“I have been a part of many negotiated rule makings over the years, and without a doubt, this has been the most collegial group that I have ever seen,” Kent said. “I sincerely appreciate how you've embraced my call to collaborate, to engage and to debate, remaining receptive to differing perspectives and resisting the urge to dig in on opposing views.”

From here, the department must now work to publish its Notice of Proposed Rulemaking (NPRM), which Kent said will be published “early next year.”

Next month, another negotiated rulemaking committee is set to meet to discuss other provisions enacted under OBBBA, the Accountability in Higher Education and Access through Demand (AHEAD) committee. They are set to meet December 8-12, though it is unclear how the government shutdown, if it continues, could impact this session. Kent noted that negotiators for the AHEAD committee were notified on Thursday of their selection. 

Stay tuned to Today’s News for more updates on this negotiated rulemaking session and read our previous recaps. 

Publication Date: 11/7/2025

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