Department of Education notice clarifies ‘professional’ degree definition

A notice of proposed rulemaking (NPRM) clarified the Department of Education’s proposed definition of professional degrees for the purposes of graduate student loan limits.

Accounting is among a long list of degree programs — including nursing and engineering — that is not among the 11 fields of study proposed to be designated by the department as professional degree programs.

The NPRM, published Friday in the Federal Register, said, in part: “The department notes that the term ‘professional student’ as used in this [NPRM] is intended solely to distinguish those programs that we propose would be eligible for higher loan limits, as required by [H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act]. The designation, or lack thereof, of a program as ‘professional’ does not reflect a value judgment by the department regarding whether a borrower graduating from the program is considered a ‘professional.’ This NPRM only interprets the phrase ‘professional student’ as used in the context of the loan limits established by [H.R. 1].”

The NPRM is in response to legislation signed into law last summer that calls for the elimination of unlimited borrowing under the Graduate PLUS Program. Effective for loans made on or after July 1, 2026, the proposal would limit borrowing amounts for students in the 11 professional degree programs to an annual limit of $50,000 with an aggregate lifetime limit of $200,000.

All other graduate students would be subject to an annual limit of $20,500 with an aggregate lifetime limit of $100,000.

“Accounting is a critical part of our nation’s economic infrastructure and is a profession that has contributed significantly to our economic growth,” Mark Koziel, CPA, CGMA, president and CEO of the AICPA, said in a statement. “We appreciate the Department of Education’s recognition of the broad definition and various aspects of the word ‘professional.’ As the rulemaking process moves forward, the AICPA will continue to review the proposal, and we look forward to providing our suggestions and insights.”

In December, the AICPA joined other accounting organizations in sending a letter to Secretary of Education Linda McMahon that questioned the exclusion of the profession from the professional degree designation.

The 11 proposed “professional degree programs” are law, medicine, pharmacy, dentistry, chiropractic, optometry, osteopathic medicine, podiatry, veterinary medicine, clinical psychology, and theology.

The Department of Education is accepting comments on the notice through March 2.

— To comment on this article or to suggest an idea for another article, contact Bryan Strickland at Bryan.Strickland@aicpa-cima.com.