On June 24, 2026, the U.S. District Court for the District of Columbia stayed portions of the Department of Education’s narrowed definition of “professional degree” under the RISE Final Rule. The court concluded that when Congress incorporated the prior three-part definition “as in effect on July 4, 2025,” it removed the Department’s authority to narrow that definition. Practically, this restores the statutory three-part standard, rather than the Rule’s narrowed approach, while the litigation continues. The immediate effect is two-fold.

First, the three-part test from the prior rule is once again the operative standard: a professional degree (1) signifies completion of academic requirements to begin practice in a profession; (2) signifies a level of professional skill beyond a bachelor’s degree; and (3) generally requires professional licensure.

Second, the stay leaves undisturbed the 11 enumerated fields the Department already recognizes as professional, so those programs remain definitively professional. The rest of the RISE Final Rule remains in effect, including the elimination of Grad PLUS and the new annual and aggregate loan limits and repayment plans effective July 1, 2026.

In response to the court’s order, Federal Student Aid issued an Electronic Announcement identifying programs that, for the duration of the stay, the Department will treat as awarding professional degrees for loan-limit purposes. These interim designations are expressly temporary and subject to change as the litigation proceeds. In addition to the 11 long-recognized fields, the Department is, for now, treating several other programs as professional:

  • Audiology (AuD)
  • Speech-Language Pathology (SLP)
  • Certified Anesthesiologist Assistant (CAA)
  • Physician Associate/Assistant (PA/MSPA)
  • Athletic Training (MSAT/MAT)
  • Occupational Therapy (OT/MSOT/OTD)
  • Physical Therapy (PT/DPT)
  • Select graduate nursing degrees such as
    • Registered Nursing (MSN)
    • Nursing Practice (DNP)
    • Nurse Anesthetist (DNAP)

The Department clarified that the Registered Nursing/Registered Nurse (MSN) and Nursing Practice (DNP) designations extend to any program within the same four-digit CIP, provided it awards the same credential, and it confirmed that Clinical Psychology includes the Ph.D. designation. At the same time, certain theology/theological studies and applied psychology subfields and several pharmacy-science CIPs are not treated as professional under the interim list.

Institutions should use the Department’s interim list to determine loan limits. For programs on that list, schools may treat students as professional for the $50,000 annual/$200,000 aggregate caps; for programs not listed, the graduate caps ($20,500 annual/$100,000 aggregate) continue to apply unless and until the Department updates its guidance. When originating and disbursing for programs on the interim list, schools should report professional academic levels in COD using the applicable Professional Grade Level codes (10, 11, or 13). After a loan is reported at a professional level, NSLDS will reevaluate aggregate usage and may generate post-screening transactions reflecting the borrower’s updated limit status.

The Department has also reminded institutions that, beginning July 1, 2026, they may set program-level limits. Given the fluid litigation posture, some institutions may consider temporarily limiting borrowing to graduate-level caps for programs that are only temporarily treated as professional to reduce the potential for disruption if classifications change. If a program is later removed from the interim list, the Department has indicated that amounts already disbursed at the higher limit need not be adjusted; however, subsequent disbursements must be made at graduate-level caps, and all borrower eligibility requirements must be reverified in light of aggregate usage. Institutions should communicate these developments clearly to current and prospective students. For students in the 11 enumerated professional fields, nothing has changed; they remain eligible for the higher loan limits. For students in other programs—especially nursing, therapy, and behavioral health—eligibility at the professional caps depends on ongoing Department action. Schools should avoid promising outcomes or timelines, advise students to proceed with their established funding plans, and commit to providing updates as further guidance issues. Looking ahead, the Department stated that additional degree determinations under the three-part test could be made relatively quickly, but no specific timeline was provided.

Institutions should monitor FSA Partner Connect and StudentAid.gov for updates. HEAG will continue to track developments and provide timely guidance. This blog is for informational purposes only and does not constitute legal advice. Institutions should consult counsel regarding program-specific implementation.