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Department of Education Proposes Redefinition of “Professional Degree,” Excluding Nursing and Limiting Graduate Loan Borrowing

Client Alert

In response to President Trump’s One Big Beautiful Bill Act (OBBBA), the U.S. Department of Education (the Department) recently announced several federal student-loan related changes, including redefining what the Department considers to be a “professional degree”. Nursing is one of several degrees excluded from the list.

The Department issued a Notice of Proposed Rulemaking for “Reimagining and Improving Student Education” on January 30, 2026. The public is invited to submit comments on the proposed rules by March 2, 2026. 

The professional degrees recognized under OBBBA are as follows:

  • 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.)
  • Theology (M.Div., or M.H.L.)

The Department also seeks to eliminate the Grad PLUS program that currently affords graduate students the ability to borrow up to the full cost of attendance. Students in professional degree programs will be limited to borrowing $50,000 per year with up to $200,000 over their lifetimes. Meanwhile, for students in graduate programs not deemed to be a “professional degree” program, the borrowing limits will be $20,500 per year with a $100,000 lifetime cap.

The Under Secretary of Education, Nicholas Kent, stated the proposed changes “will help drive a sea of change in higher education by holding universities accountable for outcomes and putting significant downward pressure on the cost of tuition.” Further, Under Secretary Kent believes “[t]his will benefit borrowers who will no longer be pushed into insurmountable debt to finance degrees that do not pay off.”

If you would like assistance drafting comments in support of, or in opposition to, the proposed changes, or you want to learn more about how the borrowing restrictions may impact you, please contact BMD Member Jeana Singleton at jmsingleton@bmdllc.com or Attorney Kate Crawford at khcrawford@bmdllc.com.


Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.

Top Compliance Risks for Ohio Med-Spas in 2025

The Ohio Board of Pharmacy has increased inspections of med-spas holding Terminal Distributor of Dangerous Drugs (TDDD) licenses, with many facing enforcement actions in 2025. Common issues include purchasing from unlicensed distributors, improper drug storage, inadequate recordkeeping, and insufficient prescriber oversight. Understanding these risks and maintaining compliance can help protect your practice from penalties and license suspension.

Pre and Postnuptial Agreements | Necessary, Maybe, What Happened to Forever?

Both Florida and Ohio now allow clients to enter into a prenuptial or postnuptial agreement prior to marriage or after marriage (Ohio previously did not allow postnuptial agreements). Both documents have statutory guidelines that must be followed in terms of execution and financial disclosure.

DHS Ends All Employment Authorization Auto-Extensions

Effective October 30, 2025, DHS ends all automatic work authorization renewals. The 540-day extension applies only to renewals filed before this date, and there is no grace period for expired EADs filed on or after October 30. Employers must audit EADs, train staff, ensure I-9 compliance, and plan for work authorization gaps. Penalties for noncompliance can be severe.

CMS’s Rural Health Funding Announcement

CMS has announced a $50 billion Rural Health Transformation (RHT) Program to improve healthcare access, quality, and outcomes in rural communities. All states are eligible to apply for funding by November 5, 2025. Half of the funds will be distributed equally, with the remainder based on state-specific factors. The program supports evidence-based initiatives, workforce recruitment, and access to treatment services, with awards assessed annually