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

Client Alert
February 20, 2026

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.

HealthcareEducationJeana SingletonKate Crawford
Client Alert

Expanding Access to Care: Ohio’s Effort to Modernize APRN Practice Through Ohio SB 258 and HB 508

October 24, 2025Ohio is moving to expand access to healthcare through Senate Bill 258 and House Bill 508, which would modernize APRN practice by removing the outdated requirement for a physician contract. This change would allow nurse practitioners, nurse midwives, and clinical nurse specialists to provide care more efficiently, especially in underserved areas, while maintaining high-quality, cost-effective care.Client Alert

Cleveland Joins the Pay Transparency Movement: What Employers Need to Know

October 21, 2025Beginning October 27, 2025, all Cleveland employers with 15 or more employees will be prohibited from asking applicants about their pay history and will be required to include reasonable pay ranges in all job postings where the position will be performed, solicited, considered, or processed in Cleveland. The ordinance is intended to help close the gender wage gap and promote greater pay equity across the city.Client Alert

New $100,000 Fee on H-1B Petitions – Legal Immigration

September 23, 2025President Trump issued an Executive Order (EO) imposing a $100,000 payment to accompany any new H-1B visa petitions submitted after 12:01 a.m. eastern time on September 21, 2025 and will remain in place for 12 months (unless extended).Client Alert

Implications of Supreme Court Stay for Business Operations in Noem v. Vasquez Perdomo

September 16, 2025On September 8, 2025, the U.S. Supreme Court temporarily reinstated immigration officers’ authority to conduct brief stops based on factors such as location, work type, language, or appearance. This stay in Noem v. Vasquez Perdomo allows enforcement actions to resume in California pending appeal. Employers in industries like construction, agriculture, landscaping, and day labor should prepare for increased worksite disruptions and review compliance protocols.Client Alert

Ohio House Bill 429: Potential Relief for Providers Facing Same-Day Reimbursement Restrictions

September 15, 2025Ohio House Bill 429 aims to prevent third-party payers from reducing provider reimbursement for multiple procedures performed on the same day. The bill could improve payment practices for a range of specialties, including surgery and gastroenterology.
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