Department of Education Issues RISE Final Rule

[Originally Published on Alliance Daily] On April 30, 2026, the Department of Education (DOE) released the final rule titled Reimagining and Improving Student Education (RISE), which largely finalizes the professional degree definition as proposed in the January Notice of Proposed Rulemaking (NPRM). Notably, the final rule does not expand the definition of professional degree to include Master of Science in Nursing (MSN), Doctor of Nursing Practice (DNP), Doctor of Physical Therapy (DPT), Master of Science in Occupational Therapy (MSOT), Doctor of Occupational Therapy (OTD), Master of Social Work (MSW), Doctor of Social Work (DSW), or Master of Science in Physician Assistant Studies (MSPAS) programs.

The One Big Beautiful Bill Act (OBBBA) – now referred to in the final rule as the Working Families Tax Cuts Act – established a federal student loan structure that distinguishes between graduate and professional students and cross-references the existing regulatory definition of professional degree at 34 CFR § 668.2 as in effect on the date of enactment. That regulation contains a three-part operative test to qualify as a professional degree: (1) completion of academic requirements for beginning practice in a given profession, (2) professional skill beyond a bachelor’s degree, and (3) professional licensure is generally required. This includes, but is not limited to, an illustrative list of nine degree examples: 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.), and Theology (M.Div., or M.H.L.).

In the NPRM, the DOE applied that definition to recognize these degree programs with the addition of clinical psychology, but excluded nursing, physical therapy, occupational therapy, advanced social work, and physician assistant advanced degree programs. See the Alliance’s prior coverage of the NPRM. In our March 2026 comment letter, the Alliance urged the DOE to adopt a broader definition of professional degree that encompasses post-baccalaureate healthcare degree programs in nursing, physical therapy, occupational therapy, social work, and physician assistant studies.

The final rule maintains the NPRM’s list of qualifying professional degrees: Pharmacy (PharmD), Dentistry (DDS/DMD), Veterinary Medicine (DVM), Chiropractic (DC/DCM), Law (JD/LLB), Medicine (MD), Optometry (OD), Osteopathic Medicine (DO), Podiatry (DPM), Theology (MDiv/MHL), and Clinical Psychology (PsyD/PhD). The final rule also continues to exclude advanced nursing, physical therapy, occupational therapy, advanced social work, and physician assistant degree programs. Specifically, the DOE is codifying the professional student classification at 34 CFR § 685.102, incorporating a four-digit Classification of Instructional Programs (CIP) code and defining this as follows:

Professional student: A student enrolled in a program of study that awards a professional degree upon completion of the program;

(i) A professional degree is a degree that:

(A) 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;

(B) 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;

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

(D) 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 (ii)(A) of this definition.

(ii) A professional degree may be awarded in the following fields: (A) 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.), and Clinical Psychology (Psy.D. or Ph.D.).

Beginning July 1, 2026, graduate students will be capped at $20,500 annually with a $100,000 aggregate limit, while professional students will be eligible for up to $50,000 annually with a $200,000 aggregate cap. Separately, the OBBBA terminates eligibility for Grad PLUS loans for all graduate and professional students for any period of instruction beginning on or after July 1, 2026, which means the professional classification is the only pathway to higher federal borrowing limits for affected students. The Alliance is concerned this could result in downstream consequences for the care at home workforce.