(GENERAL-26-42) Update to List of Professional Degree Programs Due to Court Order (Updated July 10, 2026)

The purpose of this Electronic Announcement is to identify the list of Classification of Instructional Programs (CIP) Codes that are designated as professional degree programs for reporting Title IV loan originations and disbursements to the Common Origination and Disbursement (COD) System. On June 24, 2026, the U.S. District Court for the District of Columbia, in consolidated cases Nos. 26-1780, 26-1941, preliminarily stayed part of the U.S. Department of Education’s (the Department’s) professional degree definition contained in the Reimagining and Improving Student Education (RISE) Final Rule published in the Federal Register on May 1, 2026. Although the Department is confident that the professional degree definition in the RISE Final Rule is lawful and will continue to defend it, we are nonetheless, for the duration of the Court’s preliminary stay, based on the Department’s understanding of the Court’s ruling, treating the programs listed below as awarding professional degrees for the purpose of administering statutory loan limits. These interim administrative designations are provided solely to facilitate implementation of the Court’s order and may change as litigation in the case proceeds.

The vast majority of the RISE Final Rule is unaffected by the Court order and will take effect on July 1, 2026, including the elimination of the Grad PLUS program, the establishment of new annual and aggregate loan limits for graduate and professional students, and the creation of two new repayment plans: the Repayment Assistance Plan and the Tiered Standard Repayment Plan.  

The RISE Final Rule defined a professional student, in 34 CFR 685.102, in part, as a student enrolled in a program of study that awards a professional degree upon completion of the program. This provision of the regulation is not affected by the Court order.

However, the Court order preliminarily sets aside and stays the following elements contained in paragraph (i) of that definition, codified in 34 CFR 685.102(b), defining a professional degree as one that:

The professional degrees in the 11 fields listed in paragraph (ii)(A) of the professional student definition are also unaffected by the Court’s order.

During the period of the Court’s stay and consistent with the Court’s order and construction of 20 U.S.C. § 1087e(a)(4)(C)(ii), which is different than the Department’s construction of that provision as proposed in the RISE Final Rule, the following programs will be treated as awarding professional degrees for the duration of the Court’s stay. Such programs must award the degree in parentheses to qualify for this designation.

*Includes any program within the same four-digit CIP code, as assigned by the institution or determined by the Secretary, provided it awards the same credential. 

Due to the Court’s stay and based upon its construction of 20 U.S.C. § 1087e(a)(4)(C)(ii), which is different than the Department’s construction of that provision as proposed in the RISE Final Rule, the following programs are not considered programs that award professional degrees for the duration of the stay.

Depending on a borrower’s loan history, most borrowers will be prescreened or postscreened at the graduate loan limit. Financial Aid Administrators can review the National Student Loan Data System (NSLDS^®) Professional Access website to determine the borrower’s progress toward any of the aggregate loan limits. If a borrower has exceeded their graduate aggregate limit and they are eligible for the professional loan limit, institutions may clear the C Flag and process aid using the higher professional loan limit.

In order to originate and disburse loans at the higher loan limit for professional students during the period covered by the Court order, institutions will report one of the following Professional Grade Levels in the Student Level Code field when reporting a loan to the COD System:

If an institution previously originated and/or disbursed a loan for award year 2026–27 in COD using a graduate academic level for these programs, the institution can (1) update the student level code for the existing loan to reflect one of the applicable professional level codes and increase the loan/disbursement amount to match the professional annual loan limits; or (2) originate a new loan using one of the applicable professional level codes for the difference between the graduate and professional loan limit amounts.

After a loan is originated and/or disbursed using a professional academic level, the academic level information is reported to NSLDS by the federal loan servicer. NSLDS will then reevaluate the borrower's aggregate loan limit usage and, if applicable, generate a postscreening transaction when the updated information results in a change to the borrower's aggregate limit status, either causing the borrower to no longer exceed the applicable aggregate limit or causing the borrower to exceed the applicable aggregate limit.

As the Department announced on Friday, June 26, 2026, under the Working Families Tax Cuts Act, institutions may set program-level limits for federal student loans beginning July 1, 2026. During the pendency of the ongoing litigation, institutions may wish to consider, for programs now temporarily classified as awarding professional degrees pursuant to the Court’s order, limiting loan amounts to the graduate-level caps to mitigate potential disruption to student borrowers resulting from changes in program classification that may arise from the ongoing litigation.

If an institution has made a disbursement on a loan associated with one of the programs that are temporarily removed from the list at the higher loan limit prior to the publication of this Electronic Announcement, the institution is not required to adjust the amounts already disbursed; however, the institution is not permitted to make subsequent disbursements at the higher limit. Any subsequent disbursements must be reported with the applicable graduate grade level. Additionally, all borrower eligibility requirements must be met at the time that the subsequent disbursements are made. For example, if a borrower exceeds the aggregate limit based upon receiving the professional-level disbursement, then they would not be eligible for additional disbursements or loans as a graduate-level borrower.  

Institutions should check the One Big Beautiful Bill Act Information page for more detailed guidance on loan limit eligibility. Further adjustments may follow once the litigation concludes.

Information for students and borrowers about the preliminary Court order is available on:

We will continue to update both pages promptly when new information becomes available.