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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

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CMS Requires Providers to Use an Updated Advance Beneficiary Notice (ABN) Form by May 12, 2026

May 22, 2026CMS has released an updated Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131, that all providers and suppliers must begin using by May 12, 2026. The revised form includes clearer language and formatting updates intended to improve patient understanding and compliance.Client Alert

CMS and Ohio Ramp Up Fraud Enforcement in Home Health and Hospice

May 15, 2026CMS and Ohio have launched sweeping new fraud prevention initiatives targeting home health and hospice providers, signaling a period of heightened scrutiny for enrollment, billing, documentation, and EVV compliance. While aimed at combating fraud, these measures also create significant operational and due process risks for compliant agencies, making proactive compliance programs, auditing, and governance more important than ever.Client Alert

MYTH BUSTER: Can a New Chiropractor Bill Under An Established Chiropractor’s NPI?

May 14, 2026Many chiropractic practices mistakenly believe a newly hired chiropractor can bill under an established chiropractor’s NPI while waiting for credentialing approval. In most cases, this is not permitted. Claims should be submitted under the NPI of the chiropractor who actually rendered the service to avoid compliance risks, including potential False Claims Act exposure. This article outlines key billing rules, common exceptions, and practical compliance tips for chiropractic practices.Client Alert

RNs and APRNs Take Note: Ohio Board of Nursing Mandates a New CE Reporting Period

April 29, 2026Ohio’s Board of Nursing has updated the continuing education reporting period for RNs and APRNs. Beginning March 26, 2026, CE credits must be completed between July 1 and June 30 of odd-numbered years, replacing the previous November to October timeframe.
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