Occupational therapy included on interim list of “professional degree” programs
Snapshot
On June 29th, the Department of Education (ED) released a new, interim list of Classification of Instructional Programs (CIP) codes designated as “professional degree” programs for purposes of new caps on federal graduate student loans scheduled to take effect on July 1, 2026.
Occupational therapy's CIP code (51.2306) is included on this interim list of “professional degree” programs, meaning students enrolled in a program pursuing an MSOT or OTD degree will be eligible to borrow up to $50,000 per year and up to $200,000 in total as of July 1st. Under ED's initial rule, occupational therapy was classified as a “graduate program,” which would have limited loans to $25,000 per year and $100,000 in total. While this change is a significant win, this new list is not permanent and may change as litigation continues.
Background
The interim list was developed in response to a June 24th ruling by the U.S. District Court for the District of Columbia, which issued a preliminary stay of certain requirements in ED's RISE final rule governing professional degree designations. The court found that Public Law 119-21 establishes only three criteria for determining whether a program qualifies as a professional degree program:
- The degree signifies “completion of the academic requirements for beginning practice in a given profession”;
- The degree signifies “a level of professional skill beyond that normally required for a bachelor’s degree”; and
- Licensure is “generally required”.
The court temporarily halted additional requirements imposed by the RISE rule, including requirements that the professional degree:
- Be at the doctoral level;
- Require six years of post-secondary coursework;
- Fall within specified CIP code groupings; and
- Require licensure to begin unsupervised practice.
As a result, the Department was required to apply only the three statutory criteria when determining which programs qualify as professional degrees for the duration of the court's stay.
ED has now published an interim list of programs that will be treated as professional degree programs while the stay remains in effect. Programs currently eligible for professional-level loan limits of $50,000 annually and $200,000 in aggregate include:
- Physical Therapy (DPT)
- Occupational Therapy (OTD/MSOT)
- Athletic Training (MSAT/MAT)
- Physician Associate/Assistant (MSPA/PA)
- Audiology (AuD)
- Speech-Language Pathology (SLP)
- Anesthesiologist Assistant (CAA)
- Registered Nursing (MSN)
- Nurse Anesthetist (DNAP)
- Nursing Practice (DNP)
- Additional clinical psychology subfields awarding the Psy.D.
ED's update also includes a list of programs that are no longer considered professional degrees, despite having been included originally.
Importantly, this stay is preliminary. It remains in effect only pending further proceedings at the summary judgment stage. The federal government has the right to appeal the court's order and could seek to reverse or pause the stay. The timing of future court actions remains uncertain.
What’s Next
ED’s announcement explicitly states that these interim designations “may change as litigation proceeds.” In the same notice, the Department recommends that institutions consider capping loan disbursements at graduate-level amounts for programs temporarily classified as professional, specifically to protect students from disruption if the stay is later reversed or narrowed.
The court’s ruling and ED’s response provide important short-term relief; they do not address the broader concerns raised by the American Occupational Therapy Association and the Advanced Professional Workforce Alliance regarding the RISE rule's impact on access to graduate education and the development of a highly skilled workforce across critical sectors.
Even if the litigation ultimately results in a favorable outcome, a court decision alone will not provide a permanent solution for all affected professions. Congressional action is still needed to address the underlying law and ensure long-term access to financing for graduate education. We urge you to continue to raise this issue with your members of Congress, and thank you for your continued advocacy and engagement on behalf of the occupational therapy profession.