Article Guide · FAFSA Updates
Nursing, PA, and PT Students: Are You on the Professional-Degree List?
Since July 1, 2026, a new graduate student can borrow $20,500 a year in federal loans, but a professional student can borrow $50,000. Which one you are depends on a list. A court order on June 24, 2026 pushed the Department of Education to add MSN, DNP, nurse anesthesia, physician assistant, physical therapy, and occupational therapy programs to it, for now.
By Moises Lopez, Educator (10+ yrs, LAUSD & nonprofits) · Sourced from FSA Electronic Announcement GENERAL-26-42 and the court's order · Case status checked September 26, 2026
Why the List Matters
Grad PLUS loans are gone for students starting a graduate program now. What's left is the Direct Unsubsidized Loan, and its limit depends on whether ED treats your program as graduate or professional:
| Program type | Each year | In total |
|---|---|---|
| Graduate | $20,500 | $100,000 for graduate study |
| Professional | $50,000 | $200,000, minus anything you borrowed as a graduate student |
Over a three-year program, borrowing the most each year, that's $61,500 at the graduate limit and $150,000 at the professional limit, a difference of $88,500. Neither amount can exceed your cost of attendance minus other aid, and every student also has a lifetime maximum of $257,500 in federal student loans, which counts undergraduate loans too.
The list mostly matters for students who started a program on or after July 1, 2026. If you were enrolled on June 30, 2026 and had a Direct Loan for your program before July 1, 2026, you likely have the interim exception: the old limits, Grad PLUS included, for up to 3 more academic years. Studentaid.gov adds that health profession students who had higher limits before keep them while the exception lasts. The list becomes your limit once the exception ends.
What the Court Did
ED's May 2026 final rule defined a professional degree in two parts. Part (ii) named 11 fields: pharmacy, dentistry, veterinary medicine, chiropractic, law, medicine, optometry, osteopathic medicine, podiatry, theology, and clinical psychology. Part (i) set general tests a degree had to meet, and the rule's preamble added one more: a professional degree could not lead to work that "ordinarily must be supervised by a licensed professional in a different occupation and cannot be performed independently." Under that approach, nursing, PA, and PT programs were graduate programs.
Nurse practitioner and physician assistant groups sued. On June 24, 2026, the U.S. District Court for the District of Columbia set aside and stayed part (i) and the supervision test while the case goes on. The court did not stay the 11 named fields. It also refused two broader requests: to block the graduate and professional loan caps altogether, and to order ED to treat physician assistant students as professional students.
ED responded with an interim list of 29 programs it will treat as professional "for the duration of the Court's stay" (Electronic Announcement GENERAL-26-42, updated July 10, 2026). ED says its original definition is lawful and that it will keep defending it.
Health Programs on the Temporary List
A program counts only if it awards one of the degrees in parentheses. Schools report programs by CIP code, a federal program classification; your aid office can tell you your program's code.
| Program (degree) | CIP code |
|---|---|
| Registered Nursing/Registered Nurse (MSN) | 51.3801 |
| Nursing Practice (DNP) | 51.3818 |
| Nurse Anesthetist (DNAP) | 51.3804 |
| Physician Associate/Assistant (MSPA; PA) | 51.0912 |
| Physical Therapy/Therapist (PT; DPT) | 51.2308 |
| Occupational Therapy/Therapist (OT; MSOT; OTD) | 51.2306 |
| Anesthesiologist Assistant (CAA) | 51.0809 |
| Audiology/Audiologist (AuD) | 51.0202 |
| Speech-Language Pathology/Pathologist (SLP) | 51.0203 |
| Athletic Training/Trainer (MSAT; MAT) | 51.0913 |
Nursing specialties. On July 10, 2026, ED clarified that the MSN and DNP entries include any program in the same 4-digit CIP code, 51.38, that awards the same credential. So an MSN or DNP in a nurse practitioner specialty coded under 51.38 counts, not only a program coded exactly as the entry above.
The full list also includes medicine, dentistry, pharmacy (Pharm.D.), law, veterinary medicine, and several Psy.D. programs. The graduate loans guide shows all 29 programs with their CIP codes.
Who Is Still Left Out
- •Ph.D. in Nursing. The nursing entries list the MSN, DNAP, and DNP only, so a research doctorate in nursing is not on the list.
- •A degree title that isn't listed. A program in a listed field that awards a different degree than the one in parentheses doesn't qualify. If your nursing master's awards something other than an MSN, ask your school how it reports the program.
- •Fields ED names as excluded. ED lists 25 CIP codes it will not treat as professional during the stay, including pharmaceutical sciences and pharmacy administration programs other than the Pharm.D., several psychology fields such as educational and industrial-organizational psychology, and theology and ministerial studies programs other than the M.Div. and rabbinical studies.
- •Programs on neither list, such as public health and marriage and family therapy. They fall under the graduate limits.
Those gaps are now part of the lawsuit. On August 3, 2026, the plaintiffs filed an amended complaint that also challenges ED's interim list, arguing that it still leaves out doctoral nursing programs such as the Ph.D. in Nursing and other advanced nursing specialties, as well as public health, marriage and family therapy, and some education programs. The court hasn't ruled on that.
Your School Can Still Lend You Less
Being on the list raises the federal maximum. It doesn't guarantee you can borrow it. Starting July 1, 2026, schools may set lower loan limits for a program of study, as long as they apply the limit consistently to every student in that program (studentaid.gov).
In the same announcement that created the interim list, ED suggested that schools "may wish to consider" capping loans in these temporarily professional programs at the graduate limits, to avoid disrupting students if the classification changes later. Some schools may do that. If your award letter shows $20,500 for a program on the list, ask whether that's a school limit. Our guide to school-set loan limits explains the rules schools must follow.
What Could Change, and When
The stay lasts "until further order of the Court." As of September 26, 2026, the court docket shows no appeal of the order. The judge's schedule has the plaintiffs' summary judgment motions due October 2, 2026, with the last brief due December 4, 2026. A final decision would come after that, so the current list is likely to hold through the fall term, though that isn't guaranteed.
ED's handling of the June change shows how a later change could work. When the interim list dropped programs that had been treated as professional, loans already disbursed at the higher limit didn't have to be adjusted. Every later disbursement had to be at the graduate level, though, and a student whose borrowing was already over the $100,000 graduate total couldn't get more graduate-level loans. ED hasn't said it would follow the same approach if the list changes again.
We check the list and the case docket and will post any change on the updates page.
What to Ask Your Financial Aid Office
- 1 What CIP code and degree does my program report, and does ED's interim list treat it as professional?
- 2 Is my annual loan limit $50,000 or $20,500? If it's lower than the federal maximum, is that a school-set program limit?
- 3 Do I have the interim exception, and if so, when does it end for me?
- 4 If the list changes while I'm enrolled, what happens to loans for the rest of this year?
- 5 How much have I already borrowed toward the $200,000 professional total and the $257,500 lifetime maximum?
Whatever your limit, any Direct Loan first disbursed on or after July 1, 2026 can be repaid only under RAP or the Tiered Standard Plan. The repayment plan chooser shows which plans stay open to you.
Related Articles
Graduate Student Loans After OBBBA: What You Can Still Borrow
All 29 programs on the list, the new limits, and ways to cover the gap
FAFSA Legacy Borrower Status: The Complete 2026 Guide
Who keeps the old loan limits, including Grad PLUS, and for how long
Transferring Schools or Taking a Semester Off: Do You Lose the Old Loan Limits?
What ends the interim exception for graduate students, and what doesn't
Sources: FSA Electronic Announcement GENERAL-26-42, "Update to List of Professional Degree Programs Due to Court Order" (updated July 10, 2026); Order, American Association of Nurse Practitioners v. McMahon, No. 26-cv-1780, and PA Education Association v. U.S. Department of Education, No. 26-cv-1941 (D.D.C. June 24, 2026); case docket (amended complaint, ECF No. 53; scheduling order; checked September 26, 2026); ED final rule, 91 FR 23768 (May 1, 2026), 34 CFR 685.102; studentaid.gov, "One Big Beautiful Bill Act – Important Definitions" (loan limit charts, interim exception, school-set limits). Figures checked against official Federal Student Aid sources (how the numbers are checked). FAFSA Updates is not affiliated with the U.S. Department of Education.