Following last week’s federal court order, the Office of Federal Student Aid (FSA) has now issued implementation guidance identifying the programs the Education Department (ED) will treat as professional degree programs for purposes of Title IV loan originations and disbursements during the period covered by the court’s stay.
The full announcement is available online: https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2026-06-29/update-list-professional-degree-programs-due-court-order
The Department has not suspended the new loan cap framework. Grad PLUS elimination, the new annual and aggregate borrowing limits for graduate and professional students, and other major pieces of the RISE Final Rule are still scheduled to take effect July 1.
But for purposes of administering the statutory loan limits during the court stay, ED has now identified an interim list of programs that will be treated as awarding professional degrees. The Department emphasized that these are interim administrative designations provided to facilitate implementation of the court’s order and may change as the litigation proceeds.
For many COHEAO members, the most important development is that ED’s interim list includes several licensure-based health and allied-health programs that had been excluded or placed in a more uncertain position under the Department’s narrowed final-rule approach. Notable examples include physician associate/assistant, physical therapy, occupational therapy, speech-language pathology, audiology, athletic training, anesthesiologist assistant, certain advanced nursing programs, and several Psy.D. psychology fields. ED also listed the specific degrees that must be awarded for a program to qualify under the interim designation, so institutions should review both the CIP code and the degree credential carefully.
This could materially reduce the immediate exposure for some programs and institutions. For example, programs that had been preparing for the lower graduate borrowing limits may now be eligible, during the stay, for the higher professional student limits if they meet the listed CIP-code and degree requirements.
At the same time, this should not be read as full or permanent relief.
The new federal financing environment is still moving forward. Professional students remain subject to annual and aggregate caps. Graduate PLUS is still being eliminated for new borrowers. Program classifications remain tied to ongoing litigation.
ED may issue additional guidance, and the interim list may change depending on how the court case proceeds. The Department indicated institutions may wish to consider limiting loan amounts to the graduate-level caps for temporarily classified professional programs in order to reduce potential disruption to borrowers if program classifications change later in the litigation.
For COHEAO members, the main takeaways are:
- ED has now issued an interim professional-degree list for use during the court stay.
- The list provides important temporary relief for several health, allied-health, advanced nursing, and psychology programs.
- Institutions should review the specific CIP-code and degree combinations before changing loan packaging or COD reporting.
- The broader loan cap framework still takes effect July 1, including Grad PLUS elimination and the new graduate/professional annual and aggregate limits.
- The interim designations are not final and may change as litigation proceeds.
- Campus teams should coordinate among financial aid, student accounts, legal counsel, enrollment leadership, and affected academic programs before making final implementation decisions.
This remains a fast-moving legal and operational issue. COHEAO will continue monitoring ED guidance, court developments, and implementation questions affecting campus financing, institutional loan programs, student accounts, and related member operations.
For questions on this issue, please contact Wes Huffman at wes@campusaccesspartners.com.
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