Interim Guidance Issued on “Professional” Loans Under RISE Committee

On Wednesday, June 24, 2026, the U.S. District Court for D.C. preliminarily stayed part of the RISE Final Rule’s professional degree definition. In response, the Department of Education has published guidance on how they will treat programs for the duration of the stay. 

The announcement provides two tables: one for the 29 fields that will, at least temporarily, be treated as professional for the purposes of student loan borrowing limits, and one for the 25 programs that the Department has determined does not meet the criteria to be considered professional. 

Some of the programs on the non-professional program list, such as Theology (CIP 36.0601), were previously classified as professional programs.  For institutions that have already disbursed loans under the higher borrowing limits for these programs, the Department's guidance states that previously disbursed loan amounts do not need to be adjusted. However, institutions may not make any future loan disbursements for these programs using the higher borrowing limit.

The guidance also recommends that institutions with programs that are professional under the stay, but were not considered professional previously, should consider capping program-wide borrowing limits to “mitigate potential disruption to student borrowers," if the program classification changes again.

The guidance is effective immediately and will remain in effect until either the courts or the Department announce otherwise.

For more information, please contact:
Justin Monk