RISE Negotiated Rulemaking Ends in Consensus, DO Degree Retains Professional Designation

On November 6, 2025, during the second week of the Reimagining and Improving Student Education (RISE) Negotiated Rulemaking Committee, negotiators reached consensus on the entire set of regulatory proposals issued under the One Big Beautiful Bill Act (OBBBA), P.L.119-21, by the U.S. Department of Education (ED). One negotiator abstained. ED will now develop a Notice of Proposed Rulemaking based on the consensus package for publication in the Federal Register, where it will be open for public comment. 

The package reflects consensus on 17 proposals, including borrowing limits and adjustments to repayment plans, but much of the discussion centered on the definition of graduate and professional degree programs relative to the new loan borrowing limits enacted in the OBBBA. Under Secretary of Education Nicholas Kent and others from ED joined during final discussions, pointing out that more than 2,000 individual doctoral programs would fall within ED’s new proposed definition. In the final consensus package, the DO degree remains designated as a professional degree along with the other nine original programs in statute, with the addition of a doctorate in clinical psychology and other doctoral programs that share a four-digit Classification of Instructional Programs code with the listed programs.

On December 8, 2025, the Accountability in Higher Education and Access through Demand negotiated rulemaking will begin. View AACOM’s summary of the second RISE session and the consensus package.