Eleven degree types. That's how many programs receive the $50,000 professional cap. Section 81001 defines "professional student" by pointing to 34 CFR § 668.2, a regulation that lists exactly 11 degree types as "first-professional" degrees:
D.C., D.D.S./D.M.D., J.D., M.D., O.D., D.O., Pharm.D., D.P.M., D.V.M., Psy.D. and M.Div./M.H.L./B.D.
These receive the $50,000 annual cap. Every other graduate degree, regardless of clinical intensity, program duration, cost, or IPEDS classification, receives $20,500.
Who Falls Through the Crack
The following five clinical doctorate types are classified by IPEDS as AWLEVEL 18, "Doctor's degree—professional practice," the same classification used for M.D. and J.D., but are not included in the 34 CFR § 668.2 list. The loan cap framework treats them as ordinary graduate programs.
| Program | Loan Cap | Programs | Gap Rate | Median COA | Median Annual Gap | IPEDS Level |
|---|---|---|---|---|---|---|
| Physician Assistant (PA) | $20,500 | 180 | 100% | $60,080 | $39,580 | 7/18 |
| Physical Therapy (DPT) | $20,500 | 202 | 100% | $51,972 | $31,472 | 18 |
| Occupational Therapy (OT) | $20,500 | 94 | 100% | $52,600 | $32,100 | 18 |
| Nursing Doctorate (DNP) | $20,500 | 390 | 99% | $40,360 | $19,860 | 18 |
| Audiology (AuD) | $20,500 | 37 | 100% | $49,780 | $29,280 | 18 |
| For comparison: | ||||||
| Medicine (MD) | $50,000 | 227 | 94% | $85,614 | $35,614 | 18 |
| Dentistry (DDS/DMD) | $50,000 | 107 | 98% | $99,869 | $49,869 | 18 |
| Pharmacy (PharmD) | $50,000 | 139 | 75% | $63,471 | $13,471 | 18 |
| Clinical Psychology (PsyD) | $50,000 | 28 | 79% | $63,552 | $13,552 | 18 |
| Law (JD) | $50,000 | 304 | 77% | $65,996 | $15,996 | 18 |
A PA student pays a median $60,080 per year, comparable to a pharmacy student ($63,471), yet receives less than half the federal borrowing limit. The classification creates a $29,500 difference in available funding between programs with comparable costs, based solely on the 34 CFR § 668.2 degree list.
Author's note on HEAL precedent: The 1978 HEAL program was created precisely because high-cost health professions needed borrowing capacity beyond standard federal limits. HEAL covered MD, DO, dentistry, and veterinary medicine, but it also did not cover DPT, PA, or nursing doctorates, which either didn't exist as doctoral programs or were far less expensive at the time. Forty-eight years later, those programs have become expensive clinical degrees, but the 34 CFR § 668.2 list has not changed. Under the OBBBA, the professional degree list is fixed as of enactment, meaning a regulatory update to 34 CFR § 668.2 would not retroactively change which programs qualify for the $50,000 cap.