Milbank Submits Public Comment on Proposed Changes to Graduate and Professional Degree Definitions

On March 2, 2026, The Milbank Memorial Fund submitted a public comment in response to the U.S. Department of Education’s proposal to amend the § 685.102 Degree Definitions to include new definitions of graduate student and professional student. The proposed rule excludes several graduate degrees for health professions and related clinical sciences, lowering borrowing limits for these professional degrees. The Fund argues that this change will have negative implications for the health workforce pipeline, the cost of health care, and health care access in underserved areas, including many rural areas.

Based on the Fund’s expertise and experience in sustainable health costs and primary care, and The Milbank Quarterly’s peer-reviewed articles on population health and evidence-based health policy, the Fund recommends amending the proposed rule. We support the recommendation in a recent letter from the Association of Schools and Programs of Public Health to classify all graduate degrees in health professions and related clinical sciences (CIP codes beginning with 51) as professional degrees. Categorizing degrees by CIP codes would also allow for administrative efficiency and consistency in definitions, while considering the population health effects of these decisions. The Fund also signed on to a joint letter to the Department of Education submitted by Grantmakers In Health (GIH) and 38 co-signers.