Skip to main content

RISE Rule Update: Court Halts Key Parts of RISE Rule, But Uncertainty Continues

Published June 26, 2026

What Happened

On June 24, 2026, the U.S. District Court for the District of Columbia granted in part and denied in part the Physician Associates Education Association and American Association of Nurse Practitioners' (PAEA/AAPA) request for preliminary relief challenging the Department of Education’s RISE rule. The court stayed (i.e., blocked) key elements of the rule's revised definition of "professional degree," including the new eligibility criteria – such as doctoral-level and duration requirements – and the requirement that qualifying degrees must lead to independent, unsupervised practice.

This is a huge win for higher education advocates, including the Academy. However, the court denied broader relief, declining to require the Department to classify physician assistant (PA) programs as "professional," declining to enjoin the statutory loan caps, and leaving intact the rule's list of enumerated professional degree programs.

At the same time, the Senate rejected Senator Jeff Merkley’s Congressional Review Act (CRA) resolution to overturn the RISE rule, with Senate Republicans voting down the measure and allowing the administration’s student loan overhaul to proceed.

Why It Matters

The ruling represents a significant legal shift because the court found the Department likely acted unlawfully by narrowing the definition of "professional degree" beyond what Congress authorized, effectively restoring the broader, longstanding three-part regulatory definition that Congress incorporated into statute. This reopens the possibility that programs such as PA, nursing, and other health professions could qualify as "professional degrees" if they meet the statutory criteria, removing the categorical restrictions imposed by the RISE rule.

At the same time, the court stopped short of resolving classification questions itself, leaving the Department with discretion to apply the restored standard on a program-by-program basis. Importantly, the decision does not alter the underlying statutory framework – loan caps and the elimination of Grad PLUS loans remain in effect – meaning access to federal financing remains constrained regardless of classification outcomes.

The failure of Senator Merkley's CRA effort further underscores that legislative avenues to overturn the rule in full have narrowed, increasing reliance on litigation outcomes and administrative implementation.

What's Next

The Department of Education must now implement the statutory loan caps using the restored definition of "professional degree," which will likely require near-term, program-specific determinations about eligibility. The litigation will continue on the merits, so the court's order is preliminary and could evolve with future rulings.

In the interim, there is a critical opportunity for stakeholders to advocate for inclusion of PA programs and other excluded fields under the reinstated three-part test. With the CRA path closed, congressional action is more likely to take the form of targeted legislation or oversight rather than wholesale repeal.

Meanwhile, institutions and students are likely to face ongoing uncertainty as the Department reassesses classifications and issues guidance ahead of implementation, particularly given the compressed timeline and high stakes associated with student loan availability.

Bottom Line

The court significantly weakens DOE's restrictive framework and reopens the door for broader "professional degree" recognition – including nutrition and dietetics – but the decisive classification question and financial constraints remain unresolved.

The Academy will continue to advocate for the inclusion of Nutrition and Dietetics graduate degrees in the definition of professional degree.

References

Join the Academy

Members of the Academy of Nutrition and Dietetics receive exciting benefits including complimentary continuing professional education opportunities, discounts on events and products in eatrightSTORE.org, invitations to exclusive members-only events and more!