Disclaimer: This article is for informational and educational purposes only and should not be considered legal advice. FLSA classifications depend on specific job duties, salary tests, and jurisdictional guidance. Organizations should consult legal counsel or the Department of Labor for guidance on their unique situations.
For HR and compensation teams, few things create anxiety faster than a headline that hints at possible changes to exemption rules. Recently, the Department of Education (DOE) updated how it classifies certain academic programs, shifting some degrees out of the “professional degree” category. Although the change was minor inside higher education, it had an unexpected ripple effect. HR leaders began asking whether this DOE update might affect the learned professional exemption under the Fair Labor Standards Act. The terms sound similar, and that alone was enough to create concern.
This confusion is understandable because HR teams often navigate overlapping language across agencies. However, even though the DOE and the Department of Labor (DOL) use the word “professional,” they are describing completely different things. One governs academic labeling, and the other governs employment law. They do not interact. To be clear, the DOE’s update does not change how the DOL evaluates roles under the learned professional exemption. The two systems live in separate worlds.
Understanding why this is true helps HR teams respond with clarity, correct internal misunderstandings, and provide quick reassurance to leaders and employees who may be reacting to “professional degree” headlines without context.
Two Agencies, One Word, Completely Different Universes
The DOE and DOL use the same term for very different purposes. The DOE uses “professional degree” as an academic label within its program reporting structures. It guides financial aid, classification of program types, and how colleges organize fields like medicine, dentistry, veterinary medicine, and law. It is purely academic. Their definitions are located here:
👉 https://nces.ed.gov/ipeds/cipcode/resources.aspx?y=56
The DOE’s recent shift simply reclassifies how some degrees appear within their internal system. These changes do not alter what students study, the expertise they gain, or the type of work they perform after graduating. They also do not change the level of specialized knowledge tied to those fields. For higher education, it is an administrative update. For HR, though, the wording triggered temporary confusion.
Meanwhile, the DOL oversees FLSA and uses the term “professional” in employment-specific ways. Their focus is job duties, pay structure, judgment required, and whether a role meets the criteria for exemption. The DOL’s fact sheet is here:
👉 https://www.dol.gov/agencies/whd/fact-sheets/17a-overtime
The regulatory definition of the learned professional exemption is located here:
👉 https://www.ecfr.gov/current/title-29/subtitle-B/chapter-V/subchapter-A/part-541#541.300
These two systems—academic program labeling and employment law—do not overlap. As a result, the DOE’s shift has no impact on the learned professional exemption or how HR teams classify roles.
Where HR Found the Confusion
It makes sense that HR leaders paused when they saw headlines about degrees being reclassified as “not professional.” HR carries the responsibility of defending exemption decisions, ensuring compliance, and communicating clearly about regulatory changes. When employees read headlines, managers hear their concerns, and eventually, HR receives questions. Even a subtle academic shift can trigger a cascade of assumptions inside an organization.
Although the DOE’s move does not affect the learned professional exemption, HR professionals may still want to monitor indirect effects in fields most directly impacted by the academic shift. For example:
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Talent pipelines may tighten if aid eligibility becomes more limited.
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Employee morale may fluctuate if graduates feel their degrees were “downgraded” by academic labels.
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Recruitment costs could rise in fields like nursing or public health if degree access changes.
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Retention pressures may grow in roles requiring specialized graduate education.
These ripple effects sit outside FLSA, but they affect workforce planning and compensation strategy. Therefore, while HR does not need to reassess exemption decisions due to the DOE update, monitoring organizational impacts is still wise.
The important message is that DOE academic relabeling does not change the DOL’s job classification rules. The learned professional exemption remains centered on the nature of the work—not the title of a degree.
What Defines a Professional Job Under FLSA? (Hint: It’s Not the Degree Label)
The learned professional exemption is defined by the nature of the work, not the name of a degree. A role qualifies when the job requires:
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Advanced knowledge
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In a field of science or learning
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Customarily obtained through prolonged specialized instruction
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And used to make consistent judgments and informed decisions
These criteria are broad by design. Work has evolved. Organizations now include roles in data science, analytics, design, behavioral research, digital strategy, healthcare support, and other fields that involve complex thinking. These roles may not fit the DOE’s “professional degree” label, yet they easily meet the DOL’s criteria for the learned professional exemption when the duties require specialized knowledge.
This is why FLSA classification should never rely on the title of a degree alone. The DOE’s academic terminology is not a factor in exemption decisions. Instead, HR must assess job duties and the level of expertise required. If the work truly requires judgment, advanced skill, and specialized study, then it likely meets the learned professional exemption regardless of any DOE reclassification.
Real-world examples help make this clear. Consider roles requiring advanced training that the DOE no longer categorizes as professional degrees. If the job involves deep analysis, field-specific expertise, and consistent problem-solving, it still meets the DOL’s standard. Likewise, emerging technical roles that never fit into DOE’s traditional labeling also qualify when their work is complex and grounded in specialized skill. These scenarios show that academic labels are not a measure of professional work under FLSA.
Where HR Should Direct Its Attention Now
Although nothing has changed in FLSA, the DOE’s update offers HR leaders a moment to reinforce clarity and strengthen internal communication. Consider focusing on:
1. Clarifying internally that FLSA rules have not changed.
The learned professional exemption remains tied to job duties and intellectual requirements. The DOE update does not influence exemption classifications.
2. Educating leaders on the difference between academic labels and employment law.
This helps prevent unnecessary re-evaluation of roles.
3. Reviewing job descriptions for accuracy.
Well-written descriptions that reflect judgment and expertise help maintain classification clarity.
4. Preparing concise explanations for employee conversations.
Employees may ask whether these DOE changes affect their roles. Clear responses maintain trust.
5. Documenting exemption rationale.
Although this update requires no change, this is a good trigger to refresh documentation.
6. Monitoring talent and morale in affected degree fields.
This is not an FLSA issue, but it is a workforce planning reality.
By focusing on these areas, HR leaders keep conversations grounded, confident, and aligned with actual regulatory requirements.
Key Takeaways
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The DOE changed its academic labeling of certain degrees.
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The DOL did not change FLSA standards.
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The learned professional exemption still depends on job duties—not degree labels.
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HR decisions remain stable and defensible.
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Academic language and employment law operate in separate systems.
Quick Implementation Checklist
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Confirm classification decisions based on job duties
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Reassure leaders that the DOE update does not affect FLSA
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Refresh job descriptions with duty-specific detail
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Prepare FAQ responses for managers and employees
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Document the exemption rationale for audit readiness
Call to Action
If your organization needs help evaluating exemption status, revising job descriptions, or training leaders on the learned professional exemption, MorganHR can support you with clear guidance and practical steps that keep your teams compliant and confident.
👉 https://www.morganhr.com/contact