You Have Questions; We Have Answers: Making Sense of the Student Loan Changes from OBBBA’s RISE Committee
By Jill Desjean, Director of Policy Analysis
The Department of Education (ED) inched closer to implementing regulations for the loan-related provisions of the One Big Beautiful Bill Act (OBBBA) earlier this month with the conclusion of its Reimagining and Improving Student Education (RISE) negotiated rulemaking (neg reg) committee, which reached consensus after two weeks of discussions. While final regulations are still forthcoming, ED addressed several outstanding questions and provided some clarification throughout the rulemaking session.
Below are some clarifications that arose during neg reg as well as answers to some commonly asked questions NASFAA has received from members. Note that all answers are tentative pending final rules, which are expected in early 2026.
Professional degree/student definition
The OBBBA sets new, higher annual and aggregate loan limits for “students enrolled in a program of study that awards a professional degree,” as defined in an existing regulatory definition at CFR 668.2 as of the date of enactment of the OBBBA. Degrees included as examples of a professional degree in that definition include but are not limited to: Pharmacy (Pharm.D.), Dentistry (D.D.S. or D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C. or D.C.M.), Law (L.L.B. or J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M., D.P., or Pod.D.), and Theology (M.Div., or M.H.L.).
The RISE committee agreed to ED’s proposed definition of a professional degree for Direct Loan purposes, which is one of the 10 programs listed in CFR 668.2, plus Clinical Psychology (Psy.D. or Ph.D.). Any other program with the same 4-digit Classification of Instructional Programs (CIP) code as the aforementioned programs could also be considered a professional degree if it:
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Signifies both completion of the academic requirements for beginning practice in a given profession, and a level of professional skill beyond that normally required for a bachelor's degree;
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Is generally at the doctoral level, and that requires at least six academic years of postsecondary education coursework for completion, including at least two years of post-baccalaureate level coursework; and
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Generally requires professional licensure to begin practice.
ED noted during rulemaking that the potential universe of eligible professional programs based on CIP alone is 44, but that does not account for the licensure or program length requirements, which will likely reduce that number.
Many NASFAA members have asked if health professions such as physician’s assistant/associate, physical therapy, and nursing, among others, would be considered professional degrees. Under ED’s definition, these programs would not be considered professional degrees because they do not share a 4-digit CIP code with any of the eleven programs ED designates as fields in which a professional degree may be awarded in the new regulatory text, despite the fact that those programs may be otherwise similar to other professional programs and meet the other criteria.
Legacy provisions
The OBBBA eliminates the Graduate PLUS program; establishes new aggregate limits for graduate student unsubsidized loans; and establishes new annual and aggregate borrowing limits for Parent PLUS and for professional student unsubsidized loans, beginning July 1, 2026.
The RISE committee agreed to regulatory language that specifies the new limits apply to loans borrowed for periods of enrollment beginning on or after July 1, 2026. They also agreed that students can continue to borrow under the Graduate PLUS program and that the current loan limits (including the additional unsubsidized annual and aggregate borrowing limits for certain health professions, sometimes referred to as the HEAL limits) continue to apply for students who were enrolled in a program of study as of June 30, 2026 and for whom a Direct Loan was made for that program of study prior to July 1, 2026. It is important to note that the legacy provisions are tied to these specific enrollment and disbursement dates, and not on award year.
This legacy eligibility would continue for the lesser of three academic years or the student’s expected time to credential (which is defined as the difference between the program length and the period of the program the student has completed as of the date of the determination, where program length is the amount of time it takes a full-time student to complete the program). Borrowers who withdraw or otherwise cease enrollment in their program of study would no longer be eligible to borrow under current programs and limits. In such cases, when those students re-enrolled, they would be subject to the new annual and aggregate limits. Students who take an approved leave of absence (LOA) in accordance with CFR 668.22 would not be considered to have withdrawn or otherwise ceased attendance, so they could continue borrowing under the legacy provisions when they returned to school, provided they met the other legacy requirements. NASFAA has created a flowchart for graduate and professional student loan borrowing limits.
Negotiators also agreed to language specifying that, for Parent PLUS legacy eligibility only, a student who changes majors within the same degree or certificate will be considered to be enrolled in the same program of study.
NASFAA members have asked what it means for a loan to have been “made” prior to July 1, 2026 for purposes of legacy eligibility, and ED confirmed during negotiations that they use the word “made” broadly throughout the regulations to refer to “disbursed” and that the same meaning is intended for these purposes.
Members have also asked for confirmation of whether students or parents need to have borrowed a specific type of loan for the same program of study prior to July 1, 2026 in order to qualify for the legacy provisions. ED confirmed that the requirement is only that a Direct Loan was made prior to July 1, 2026, and that the type of loan does not matter.
So, for instance, if a current freshman undergraduate student borrowed a subsidized loan and their parent did not borrow a PLUS loan for this year, their parent could borrow a PLUS loan for next year under the legacy provisions, so long as the student met the other legacy eligibility requirements. Similarly, a continuing law student who had borrowed only an unsubsidized loan this year would be able to borrow a Graduate PLUS loan next year, again, provided they met the other legacy eligibility requirements.
Annual loan limit adjustments based on less than full-time enrollment
The OBBBA requires institutions to adjust the annual loan limit for students who enroll on a less than full-time basis. Negotiators agreed to regulatory text that would establish eligibility at the time of disbursement. This allows students whose enrollment status changes during the payment period to keep the amount of loans disbursed for that payment period. Future disbursements would be adjusted accordingly if the student’s annual enrollment were less than full-time.
For example, an undergraduate student in a semester-based academic year planning to enroll in 12 credits per term would be eligible for the full annual loan limit, split equally over fall and spring. If the student dropped from 12 to 9 credits after their fall loan was disbursed, the school would not have to reduce the fall loan. However, before making the spring disbursement, the institution would again have to look at the student’s annual enrollment. If the student still only planned to take 12 credits for the spring, their annual limit would be adjusted to 21/24 of the statutory annual limit and the spring amount would be that amount minus what was received in the fall. If the student enrolled in 15 credits for the spring, however, the institution could disburse the second half of the full annual limit since the student would be enrolled full-time for the academic year.
ED also made changes to the regulations to clarify that students subject to loan adjustments for less than full-time enrollment are not subject to the rule that requires substantially equal installments of loan proceeds.
Parent PLUS loans are not subject to these adjustments for less-than full-time study.
Unlike the loan limit changes, which are effective based on specific dates regardless of award year, ED is implementing this provision only for loans awarded for the 2026-27 award year and beyond.
New student loan repayment plans
The OBBBA creates two new repayment plans, the tiered Standard plan and the Repayment Assistance Plan (RAP), and sunsets the income-contingent repayment plans (ICR, PAYE, SAVE) by July 1, 2028.
Borrowers with any new loan disbursed on or after July 1, 2026 will only have the option of the tiered Standard and RAP. Current borrowers with no new loans disbursed on or after July 1, 2026 can continue to enroll in and switch between the current 10-year Standard, Graduated, Extended, Income Contingent (ICR, PAYE, or REPAYE), and Income Based Repayment (IBR) plans until June 30, 2028. They can also remain in the 10-year Standard, Graduated, Extended, or IBR plan until their loans are paid in full. However, if they are enrolled in ICR, PAYE, or SAVE as of June 30, 2028, they will need to switch to either the tiered Standard, RAP, or IBR plan. Borrowers who fail to make a selection will be automatically enrolled in the RAP. Current borrowers in repayment can also opt in to the RAP at any point after July 1, 2026.
Questions have arisen over how payments for married borrowers filing joint tax returns will be treated under the RAP. ED and negotiators agreed to language that would calculate a monthly payment based on the couple’s joint income and then calculate each individual’s monthly payment in proportion to their share of the couple’s combined debt.
Another question related to the RAP is whether payments made in excess of the amount due would qualify for the matching principal payment provision of the RAP. ED and negotiators agreed to language that would allow borrowers making payments in excess of the amount due to opt out of ED’s standard treatment of advancing the borrower’s next payment due date, which would cause the borrower to forgo the matching principal subsidy. The opt-out would allow the excess amount to instead be considered an on-time payment for the next month, which would allow for the matching principal payment to be applied.
Institutionally-determined loan limits
Beginning July 1, 2026, institutions are granted authority to set loan limits below the statutory limits so long as those limits are applied consistently to all students in that program of study. Importantly, “program of study” has a different meaning for institutional loan limits than it does for legacy loan limits addressed earlier in this article. For institutionally-determined loan limits, program of study refers to an “eligible program,” a distinction ED believed was necessary to communicate that institutions can limit borrowing for students by major.
ED confirmed during negotiations that, if a school opted to apply institutional loan limits to a population of students, it could not use PJ on a case-by-case basis to increase an individual student’s loans back to the statutory maximum.
Please note that these answers to common questions are based on NASFAA’s understanding of the regulatory text agreed to by consensus between ED and negotiators on the RISE committee, and based on discussions during the RISE negotiated rulemaking committee. While ED is bound to the consensus agreement, final regulatory text has not yet been published and could potentially change.
Read Today’s News for updates on final regulatory text from the RISE committee as well as coverage of the upcoming AHEAD committee, which will cover regulations related to the OBBBA changes to Pell Grants, including Workforce Pell Grants, and the new low-earning outcomes accountability measure.
Publication Date: 11/20/2025
Helen F | 2/24/2026 9:28:41 PM
FYI, most of the comments shared here expressing concerns about the regulations should be directed to ED via the official comment process on the Notice of Proposed Rulemaking no later than Monday, March 2nd, 2026 at https://www.regulations.gov/document/ED-2025-OPE-0944-0001
Julia K | 12/2/2025 3:13:07 PM
What about Marriage and Family Therapy (MFT) programs? There is a demand for Mental Health professionals, and MFTs require licensure, 2 years of academic work, and a practicum.
Charlotte G | 11/30/2025 6:13:16 AM
At its core, professional hierarchy discrimination is not about protecting patients—it is about protecting power. And when applied to modern regulatory issues like CIP reclassification, loan caps, and scope-of-practice opposition, it becomes a systemic barrier that worsens provider shortages and undermines equitable access to healthcare. Respectfully, Dr. Charlotte A. Gullap-Moore, DNP, MSN, APRN, ANP-BC, RN
Travis H | 11/25/2025 10:45:53 AM
Is COD going to start tracking credits enrolled per aid year? If not, the loan adjustment described in this article does not account for handling transfer students who drop credits prior to transferring. It also doesn't talk about summer header/trailer impacts. Shouldn't this work just like pell enrollment intensity per term and call for a reduction if backdating to remove credits?
I also fully agree that the high costs associated with some of today's medical field programs calls for ED to look harder at the professional degree inclusions.
Christine Walter | 11/25/2025 2:32:33 AM
I strongly oppose the proposal to reclassify advanced nursing degrees (MSN, DNP, CRNA, CNM, CNS, APRN) out of the “professional” category. This change will harm the nursing profession and undermine the stability and safety of the U.S. healthcare system.
Graduate nursing education clearly meets the criteria of a professional. These programs require rigorous academic work, advanced clinical training, national certification, and high-level competencies comparable to medicine, pharmacy, and dentistry. Reclassifying them as “non-professional” does not reflect the level of responsibility or clinical judgment these roles require.
Advanced-trained nurses are essential to delivering accessible, high-quality, cost-effective care, especially in rural/underserved areas where provider shortages are already severe. At a time of rising patient acuity & workforce strain, reducing the recognized professional status of these degrees would further weaken healthcare access.
Reclassification would also restrict financial aid and loan structures that many working nurses, rural students, and first-generation learners depend on to pursue graduate education. This would shrink the pipeline of advanced-practice nurses at a time when demand is growing.
Nursing faculty are required to hold advanced degrees. If fewer nurses can pursue graduate education, we will face even greater faculty shortages, forcing nursing programs to limit enrollment and worsening the national nursing shortage long-term.
As a longtime nurse who has cared for elderly, high-risk, and medically complex patients, I have seen how essential advanced-practice nurses are for these vulnerable groups. Reducing their numbers will lead to delays in care, poorer outcomes, and increased preventable hospitalizations.
For these reasons, I urge the Department of Education to maintain professional-degree classification for all advanced nursing programs to protect patient safety, healthcare access, and the future nursing workforce.
Patricia R | 11/24/2025 10:18:55 PM
I am writing to strongly object to the Department of Education’s decision to reclassify Nursing as a non-professional field. This change disregards the educational rigor, clinical judgment, and public responsibility that define the nursing profession.
Nurses complete extensive academic preparation, clinical training, and must pass a national board examination before legally using the title “RN.” They also maintain licensure through lifelong learning and continuing professional development. Physicians follow the same model: board exams, professional title protection, and ongoing education. If these criteria no longer meet the Department’s definition of a “professional” field for nurses, then by the same logic, they would not meet it for physicians—an inconsistent and unreasonable outcome.
Reclassifying nursing risks undermining public trust, weakening educational standards, limiting federal aid pathways, and worsening the ongoing national nursing shortage. It devalues the work of millions of highly trained clinicians whose roles are essential to patient safety, care coordination, and the functioning of the entire healthcare system.
This decision also contradicts standards set by the American Nurses Association, state boards of nursing, and national accrediting bodies, all of which recognize nursing as a professional discipline requiring advanced education and independent clinical responsibility.
I respectfully urge the Department to reconsider this reclassification and to engage with nursing organizations, educators, and frontline clinicians before implementing changes that could negatively affect healthcare delivery and the nursing workforce.
Althea M | 11/23/2025 2:52:11 PM
I am an oncology certified nurse, currently working as a nurse clinician at the University of Iowa Health Care. I am writing to urge you to revise the Department of Education’s definition of ‘professional degree’ to explicitly include graduate nursing programs (MSN, DNP, PhD).
Graduate-prepared nurses are vital to our country’s healthcare, particularly in rural and underserved areas. Nurse Practitioners and Nurse Anesthetists make a large impact on the care in Iowa. Excluding nursing from the professional degrees will worsen shortages and limit access to essential care.
Please ensure advanced nursing education is fully recognized and supported in federal policy.
Leticia L | 11/23/2025 11:54:05 AM
I stand in strong opposition of the Department of Education’s action to reclassify graduate-level nursing degrees, such as MSN, DNP, CRNA, CNM, CNS, and APRN programs, out of the “professional degree” category.
This change would have significant and deleterious implications for the nursing profession, for the safety of patients, and the stability of an already fractured U.S. healthcare system.
Nurses with advanced degrees are operating within a scope of practice that has prepared them to bridge gaps extending access to care; nurses with advanced degrees and experience are prepared to educate the next generation of nurses, creating a pipeline of safe qualified nurses to the workforce; nurses with advanced degrees integrate evidence to address disparities in care, implementing quality improvements to improve healthcare systems and patient outcomes.
You are deeply mistaken if you have relegated to profession to changing bedpans; our profession is far more complex. We recognize early decompensation to mitigate poor patient outcomes. We contribute to the clinical discourse representing the patient's best interest, with best evidence, and available resources. We are active collaborators with physicians and other multidisciplinary groups. We are quite literally the final safety measure to ensure safe patient care.
Lack of access to advanced education means that you will effectively dismantle safe patient care, access to care, and the recruitment and retention of a future nursing workforce. You will eventually realize that you have caused the nursing workforce to dwindle; you will realize an increase in chronic diseases; you will realize increases in mortality and morbidity; you will realize health systems collapse. We are the infrastructure needed to keep healthcare sustainable.
Marianna K | 11/22/2025 5:4:08 PM
I strongly oppose the Department of Education’s proposal to reclassify graduate-level nursing degrees, such as MSN, DNP, CRNA, CNM, CNS, and APRN programs, out of the “professional degree” category.
This change would have significant and harmful implications for the nursing profession and for the safety and stability of the U.S. healthcare system.
Advanced nursing degrees meet every criteria of a professional field:
1. Advanced Clinical Expertise: Graduate nursing programs require extensive clinical training, national certification, and advanced competencies comparable to other professional degrees such as medicine, pharmacy, and dentistry.
2. Critical Workforce Role: APRNs and advanced-trained nurses provide high-quality, cost-effective care, especially in underserved and rural communities where access to healthcare is already critically limited.
3. Public Health Impact: Declassifying these degrees threatens the pipeline of highly trained nurses at a time of workforce shortages, increased demand for primary care providers, and rising complexity in patient care.
4. Economic and Educational Equity: Reclassification would reduce access to essential financial aid and loan structures, disproportionately harming working nurses, low-income students, rural students, and first-generation learners who rely on professional-degree financial protections.
5. Consistency and Recognition: Graduate nursing education has long been recognized as a professional pathway requiring advanced academic rigor, clinical mastery, and national licensure. Declassification contradicts established standards across accreditation bodies, industry expectations, and federal workforce initiatives.
For these reasons, I urge the Department of Education to maintain professional-degree classification for advanced nursing programs. Protecting the integrity and accessibility of graduate nursing education is essential for meeting national healthcare needs and ensuring patient safety.”
Tara S | 11/22/2025 8:18:59 AM
I strongly oppose the omission of many of the professions from the definition of a professional degree. Six years ago I completed my PhD in nursing. - I would not have completed without access to federal funding for my degree. I teach in an APRN program that includes a DNP and CRNA program. These new rules are not only detrimental to my students and others across the country, they are harmful to the nursing profession as a whole. This devalues the important contribution nursing makes to healthcare and our patients. It continues to perpetuate the notion that nurses are “less than” other interprofessional colleagues. Nursing meets every component outlined in the definition of a profession. Limiting access to federal aid will further the faculty shortage as people like me will not be able to advance in order to teach future nurses. It will also exacerbate the provider shortage as fewer nurses will enter NP, CNS, CNM, and CRNA programs. This ruling is shortsighted and detrimental to the American public, nurses, and all health professions omitted from the list of those eligible for higher levels of aid. Please reconsider and do what is right to protect us.
Heather H | 11/21/2025 9:38:14 PM
The main criteria of a profession are a specific, specialized body of knowledge, extensive education and training, adherence to a code of ethics, and autonomy in practice. Additionally, professions are characterized by providing a service to society, having a strong internal organization, and a commitment to ongoing professional development. Advanced education in nursing- specifically PhD, CNS, CNM degrees- check all of these requirements. Additionally there are certification exams and licensure requirements consistent with those of medicine, chiropractic and veterinary professions.
As a doctoral prepared (PhD) nurse - and as someone who is also a patient in the US healthcare system - I strongly oppose the proposal to remove advanced nursing degrees from the professional-degree category.,
Advanced practice nurses are essential to patient safety and access to care. In high-acuity settings, they manage complex cases, prevent complications, and provide critical continuity for patients with life-threatening conditions. In home care they are often the only professionals standing between the patient and a return to hospital.. Given that we have research that clearly indicates that a shortage of nurses negatively impacts patient outcomes, this proposal cannot be based on facts.
For the sake of patients, communities, and the healthcare workforce, I urge the Department of Education to keep advanced nursing degrees classified as professional degrees. We have our own disciplinary knowledge, our own standardized classifications, and are the critical link in the healthcare system to ensuring positive outcomes for patients.
Arti C | 11/21/2025 7:47:40 PM
I am a neurosurgery nurse and current DNP student, and I strongly oppose the proposal to remove advanced nursing degrees from the professional-degree category.
Graduate nursing programs clearly function as professional disciplines. DNP, MSN, APRN, CRNA, CNS, and CNM programs require rigorous graduate-level coursework, extensive clinical training, national certification, and licensure — standards comparable to medicine, dentistry, and pharmacy.
Advanced practice nurses are essential to patient safety and access to care. In neurosurgery and other high-acuity settings, they manage complex cases, prevent complications, and provide critical continuity for patients with life-threatening conditions. Limiting loan eligibility will reduce the number of nurses who can pursue these roles at a time when shortages are already severe.
This change also disproportionately harms women, working nurses, and students from rural or low-income backgrounds who depend on financial aid to advance their education.
For the sake of patients, communities, and the healthcare workforce, I urge the Department of Education to keep advanced nursing degrees classified as professional degrees.
Rekishia M | 11/21/2025 7:36:37 PM
I am writing to express my strong opposition to this bill. All professions that have been removed from eligibility must be reinstated. The fields being excluded are already experiencing significant workforce shortages, and removing them from funding consideration would be catastrophic. This change would further limit the number of qualified individuals entering these professions at a time when demand for services is increasing, not decreasing.
As a graduate-level social worker who provides intensive case management for veterans, I see firsthand the critical need for highly trained professionals across social work and related fields. This bill would create unnecessary barriers for those who wish to enter these helping professions by restricting access to the financial support required to pursue graduate-level education. Limiting funding will directly translate into fewer professionals available to serve vulnerable populations.
For the sake of students, employers, and the communities who depend on these services, I urge you to reinstate all removed professions and reconsider the long-term impact this bill will have on an already strained workforce.
Michelle H | 11/21/2025 2:37:08 PM
I strongly oppose the Department of Education’s proposal to remove advanced nursing degrees (MSN, DNP, CRNA, CNM, CNS, APRN programs) from the professional degree category.
Graduate nursing programs clearly meet the standards of a professional discipline. They require advanced academic study, extensive supervised clinical training, national certification, and licensure - similar to other professional programs in fields such as medicine, dentistry, and pharmacy.
Advanced practice nurses are essential to the U.S. healthcare workforce. They deliver high-quality, cost-effective care, often serving as the primary or only providers in rural and underserved communities. Any change that limits access to graduate nursing education will deepen provider shortages and reduce access to safe, timely care.
Reclassification also threatens equity. Professional-degree designation affects eligibility for financial aid and loan protections. Removing this classification would make graduate nursing education less accessible for working nurses, low-income learners, first-generation students, and those in rural areas who rely on financial support to advance their training.
Finally, this proposal contradicts decades of accreditation standards, national workforce policy, licensure expectations, and federal initiatives that recognize graduate nursing as a specialized professional pathway vital to patient safety and healthcare delivery.
For these reasons, I urge the Department of Education to maintain professional-degree classification for advanced nursing programs. Protecting access to graduate nursing education is essential to the health of our communities and the strength of the U.S. healthcare system.
Tracy W | 11/21/2025 2:25:10 PM
The Department of Education is poised to make a regulatory change that would reclassify certain careers as “not professions.” On paper, this may sound like routine bureaucracy. In reality, it would cut off federal student loan access to entire fields — fields overwhelmingly held by women. If enacted, this policy could collapse the pipelines feeding our healthcare, education, public health, and mental health systems.
The data tells a disturbing story. A google search shows that most of the careers most threatened by this rule are almost entirely female:
• 77% of educators
• 80% of social workers
• 89% of occupational therapists
• 96% of speech-language pathologists
• 87–99% of nurses
• 79% of public health workers
• Most counseling, therapy, and allied health fields
Removing student loan access from these programs is not a neutral act. It is a targeted one.
If this rule goes forward, healthcare will suffer immediately. We already face a severe nursing shortage. Removing the financial pathways to enter nursing or advanced practice will result in fewer clinicians at the bedside and in clinics. Rural communities — where NPs and PAs often serve as the primary providers — will be hit hardest. Education will suffer soon after. Graduate programs will lose enrollment, faculty pipelines will shrink, and the nation’s teacher and mental health shortages will deepen.
This policy will not fix student debt. It will prevent people — especially women — from accessing the education required to serve the public.
The discussion around CIP codes seems to be a distraction and not based on truth. This information does not align with why you are changing the language on which careers are considered a profession. Restore the careers back to the list.
Nai'eema Jackson | 11/21/2025 1:50:14 PM
I’m firmly opposed to the Department of Education’s proposal to strip graduate-level nursing degrees – including MSN, DNP, CRNA, CNM, CNS, and APRN programs – of their “professional degree” status.
This move is harmful, short-sighted, and puts both the profession and the healthcare system at risk.
Advanced nursing degrees are professional degrees. Period. They meet every standard:
Advanced Clinical Expertise: These programs require intensive clinical training, national certification, and advanced competencies on par with medicine, pharmacy, and dentistry. Acting like that’s not “professional” is wild.
Essential Workforce Contribution: APRNs and other advanced-trained nurses are the backbone of access in this country, especially in rural and underserved areas. Removing professional status destabilizes care where it’s already fragile.
Public Health Impact: We’re already facing shortages and rising complexity in patient care. Declassifying these degrees weakens the pipeline at the exact moment the nation needs more advanced providers, not fewer.
Equity and Access: This change would hit working nurses, low-income students, rural students, and first-gen learners the hardest by disrupting financial aid and loan structures tied to professional programs. It punishes the very people who keep the system running.
Professional Standards: Graduate nursing education has always been recognized as a professional path requiring advanced academic rigor, clinical mastery, and national licensure. This proposal goes against accreditation standards, industry norms, and federal workforce goals.
For all these reasons, I strongly urge the Department of Education to maintain professional-degree classification for advanced nursing programs. Protect the integrity of the field. Protect access to training. Protect patient safety.
Matthew M | 11/21/2025 1:49:51 PM
Subject: Opposition to the Proposed Declassification of Advanced Nursing Degrees from “Professional Degree” Status
I strongly oppose the Department of Education’s proposal to reclassify graduate-level nursing degrees, such as MSN, DNP, CRNA, CNM, CNS, and APRN programs, out of the “professional degree” category.
This change would have significant and harmful implications for the nursing profession and for the safety and stability of the U.S. healthcare system.
Advanced nursing degrees meet every criteria of a professional field:
1. Advanced Clinical Expertise: Graduate nursing programs require extensive clinical training, national certification, and advanced competencies comparable to other professional degrees such as medicine, pharmacy, and dentistry.
2. Critical Workforce Role: APRNs and advanced-trained nurses provide high-quality, cost-effective care, especially in underserved and rural communities where access to healthcare is already critically limited.
3. Public Health Impact: Declassifying these degrees threatens the pipeline of highly trained nurses at a time of workforce shortages, increased demand for primary care providers, and rising complexity in patient care.
4. Economic and Educational Equity: Reclassification would reduce access to essential financial aid and loan structures, disproportionately harming working nurses, low-income students, rural students, and first-generation learners who rely on professional-degree financial protections.
5. Consistency and Recognition: Graduate nursing education has long been recognized as a professional pathway requiring advanced academic rigor, clinical mastery, and national licensure. Declassification contradicts established standards across accreditation bodies, industry expectations, and federal workforce initiatives.
For these reasons, I urge the Department of Education to maintain professional-degree classification for advanced nursing programs.
Joan O’Hanlon C | 11/21/2025 1:44:39 PM
I strongly oppose removing nursing and advanced nursing education from recognition as a profession. Nursing is essential to the nation’s healthcare system, and this change will directly harm public health.
Advanced Practice Registered Nurses provide critical primary care, maternal care, mental health services, and support in rural and underserved areas. These roles require advanced scientific training and significant clinical responsibility. Removing nursing from the professional-degree category will take away key financial supports and create new barriers for students who already face high costs, unpaid clinical hours, and reduced income during training.
This will not make education more affordable. It will drive qualified people—especially those from disadvantaged and underrepresented communities—away from the field at a time when we face severe provider shortages.
Nursing is and must remain recognized as a profession. This proposal should be withdrawn to protect healthcare access and public health.
Tauqilla M | 11/20/2025 6:37:48 PM
Nursing has one of the highest percentages of first-generation, minority, and second-career graduate students who rely heavily on unsubsidized and PLUS loans. How does NASFAA expect the new loan limit changes to affect access to advanced nursing education for underrepresented groups, including Black, Hispanic, and rural students?
Tauqilla M | 11/20/2025 6:36:30 PM
It is noted that schools can implement lower institutional loan limits starting in 2026, applied by program. Given that many nursing programs already have high clinical fees and limited scholarship funding, are there any concerns that institutions may disproportionately apply lower limits to nursing students compared to other health professions?
Does NASFAA recommend any protections or consistency guidelines for nursing borrowers?
Tauqilla M | 11/20/2025 6:32:32 PM
Given the ongoing national shortage of advanced practice nurses, particularly in primary care, anesthesia, maternal health, and behavioral health, has NASFAA or ED conducted any workforce impact analysis on how excluding nursing from the professional degree definition may affect the pipeline of DNP, CNM, CRNA, and NP providers?
If no such analysis exists, does NASFAA plan to advocate for one before final rulemaking?
Tauqilla M | 11/20/2025 6:28:41 PM
Considering loan repayment & workforce retention, how might the new Repayment Assistance Plan (RAP) affect nurses working in lower-paying, public service, or community health roles, especially those in underserved or rural areas?
Could these repayment changes help or harm efforts to retain nurses in critical shortage areas?
Tauqilla M | 11/20/2025 6:27:02 PM
Two part question:
How will the elimination of Graduate PLUS loans affect nurses pursuing doctoral or advanced practice programs, given the already significant financial barriers in nursing education?
In what ways should nursing schools and advisors begin preparing future nursing students to strategically plan for these new loan limits and repayment structures?
Tauqilla M | 11/20/2025 6:25:25 PM
Question 1: The article states that advanced nursing programs like NP, DNP, CRNA, and CNM are not considered “professional degrees” because they do not share the same 4-digit CIP code as the 11 designated professional programs even if they meet the licensure, doctoral education, and skill requirements.
Do you think excluding nursing solely based on CIP code, despite meeting all other professional program criteria undermines the value of advanced nursing education? Should doctoral-level nursing programs be reconsidered as professional degrees for loan eligibility purposes? Why or why not?
Nedi G | 11/20/2025 5:55:55 PM
For school that package PLUS loans I'm wondering if you're awarding the entire $20k for year one. Hate to leave the parents hanging in year 4 with $5k eligibility.
Mary Ellen D | 11/20/2025 2:59:41 PM
Is there guidance on adjusting for less than half-time enrollment? For example, a student enrolled for 7 credits at the start of a term - are they eligible for 1/2 the term amount or is the proration based on enrollment intensity? If the student enrolls full-time for the second semester, can their eligibility for the award year be increased to the annual limit?
Ben R | 11/20/2025 2:48:55 PM
Since ability to repay is based on a student’s total accumulated debt, not just the debt incurred for a particular program, it will be interesting to see how program-based loan limits play out. In theory, if a student enters your school with prior debt that already exceeds the debt you would allow for the program they want to enter; they shouldn’t be able to borrow any more since they will have trouble repaying the total. However, it’s highly doubtful schools will turn away students based on prior debt as long as they are under the federal lifetime limits. This presents a conflict in the purpose of the limit in the first place.
It remains to be seen how this as well as how to apply limits in the presence of PSLF or IDR, where there is no "too much" borrowing.
Nicole B | 11/20/2025 2:24:47 PM
I would just like to clarification as well that the annual loan limit adjustments on less than full-time enrollment is in no way impacted by students who may stay enrolled full-time but receive a F grade (unrelated to R2T4 calculations).
Nicole B | 11/20/2025 1:46:27 PM
What is the definition of "program of study" for a graduate student?
Bee S | 11/20/2025 11:44:56 AM
Looking forward to additional explanation and examples of remaining time for legacy loan eligiblity particularly for students who attend less than full time. For example, a student who is in a 3 year PHD program attending part time -- on July 1st they have taken out loans for 2 years thus far, but completed 1 full time years worth of credits, and there for have 2 full time year's worth of credits remaining. Going only part time, this would take them 4 years to complete. Do they lose legacy loan provisions after 2 more years (because that's all it would have taken if they went full time), or can they still get it them that 3rd year?
Paul L | 11/20/2025 11:18:55 AM
Will sub/unsub loans borrowed prior to July 1st, 2026 count against the $100,000 grad/$200,000 professional lifetime cap?
Hollie F | 11/20/2025 10:35:31 AM
How does the loan proration affect Summer term amounts?
Nick A | 11/20/2025 10:27:11 AM
Based on the example above, if a student starts as full time in Fall, then reduces their credits that semester after their disbursement, they do not need to return anything for Fall. But it might reduce the amount for their Spring disbursement? So even if they are going full time again in Spring, the amount they can borrow may be reduced?
Katherine C | 11/20/2025 9:34:15 AM
All the RISE discussion & examples were for scheduled AY schools. For schools with year-round enrlmt and standard quarter terms with BBAY loans, when does the onset of the reduction rules begin for a crossover multi-term loan occur? It seems inappropriate to apply those rules before a crossover loan period has elapsed, and loans are commonly made for whole BBAYs rather than single terms.
Chris P | 11/20/2025 9:30:52 AM
My understanding from listening to the negotiations and from the RISE Consensus language is that Parent PLUS loans are indeed subject to proration when the student is enrolled on a less than full-time basis. Can you please confirm?
David H | 11/20/2025 8:59:52 AM
Hi NASFAA, Please post some articles with refreshers about all the T-IV aid implications of Leave of Absence policies. Our institution doesn't currently have a LOA policy, but must now consider doing so based on the new LOA legacy provisions. "Students who take an approved leave of absence (LOA) in accordance with CFR 668.22 would not be considered to have withdrawn or otherwise ceased attendance, so they could continue borrowing under the legacy provisions when they returned to school, provided they met the other legacy requirements."
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