Updated April 30
The Department of Education has finalized new limits on federal student loan borrowing that provider groups said will hamstring the supply of new clinical professionals.
The caps, outlined in last summer's One Big Beautiful Bill Act, are part of broader student loan changes the administration said will disincentivize educational institutions from raising their tuition rates, protect students from overborrowing and broadly "improve the health of the federal student lending system."
While the department is bound to language in the law setting borrowing limits of $20,500 per year and $100,000 in aggregate for "graduate students," healthcare groups criticized the administration for proposed definitions that bind numerous advanced practice providers to the lowered caps and generally reserve higher limits of $50,000 and $200,000 for "professional" degree programs to doctorate-level degrees. Thursday's final rule cements those industry-opposed definitions.
“This final rule will limit baccalaureate-prepared nurses' ability to pursue advanced degrees, including the Master of Science in Nursing, Doctor of Nursing Practice, Doctor of Nurse Anesthesia Practice and Doctor of Philosophy in Nursing, the very degrees that produce the advanced practice nurses and educators our country so desperately needs," Jennifer Mensik Kennedy, Ph.D., president of the American Nurses Association, said in a statement. "Make no mistake, this is not a technicality or a footnote. This rule will be felt in real communities, for example, in rural areas where nurse practitioners, midwives and nurse anesthesiologists are often the only providers of core care services."
In releases and comment letters penned following the rule's proposal, provider organizations representing hospitals, nurses, medical schools, physicians, nursing homes, physicians associates and others called on the department to use its discretion to include more advanced roles in the definition of a "professional" degree program. Alongside the high demand for those positions, they cited statistics on the high average salaries these positions offer and the historically low rate of defaults among those degree owners (read more on those arguments below).
March 2
Providers urge Education Department to reconsider which jobs face stiffer student loan caps
Provider groups are pushing the Department of Education to reconsider a proposed policy change that would limit the amount in-training nurses, physician assistants and other post-baccalaureate health professionals could borrow for a federal student loan—which they say could kneecap the clinical workforce pipeline and reduce the public’s access to care.
The proposal is part of the department’s implementation of the One Big Beautiful Bill Act, which outlined new borrowing limits to go into effect July 1, 2026. The administration has said the changes will help slow rising tuition costs and protect students from debt.
Specifically, the law limits “graduate students” to borrowing limits of $20,500 per year and $100,000 in aggregate, though those enrolling in a “professional” degree program have higher ceilings of $50,000 per year and $200,000 in aggregate. Graduate and professional students had previously been able to borrow up to the full cost of attendance.
The rub for provider groups is that the department’s proposed definition of the professional degree programs is limited to 11 roles—including medicine, pharmacy and other specialty doctorates—and excludes advanced practice registered nurse (APRN) roles, such as nurse practitioners (NPs) and certified registered nurse anesthetists, as well as other professions like social workers or physical therapists.
Providers, in lockstep, have been sounding the alarm on the issue for the past few months. In recent letters submitted during an open comment period closing March 2, their industry associations as well as individual organizations made their formal appeal for the department to change its proposed definition and allow more healthcare roles to borrow under the professional degree’s higher limits.
A missive from the American Hospital Association (AHA), for instance, highlighted data from the National Center for Education Statistics outlining an average annual cost of more than $30,000 per year for nurses and social workers seeking graduate degrees. Physical therapist degrees average between about $108,000 and $126,000 before additional living expenses and other fees, the lobby added.
“Reduced enrollment would severely constrain the pipeline of clinicians, limit hospitals’ ability to staff care teams, increase patient wait times and reliance on emergency care and weaken health system readiness in the event of a natural disaster or public health emergency,” the AHA warned in its letter. “The effects could be especially pronounced in rural and underserved communities, where APRNs are often vital for maintaining access to high-need critical services, like anesthesia and critical care. For example, in 70% of rural hospitals, anesthesia is administered by certified registered nurse anesthetists.”
The AHA added that the Education Department has the flexibility to expand the definition under the statute and said the description of a professional student given by Congress is in line with post-baccalaureate health roles even if they are not mentioned by name.
The American Nurses Association (ANA), in its letter, echoed those points while taking issue with the department’s given rationale for excluding post-baccalaureate nursing programs—state-by-state variation in NP practice authority.
The group said it is “extremely disappointed that [the department] cites outdated regulatory barriers,” which are the result of those states’ “political decisions” and “are not reflections on whether APRNs are a distinct profession, or have educational and clinical expertise and experience to practice to the fullest extent of their profession and licensure.”
The ANA added that APRNs typically earn solid pay and have historically low rates of default on their student loans and that the education department’s proposal would be “inconsistent with other policymaking within” both the first and second Trump administrations such as the Rural Health Transformation Program’s large focus on practicing at the top of a profession’s scope.
The American Academy of Physician Associates, in its letter, made similar critiques of the department’s scope of practice and physician supervision angle. On the former, the group said "the same logic would exclude nearly every licensed healthcare profession"; on the latter, it stressed that “collaboration” between doctors and physician associates “is not a marker of diminished professional status [but] the backbone of coordinated, patient-centered care.”
The American Academy of Medical Centers, the American Academy of Family Physicians, the American Association of Colleges of Nursing, the American Health Care Association/National Center for Assisted Living, the American Association for Nurse Anesthesiology and the American Organization for Nursing Leadership are among the groups that have submitted comments requesting an expansion on the definition of a professional degree.
As of midday Monday, about 65,000 total public comments had been submitted on the department’s proposed rule, though some address the borrowing restrictions that would be placed on others training for non-healthcare professions.