Nursing as a Professional Degree

Public Comment Period Open

The public comment period on the proposed rule (see below for background) is currently open to submit a personalized comment to the Department of Education. Any comments should be submitted as soon as possible prior to the March 2 deadline.

If finalized as currently written, the Department’s proposed rule would significantly reduce the federal loan amounts available to post-baccalaureate nursing students, which would have direct impacts on the future nursing workforce. Add your comment here. (A sample comment is included for you below.)

Sample Comment:

Subject: Support Nursing as a Professional Degree

As a psychiatric-mental health (PMH) nurse I am deeply concerned with the proposed rule, which does not include post-baccalaureate nursing programs in the definition of professional degree programs. The detrimental impact this decision will have on students and the nursing workforce cannot be understated. Rising rates of mental health and substance use disorders are significant challenges across the country, compounded by a shortage of mental health professionals, which leaves millions without the treatment they need. PMH-APRNs, who provide the full scope of psychiatric services, are critical to addressing these gaps in care. Therefore it is critical that the advanced education of PMH APRNs is fully valued and supported. I urge the inclusion of post-baccalaureate nursing degrees (MSN, DNP, PMHNP) explicitly in the list of professional degrees.

The failure to include post-baccalaureate nursing in the definition of “professional” degrees would unnecessarily limit federal financial aid for those pursuing advanced nursing education. Without access to “professional” borrowing limits, many qualified students will be unable to pursue post-baccalaureate nursing education, directly affecting the nursing workforce pathways. Research has found that the average annual cost of post-baccalaureate nursing programs is approximately $38,500, nearly double the new annual graduate borrowing cap.

PMH-APRNs decrease barriers to mental health care: They accept commercial insurance, Medicare, and Medicaid, while the number of other mental health providers that accept insurance has been rapidly declining. PMH-APRNs are also the fastest growing group of providers providing medication treatment for opioid use disorders. However, their supply in rural areas continues to be a gap: As of 2021, nearly 69% of rural counties still had no PMH-APRNs. Maintaining access to post-baccalaureate nursing education is imperative to support continued growth of these critical providers of psychiatric-mental health care and ensure sufficient numbers of faculty to support the preparation of future nurses.

As the Department moves forward with its rulemaking process, I strongly request the inclusion of post-baccalaureate nursing degrees (MSN, DNP, PMHNP) in the list of professional degrees. Nurses are the backbone of our healthcare system, and it is essential that the Department of Education include nursing as a professional degree to avoid implementing harmful barriers to the pursuit of post-baccalaureate nursing education.

---

Background

As a part of its current rule-making, the Department of Education may use 1960s-era definitions of “professional” and “graduate” degrees to determine loan limits. This action stems from an intent to curb student loan debt and tuition costs as part of the One Big Beautiful Bill Act. Unfortunately, if the department uses these definitions, post-baccalaureate nursing students would only be eligible for half the amount of federal loans as graduate medical students.

---

Key Information

• The Department of Education’s Reimagining and Improving Student Education (RISE) Committee’s rulemaking to implement the student financial aid provisions under Public Law 119–21 released a proposed framework that omits post-baccalaureate nursing degrees from the regulatory definition of “professional degree”
• The proposed definition describes a professional degree as one that “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” and that “generally requires professional licensure to begin practice.”
  • Post-baccalaureate nursing degrees satisfy these criteria: RNs must pass the National Council Licensure Examination to enter the profession; APRNs must have a graduate degree, such as an MSN or a DNP, and require national certification and state licensure to practice
• The classification of a professional degree vs. a graduate degree matters because the law states that students earning professional degrees may borrow up to $50,000 annually and $200,000 aggregate, while students earning graduate degrees have borrowing limits capped at $20,500 annually and $100,000 aggregate.

Track the latest updates with the American Association of Colleges of Nursing Policy Watch: Support for Nursing as a Professional Degree.

---

Get Involved

Nursing organizations have come together to collect signatures on a petition asking the Department of Education to include nursing in its proposed ‘professional degree’ program definition.

See the Petition