Alexandria, VA — DNPs of Color stands with the American Nurses Association and the American Association of Colleges of Nursing in responding to the U.S. Department of Education’s proposed rulemaking that would exclude nursing from the definition of “professional degree” and significantly limit federal student loan access for graduate nursing students.
The issue
The proposed amendments to 34 CFR § 685.102 would establish a new definition of “professional degree” that excludes nursing based on Classification of Instructional Programs (CIP) code grouping—rather than the actual characteristics of the education or profession.
Under the framework adopted November 6, 2025, only programs with CIP codes “in the same intermediate group” as eleven enumerated professions (Pharmacy, Dentistry, Veterinary Medicine, Chiropractic, Law, Medicine, Optometry, Osteopathic Medicine, Podiatry, Theology, and Clinical Psychology) would qualify as professional degrees. Beginning July 2026, federal loan caps will be $20,500 annually for graduate students versus $50,000 for professional students—making this distinction critically important for nursing students’ educational access.
This exclusion affects Master of Science in Nursing (MSN), Doctor of Nursing Practice (DNP), and PhD pathways that prepare licensed providers serving rural and underserved communities. Nursing meets every substantive requirement: academic preparation for licensure, professional competencies beyond a bachelor’s degree, and state licensure to practice. Yet we are excluded on a technicality.
Our position
Advanced practice nurses function as independent, licensed healthcare providers—often the only healthcare presence in rural communities. Excluding nursing from this definition undermines decades of work toward parity across health professions and contradicts our national healthcare workforce needs during persistent nursing shortages.
We urge ED to revise the proposed definition to include nursing, thereby maintaining workforce pipelines and preserving educational access.
Potential implications
If finalized without including nursing, this rule may:
- Limit graduate nursing education access for students depending on federal aid
- Reduce the healthcare workforce pipeline during critical shortages
- Decrease healthcare access in rural and underserved communities
- Disproportionately affect students of color and underrepresented students
Call to action
The Department of Education’s RISE Committee concluded negotiated rulemaking on November 6, 2025. The Department will publish a Notice of Proposed Rulemaking (NPRM) in the Federal Register for public comment.
We encourage all stakeholders to monitor www.federalregister.gov for the NPRM regarding 34 CFR § 685.102 and participate in the public comment period. More information: www.ed.gov/laws-and-policy/higher-education-laws-and-policy/higher-education-policy/negotiated-rulemaking-for-higher-education-2025-2026.
About DNPs of Color
DNPs of Color (DOCs), is a 501c3 nonprofit nursing organization, whose mission is to serve Doctors of Nursing Practice of Color through networking, mentorship and advocacy to increase diversity in doctoral studies, clinical practice, and leadership. Please visit our website www.dnpsofcolor.org and follow us on Facebook, Twitter, and Instagram @dnpsofcolor
