The American Association of Colleges of Nursing (AACN) is deeply concerned by the Department of Education’s decision to move forward with a proposed definition of professional degree programs that excludes nursing and significantly limits student loan access. Despite broad recognition of the complexity, rigor, and necessity of post-baccalaureate nursing education, the Department’s proposal defines professional programs so narrowly that nursing, the nation’s largest healthcare profession, remains excluded. Should this proposal be finalized, the impact on our already-challenged nursing workforce would be devastating.

Under the Department’s proposed framework, which was unanimously adopted through the Reimagining and Improving Student Education (RISE) Committee negotiated rulemaking process, professional degree programs are described as:

• Signifying 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;

• Doctoral-level programs that require six or more years of postsecondary study;

• Professional licensure; and

• Classification within the same four-digit Classification of Instructional Programs (CIP) codes as medicine, dentistry, pharmacy, law, theology, and related fields.

While the CIP code series (51) for “health professions” includes nursing, it is not “in the same intermediate group” as the other enumerated fields. Thus, post-baccalaureate nursing programs, including the Master of Science in Nursing (MSN), Doctor of Nursing Practice (DNP), and research-focused nursing PhD, fall outside the professional category.

Our post-baccalaureate nursing graduates are independent providers, systems leaders, and researchers who deliver critical care and drive innovation across communities. Excluding nursing from the definition of professional degree programs disregards decades of progress toward parity across the health professions and contradicts the Department’s own acknowledgment that professional programs are those leading to licensure and direct practice. AACN recognizes that explicitly including post-baccalaureate nursing education as professional is essential for strengthening the nation’s healthcare workforce, supporting the next generation of nurses, and ultimately supporting the healthcare of patients in communities across the country.

The Department is expected to release a Notice of Proposed Rulemaking in the coming weeks, where stakeholders, including AACN, will have additional opportunities to comment. AACN will continue to lead this effort, engage our membership and outside stakeholders, and explore every available avenue to ensure post-baccalaureate programs are included in the definition of professional degree programs.

For more details on our ongoing engagement on this issue, please visit AACN’s policy and advocacy page.