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Important Update: Comment Period Expected to Open Tomorrow on Nursing as a Professional Degree Issue

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This morning, the Department of Education's Office of Postsecondary Education issued the public inspection of the Notice of Proposed Rulemaking (NPRM) for implementing the One Big Beautiful Bill Act student loan limits for post-baccalaureate degrees. The official NPRM is currently scheduled to be published tomorrow (January 30, 2026) beginning the crucial 30-day comment period.

As expected, nursing programs are not designated as "professional degree" programs under the proposal, meaning post-baccalaureate nursing students would be treated as "graduate" students for purposes of the new student loan limits. As a result, nursing students in MSN, DNP, and PhD programs would face the significantly lower borrowing limits assigned to “graduate degree” programs ($20,500 annually/$100,000 aggregate).

Responding to the Department's NPRM is the next step in AACN's ongoing advocacy on this issue, which has included prior comments to the Department, ongoing monitoring of the negotiated rulemaking process, member and media outreach, and engagement with federal agencies and policymakers on Capitol Hill.

Our continued engagement will focus on a coordinated response along with our coalition partners across the nursing community and a unified request to the Department that stresses the importance of recognizing nursing as a professional degree. In the coming days, expect further outreach from AACN about how you too can effectively advocate for nursing as a professional degree.

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