The U.S. Department of Education’s proposed regulation, Reimagining and Improving Student Education, would amend the definition of “professional student” to exclude nurse practitioners and other advanced practice providers. Accordingly, graduate students seeking the Master of Science in Nursing (MSN) degree, required of all nurse practitioners, would, for the first time, be subjected to lifetime graduate student loan caps of $100,000. “Professional students,” which the regulation defines as those attending medical, law, dental, and divinity school, among others, are subject to a lifetime graduate student loan cap of $200,000 – twice as much as those not falling in the “professional” category. For most nurses seeking graduate education, $100,000 is clearly insufficient, as the average cost of one year in an MSN program can run $50,000 or more. NPs and advanced practice providers like physician associates (PAs), certified nurse midwives, and advanced practice psychiatric nurses comprise the majority of safety net providers and serve as the backbone of community health center networks. Any interruption to the primary care pipeline, especially regulations endangering the training of advanced practice providers, jeopardizes the care of all Americans, particularly health center patients.
The comment period for the proposed regulation closed on March 2, and the Department of Education received over 80,000 submissions. As of March 23, 2026, the Department is still in the process of validating and posting comments on their website. Of the 19,630 comments currently posted, a cursory scan shows an overwhelming majority are in favor of designating nursing (and PA) graduate programs as professional programs eligible for the $200,000 lifetime graduate student loan cap. Our own Margaret Flinter, PhD, APRN, c-FNP, FAAN, FAANP, Senior Vice President and Clinical Director of Community Health Center, Inc., was among those who submitted comments. Below, find Margaret’s introduction and a link to her full letter. Also see letters from the U.S. Congress and the National Association of Community Health Centers.
March 2, 2026. On behalf of the Moses Weitzman Health System (MWHS) and its Community Health Center, Inc. (CHCI), one of the country’s largest FQHCs, I respectfully submit these comments and the attached letter. CHCI cares for more than 100,000 patients annually. More than half of its primary care provider workforce are Advanced Practice Providers, primarily adult, family, and pediatric nurse practitioners as well as certified nurse midwives and psychiatric/mental health nurse practitioners (NPs). Our mission and charge–to provide outstanding health care in underserved communities to people who need it most–depends on our expert workforce. We urge the Department of Education to explicitly include the profession of nursing in the category of “professionals”. Not including nursing would likely have the unanticipated consequence of seriously and negatively impacting the future primary care provider workforce of the United States as well as the primary care provider workforce of federally qualified health centers. FQHCs care for over 31m people annually. NPs are a major component of the primary care workforce in health centers, where they assume the professional role of primary care provider for panels of patients who rely on them for their expert care. While the majority of nurses in the U.S. hold a baccalaureate degree, 100% of nurse practitioners/advanced practice registered nurses (APRNs) must hold a master’s degree or above to qualify for licensure and board certification as required for practice. Removing nursing from the category of professionals reduces the lifetime federal loan limit from $200,000 to $100,000, potentially putting an APRN career out of reach for many. I ask you to include nursing–one of the most trusted and accountable health care professions–in the category of professionals, where they belong, ensuring their continued eligibility for federal student loans at the upper limit of $200,000. Thank you for your consideration.
Full text of Margaret’s letter can be found HERE.