Nurses Left Out of DOE’s Higher Loan Limits for Professional Degrees

On average, one in three nurses had outstanding student debt in 2024, with an average balance of $47,000, according to Fidelity’s 2025 Nurses Financial Wellness and Retirement Readiness Study. The trend may change in ways that remain unclear, as advanced nursing students have been excluded from new borrowing caps on federal graduate student loans proposed by the Department of Education’s Reimagining and Improving Student Education committee.

Graduate students can currently borrow up to the full cost of attendance in their program, less any other financial assistance, using a Grad PLUS loan. When Grad PLUS is eliminated on July 1, 2026, as Congress approved in a provision of July’s One Big Beautiful Bill Act, the proposed regulations would cap annual loans for graduate studies at $20,500 per year ($100,000 total) and professional program studies at $50,000 per year ($200,000 total). These regulations will be finalized after a public comment period concluding in early 2026.

DOE to Garnish Wages

While it is unclear if, or what proportion of, nurses have defaulted on student loans, however, the DOE confirmed to PLANADVISER on December 23 nurses may be among borrowers who could have a portion of their pay withheld under department plans to begin in early 2026 garnishing wages of anyone with defaulted federal student loans.

“We expect the first notices to be sent to approximately 1,000 defaulted borrowers the week of January 7, and the notices will increase in scale on a month-to-month basis,” a DOE spokesperson wrote in an emailed response to questions. “All [Flexible Spending Account] collections activities are required under the Higher Education Act of 1965 and Debt Collection Improvement Act of 1996 and conducted only after student and parent borrowers have been provided sufficient notice and opportunity to repay their loans.”

The news follows the DOE’s April announcement that it would resume collections on defaulted loans in May for the first time since March 2020.

Eligibility Changes Coming

On November 6, the DOE’s RISE rulemaking committee inched closer to implementing the caps on federal graduate student loan limits passed in the OBBBA. The DOE reported reaching consensus after several weeks of a “negotiated rulemaking session” with organizations including and representing the interests of institutions of higher education, student loan borrowers and taxpayers.

The proposed regulation also defines 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;
• Is generally at the doctoral level, and that requires at least six academic years of postsecondary education coursework for completion, including at least two years of post-baccalaureate level coursework;
• Generally requires professional licensure to begin practice; and
• Includes a four-digit CIP code.”

The DOE also specified 11 fields of study that meet the requirements to be considered professional and therefore fall under the new maximum loan limits. While the DOE’s framework is designed to clarify the types of degrees that qualify for higher federal loan limits, it has also sparked concern from educators, students and health care organizations over the exclusion of nursing: a field long recognized as requiring advanced education, licensure and special training.

A change to how much graduate students can borrow, and which degrees will qualify for professional loan levels, could affect the eligible workforce available to health care employers and increase the financial stress faced by nurses and other licensed health care workers.

The graduate professional degrees that will qualify under the higher borrowing limits are: Chiropractic (D.C. or D.C.M.); Clinical psychology (Psy. D. or Ph. D.); Dentistry doctorate (D.D.S. or D.M.D.); Law (L.L.B. or J.D.); Medicine (M.D.); Optometry (O.D.); Osteopathic medicine (D.O.); Pharmacy (Pharm. D.); Podiatry (D.P.M., D.P., or Pod. D.); Theology (M. Div., or M.H.L.) and Veterinary medicine (D.V.M.).

Concerns Over Nurses’ Financial Wellness

Sangeeta Moorjani, head of tax-exempt business and retirement solutions at Fidelity Investments, told PLANADVISER in August that experts estimated by 2030, the U.S. will need to hire 1.2 million additional nurses to meet staffing needs.

Meanwhile, in the Nurses Financial Wellness and Retirement Study, Fidelity also reported that only 56% of working nurses were projected to reach their retirement goals at the time it conducted its study. More than 50% of nurses had less than five years of tenure, “highlighting a workforce that is early in their careers and potentially less financially prepared,” the report stated.

“For a health care organization to be successful, we need to make sure that nurses are successful,” Moorjani said.

Organizations representing the interests of nurses voiced concern over nurses’ financial health, including in response to the proposed DOE loan regulations.

“Nurses make up the largest segment of the health care workforce and the backbone of our nation’s health system,” said Jennifer Mensik Kennedy, president of the American Nurses Association, in a statement responding to the proposed regulations. “At a time when health care in our country faces a historic nurse shortage and rising demands, limiting nurses’ access to funding for graduate education threatens the very foundation of patient care.” 

Communicating to Prospective Students

“We don’t have a long runway,” says Alex DeLonis, assistant vice president of financial services at Saint Louis University. “Some [solutions] might come just in time.”

The university’s Trudy Busch Valentine School of Nursing trains students for professional nursing practice at baccalaureate, master’s, post-master’s and doctoral levels.

Any solutions would benefit prospective students. The DOE RISE committee agreed, during the rulemaking period, to regulatory language that specifies the borrowing limits will apply only to loans taken out for enrollment beginning on or after July 1, 2026. Students who were enrolled in a program of study as of June 30, 2026, and for whom a direct loan was made for that program of study prior to July 1, 2026, can continue borrowing under the Grad PLUS program. The legacy eligibility would continue for the lesser of three academic years or the student’s expected time to until earning the sought credential.

DeLonis says one of his main concerns as a higher education professional is an unreliable source spreading misinformation to potential nursing students. A prospective student might decide the future of their education based on inaccuracies.

“Institutions can step up and help [distribute correct] information,” DeLonis says. “My hope … is that [they] can be part of the solution to making sure that even for one year, we don’t see a gap in the [number] of students enrolling in these programs so those professions can have the right people.”

It is also important for institutions to draw the distinction that the loan limits affect graduate nursing programs only, DeLonis adds. According to a November 24 release from the DOE, 95% of graduate nursing students borrow below the coming annual loan limit.

DeLonis says that while St. Louis University has not finalized its own plans for operating under the proposed regulations, schools nationwide may look at adjusting their pricing and scholarship awards, among other actions, to help students finance their education. 

The DOE’s November release stated the new limits are needed because the ability for graduate and professional students to borrow up to the full cost of attendance has “allowed colleges and universities to dramatically increase tuition rates, even for credentials with modest earnings potential, which has saddled too many borrowers with debts they find difficult to repay.” According to the department, it is a “myth” that the proposed changes will drive tuition costs up. As an example, the DOE points to Santa Clara University School of Law’s decision in September to cut $16,000 in tuition costs for all incoming juris doctor students. A J.D. degree is the standard required for practicing law in the U.S.

Sonia Lewis, CEO of The Student Loan Doctor LLC, says institutions will have to realign their costs if they would like to keep enrollment as is or better.

“I think we’re going to see colleges and universities go through a major overhaul of their tuition, but the bigger question is, ‘is that sustainable for them to stay open?’” Lewis explains.

DeLonis, however, stated that loan limits are “not brought up” when institutions set tuition prices or determine student scholarships.

Before the DOE issues final regulations on the new loan limits, Lewis said she would like to see the department break down loan default rates by field to see what professions and demographics the regulations would impact most. She also believes nursing shortages will push current employees to stay on the job and retire later due to influence from their employers and passion for their work.

“With no data, how [is the DOE] choosing these fields [to exclude?]” Lewis asks.

PLANADVISER reached out to several health care organizations that declined to comment on the proposed regulations.