IPHA Advocacy Alert

IPHA Advocacy Alert

Ensure Higher Federal Loan Limits for All Degree Programs Act Now - Federal Comments Close on March 2, 11:59 PM

Join Our Sign-on Letter | Join by 2/27 at Noon | Please share!

Background

At the end of January 2026, the U.S. Department of Education (ED) released a Notice of Proposed Rulemaking that significantly restricts the definition of a "professional degree" for federal student loan purposes, limiting higher borrowing capacities to a narrow set of 11 specific fields.

This rule, which is scheduled to take effect on July 1, 2026, originates from the One Big Beautiful Bill Act (OBBBA) signed in July 2025, which established a two-tiered system for federal graduate loans.

The Proposed Changes

• Definition Restriction: The proposed rule narrows the "professional degree" classification to only 11 specific programs: Pharmacy (Pharm.D.), Dentistry (D.D.S./D.M.D.), Veterinary Medicine (D.V.M.), Chiropractic (D.C.), Law (J.D.), Medicine (M.D.), Optometry (O.D.), Osteopathic Medicine (D.O.), Podiatry (D.P.M.), Theology (M.Div.), and Clinical Psychology (Psy.D./Ph.D.).
• Loan Limits:
  • Professional Students: Eligible for up to $50,000 annually and $200,000 in aggregate loans.
  • Graduate Students (Excluded Fields): Capped at $20,500 annually and $100,000 in aggregate loans.
  • Elimination of Grad PLUS: The rule would eliminate the Grad PLUS program, which currently allows students to borrow up to the full cost of attendance.

Impacted Fields

Many fields previously considered professional or in high demand are excluded from the new definition, reclassifying them as "graduate" rather than "professional."

• Nursing & Healthcare: Master's and doctoral nursing programs (Nurse Practitioners, Nurse Administrators), physician assistants, physical therapy, and occupational therapy.
• Other Fields: Social work, public health, and architecture.

Rationale and Controversy

• Department of Education's Position: The Department of Education notes this is an internal definition meant to distinguish programs eligible for higher loan limits based on the new legislation, rather than a value judgment on the importance of the profession. The aim is to reduce student debt and "hold universities accountable for outcomes".
• Opposition: The Illinois Public Health Association (IPHA), Illinois Public Health Nurse Administrators (IPHNA), local health departments, IPHA members, and partners are concerned that the proposed definition excludes several critical fields that underpin the public health workforce, including nursing, physical and occupational therapy, physicians' assistants, and social work. Rural communities are likely to feel the impact most acutely, as advanced practice clinicians often serve in roles typically filled by physicians in those settings. In addition, limiting borrowing capacity for graduate-level degrees could impact the number of nurse educators, having a downstream effect on training programs and the broader pipeline.

Commenting on the Proposed Rules

Your advocacy can make a difference-and now is a vital time to raise our voices and keep up the pressure.

Please take one (or more) of these actions today:

1. Join our sign our letter. IPHA along with our Nursing Section, and the Illinois Public Health Nurse Administrators have developed a sign on letter to submit comments to the Department of Education. The letter can be read here. Please share with colleagues, family, and friends..

2. Respond to the Department of Education. Students and affected professions should submit comments to the Department of Education to object to the proposed definitions. All degrees that give someone more professional skills should be included not just the proposed 11 degree programs. Note that duplicated comments only count once. Submit comments here.

3. Call your members of Congress. Sharing your personal story directly is one of the most effective ways to influence policymakers. "5 Calls" has talking points available. (5 Calls is an app and website designed to make civic engagement easy by helping U.S. constituents call their representatives. It provides, based on your location, contact information for local and federal officials, along with issue-based scripts for calls, aimed at encouraging, on average, 5 calls per day.)

4. Encourage others to act. Colleagues, friends, students, and supporters can write or call their legislators-even if they are not members of these professions, or students.

Thank you for joining us in this important advocacy effort.

• Conny Moody, IPHA | [email protected]
• Amanda Mehl, IPHNA | [email protected]
• Emily Hendrickson, IPHNA | [email protected]
• Laura Barrett, IPHA Nursing Section | [email protected]
• Sarah Williams, IPHA Nursing Section | [email protected]

Tips for writing your own comments:

• Please be concise but include objective sources of support for your claims.
• Explain your views as clearly as possible and refrain from using any profanity.
• Refer to specific sections and subsections of the proposed regulations throughout your comments, particularly in any headings that are used to organize your submission
• Explain why you agree or disagree with the proposed regulatory text. We encourage commenters to include supporting facts, research, and evidence in their comments. When doing so, commenters are encouraged to provide citations to the published materials referenced, including active hyperlinks. Providing such citations and documentation will assist in analyzing the comments.
• Where you disagree with the proposed regulatory text, suggest alternatives, including regulatory language, and your rationale for the alternative suggestion.
• Do not include PII such as Social Security numbers or loan account numbers for yourself or for others in your submission.

Join Sign On Letter Here

If you have questions, please contact Conny Moody, IPHA Government Relations and Compliance, at [email protected] or email [email protected].