Tri-Council for Nursing Urges Nurses to Submit Comments on Department of Education's Professional Degree Designation Rule

Tri-Council for Nursing Urges Nurses to Submit Comments on Department of Education's Professional Degree Designation Rule

Washington, DC — The U.S. Department of Education proposed rule related to the implementation of the One Big Beautiful Bill Act excludes nursing from the professional degree designation, a decision that contradicts workforce realities, federal policy and basic economics. The Tri-Council for Nursing calls on all nurses to submit public comments requesting the inclusion of post-baccalaureate nursing degrees (MSN, DNP, Ph.D.) explicitly in the list of professional degrees before the March 2 deadline.

All states mandate graduate-level education as a requirement for licensure for advanced practice registered nurses—nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and certified nurse midwives—under the APRN Consensus Model. Their education includes science-based curricula, extensive supervised clinical training and nationally consistent licensure standards that meet or exceed other designated professional degrees.

Bureau of Labor Statistics data show most APRNs earn mean annual wages of $132,000 (nurse practitioners), $231,700 (nurse anesthetists), and $128,110 (nurse midwives). BLS projects 35% APRN growth through 2034—ten times the national average for all occupations—with 32,700 annual openings. APRNs hold indispensable professional roles driving healthcare delivery nationwide, especially as there continues to be shortages of primary, behavioral health, maternal health and other providers across rural and underserved areas.

The administration's $50 billion Rural Health Transformation grant program under the OBBBA incentivizes APRN utilization by rewarding states that expand nurse practitioner scope of practice and support population health infrastructure by expanding scope of practice for other providers. Excluding nursing from the professional degree designation directly undermines this federal investment and harms rural communities and Medicare beneficiaries who depend on APRNs for care.

Sixty-nine percent of post-baccalaureate nursing students rely on federal loans, but average annual costs ($38,500) nearly double the proposed graduate loan limit. American Association of Colleges of Nursing data show:

• 78% of deans expect the $20,500 annual loan cap to reduce enrollment
• 70% anticipate enrollment drops from the $100,000 lifetime cap
• 82% of students report the annual cap will negatively affect their ability to finance education
• 81% say the lifetime cap will have similar impact

National standards require nursing program directors to hold doctoral degrees and faculty to possess graduate-level nursing education. Schools are currently unable to admit thousands of qualified applicants because they lack sufficient faculty. Undermining the professional degree designation will only intensify this crisis and further diminish the nation’s supply of doctorally-prepared faculty, researchers and scientists.

Policymakers need to hear directly from nurses about what's at stake. Your voice matters. Submit your public comment by March 2 on regulations.gov. Tell the Department of Education why nursing is a professional degree. Share your story. Our health care system cannot operate without advanced practice nurses and nurse faculty.

The Tri-Council for Nursing—comprising AACN, ANA, AONL, NCSBN and NLN—represents the nation's leading nursing organizations and speaks for the full continuum of the nursing profession. 

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