While durable medical equipment stakeholders contend with immediate fallout from November’s home health final rule that reshaped Medicare competitive bidding and supplier accreditation, another impending proposed rule could affect the flow of future clinicians into the industry.
As a result of H.R. 1 — also known as the One Big Beautiful Bill signed in July 2025 — the U.S. Department of Education’s Reimagining and Improving Student Education (RISE) Negotiated Rulemaking Committee has recommended that a number of health care-related graduate degrees be redefined as professional degrees.
Students pursuing advanced degrees classified as graduate rather than professional face lower federal loan limits and therefore reduced funding flexibility.
The change would impact funding options for grad students in nursing, occupational and physical therapy, speech-language pathology, and audiology, among other fields. Public health graduate degrees, including social work and counseling/mental health, are also on the list of degrees that could be classified as graduate rather than professional.
The RISE-related proposed definition would sharply limit “professional” designations to such fields as medicine, dentistry, pharmacy, veterinary medicine, chiropractic, optometry, osteopathic medicine, podiatry, and theology.
“A professional degree 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,” said an October 2025 memo submitted to the RISE Negotiated Rulemaking Committee by policy experts from Taxpayers and the Public Interest Constituency. “Professional licensure is also generally required.”
Department of Education: Change will drive universities to lower their fees
A Nov. 24 press release from the Department of Education contends that H.R. 1’s passage “placed common-sense limits on federal student loads for graduate degrees,” and that those limits “will help drive down the cost of graduate programs and reduce the debt students have to take out.” Federal loans for “professional” degrees would be capped at $200,000, while the cap for “graduate” degree loans would be just half of that — $100,000.
Professional associations related to the impacted degrees have strenuously objected to the reclassification proposal, though a Nov. 25 Department of Education press release about nursing degrees contended that capping loans at the lower $100,000 “will push the remaining graduate nursing programs to reduce their program costs.”
“The American Nurses Association (ANA) is concerned by the Department of Education’s exclusion of nursing from the definition of ‘professional degree’ programs under forthcoming federal loan eligibility rules,” the ANA said in a November press release. “This will severely restrict access to critical funding for graduate nursing education, undermining efforts to grow and sustain the nursing workforce.”
“Nurses make up the largest segment of the health care workforce and the backbone of our nation’s health system,” said Jennifer Mensik Kennedy, Ph.D., MBA, RN, NEA-BC, FAAN, president of the ANA. “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. In many communities across the country, particularly in rural and underserved areas, advanced practice registered nurses ensure access to essential, high-quality care that would otherwise be unavailable.”
The American Association of Colleges of Nursing (AACN) also expressed deep concern over the Department of Education’s plan. “Despite broad recognition of the complexity, rigor and necessity of post-baccalaureate nursing education, the department’s proposal defines professional programs so narrowly that nursing, the nation’s largest health care profession, remains excluded,” the announcement said. “Should this proposal be finalized, the impact on our already-challenged nursing workforce would be devastating.”
The American Physical Therapy Association (APTA) and American Occupational Therapy Association (AOTA) have also spoken out about the proposed changes.
“APTA is deeply concerned by the recent recommendation from the RISE Negotiated Rulemaking Committee, which, if enacted, would designate the doctor of physical therapy degree — and dozens of other health care professional degrees — as a graduate degree rather than a professional degree,” the APTA said in a November 2025 press release. “If this proposed definition is adopted via official rulemaking by the Department of Education, the ability to borrow for federal student loans would be severely reduced, threatening to limit the physical therapy workforce at a time of nationwide shortages.”
APTA urged Congress to intervene, “as the proposed definition runs contrary to Congressional intent.”
AOTA, in an October 2025 press release, said, “One of the changes that is the most impactful for occupational therapy was the elimination of the Grad PLUS loan program, leaving post-baccalaureate students with only one federally administered borrowing option, the Direct Unsubsidized Loan program.
AOTA added that H.R. 1 “seemed to set a broad definition for which degrees should be considered professional, using language in regulations defining these degrees as ones where ‘professional licensure is also generally required.’ During negotiations on the bill, Congressional offices communicated that they intended the definition to include a wider range of post-baccalaureate health professions that required licensure.”
And AOTA said it has “led the creation of a broad coalition of over 40 national organizations to advocate that ED [Department of Education] use the broadest list of professional degrees, as we believe was the intent of Congress. We are continuing to work with ED, Congressional champions, and coalition partners to obtain clarification and urgent regulatory changes before this policy causes serious long-term damage to the profession.”
A proposed rule including these changes in expected in early 2026, to be followed by a public comment period.
