Professional Nurses as Policy Leaders – Post #3

Nurses are involved in policy to advocate for improved healthcare and to improve health inequities. Affirming the passion of a nurse to support policies that protect and empower the weakest among us would be incomplete without a moment to honor Alex Petti as an inspiration.

Here is an example of one nurse’s inspiration and motivation to work in policy. She highlights the policy efforts of the American Nephrology Nursing Association (ANNA).

Returning to the Issue of Nursing as a Profession in Regulatory Language

In the first post related to a current policy concern, we described the challenges of rural and remote healthcare and how solving health inequities in those locations relies in part on a vibrant stream of dedicated advanced practice nurses in the workforce. We acknowledged the proposed policy change in how nursing is defined as a profession (or not) in regulatory language and how that would affect loan caps for advanced practice graduate programs, essentially crimping the workforce pipeline. In our second post, we delved deeper into professionalism, the regulatory framework, and the stakeholders involved in the proposed change. In this post, we get into the nitty-gritty of rule-making and exactly how the process is unfolding to either put the change officially in place or reconsider whether the proposal makes sense.

A Federal Regulatory Issue

As explained previously, the current debate revolves around how the U.S. Department of Education (ED) plans to implement changes required by the One Big Beautiful Bill Act (Public Law 119-21), which amended the William D. Ford Federal Direct Loan Program under Title IV of the Higher Education Act of 1965. Title IV governs federal student aid, including the definition of a “professional degree” used for determining federal loan limits and eligibility under the Direct Loan program. Under the negotiated regulatory language agreed upon by ED and its rulemaking committee, the definition of professional degree in 34 C.F.R. § 668.2 will include only a narrow list of fields (e.g., medicine, dentistry, law, pharmacy, optometry, veterinary medicine, chiropractic, podiatry, clinical psychology, and theology) tied to specific Classification of Instructional Programs (CIP) codes, and does not explicitly include nursing programs such as MSN, DNP, or NP degrees; programs outside those listed would be treated as general graduate programs with lower loan limits and different borrowing caps under Title IV.

What Happens Next?

The rulemaking process goes like this: The statutory trigger happened when Congress amended the Higher Education Act of 1965 and directed the U.S. Department of Education to implement changes through regulation. The Negotiated Rulemaking has been completed under 20 U.S.C. section 1098a. ED convened a negotiated rulemaking committee. Stakeholders included institutions, accreditors, and others. Consensus was not reached on the definition of the professional degree; therefore, ED is legally permitted to proceed with its proposed language. ED published a Notice of Proposed Rulemaking in the Federal Register. This notice proposes a regulatory definition of “professional degree.” It lists qualifying programs, omits nursing programs, and invites public comment.

As of the date of this post, we are in the Public Comment period, which usually lasts 30-60 days and, in this instance, ends on March 2, 2026. Nursing organizations, universities, states, and individuals can submit comments, which become part of the administrative record and must be reviewed by the ED.

Submit Comments Now

Here is how to submit comments: Go to regulations.gov. In the search bar, enter the rule title: Reimagining and Improving Student Education (or search by the U.S. Department of Education). Click the rule labeled “Notice of Proposed Rulemaking (NPRM).” Click Comment. Paste your comment or upload a document (PDF or Word). Enter your name/organization (optional but recommended for credibility). Submit. You will receive a confirmation number — save it.

Or, you can access the comment portal through the policy pages of various professional nursing organizations. The American Association of Colleges of Nursing provides easy access to the comment portal and exemplary language depending on your position and title. Click Here. (Policy Watch, n.d.)

The American Association of Colleges of Nursing (AACN, n.d.) published its early response to this issue in November 2025. The organization subsequently developed a resource page addressing the issue, which includes a survey summarizing the profound impact of this change, links to sign a petition, links to contact Congressional representatives, links to receive alerts, and an ongoing blog of related news and issues unfolding since November 2025 (AACN Alarmed Over Department of Education’s Proposed Limitation of Student Loan Access for Nursing, n.d.; Proposed Federal Loan Changes for Nursing Students, n.d.).

After comments close, ED must review the comments, address significant issues raised, and either revise the rule or justify keeping it as written. ED publishes the Final rule in the Federal Register, including the final regulatory text, a section called “Analysis of Comments and Changes,” and ED’s justification for its decisions. The definition becomes a binding federal regulation. At that point, the rule can be challenged legally by judicial review.

There are many resources available to nurses who want to learn to be advocates in policy and understand the tools available to them. Here are two:

NLN Public Policy Toolkit

NLN Policy Action Page

For a deeper dive into the connection of policy to improving health equity, here is a presentation by a leading national voice in nursing (Carolina Nursing, 2019).

References

AACN Alarmed Over Department of Education’s Proposed Limitation of Student Loan Access for Nursing. (n.d.). AACN. Retrieved January 31, 2026, from https://www.aacnnursing.org/news-data/all-news/aacn-alarmed-over-department-of-educations-proposed-limitation-of-student-loan-access-for-nursing

Carolina Nursing. (2019, March 20). A conversation with Sue Hassmiller – The Future of Nursing Report 2020-2030 [Video]. YouTube. https://youtu.be/9nLZeE-R5ek

Congressional Research Service. (2025, December 17). The Department of Education’s Proposed Rule to Define “Professional Student” (CRS Report R48768). https://www.congress.gov/crs-product/R48768

National League for Nursing. (n.d.). Advocacy Action Center. Default. Retrieved February 3, 2026, from https://www.nln.org/public-policy/advocacy-action-center

Policy Watch: Actions to Take: Nursing as a Professional Degree. (n.d.). AACN. Retrieved February 12, 2026, from https://www.aacnnursing.org/news-data/all-news/article/policy-watch-actions-to-take-nursing-as-a-professional-degree

Proposed Federal Loan Changes for Nursing Students. (n.d.). Retrieved January 31, 2026, from https://www.aacnnursing.org/policy-advocacy/take-action/nursing-is-a-professional-degree

U.S. Department of Education. (2026, January 30). Reimagining and Improving Student Education: Proposed Definition of a Professional Degree Program (Proposed Rule). Federal Register. https://www.federalregister.gov/documents/2026/01/30/2026-01912/reimagining-and-improving-student-education