How Proposed Federal Student Loan Limits Could Impact APP Education and the Healthcare Workforce

December 15, 2025   |   Nurses

At a time when the U.S. faces increasing shortages of nurses, physical therapists, occupational therapists, speech-language pathologists and other advanced practice professionals (APPs), the next generation of clinicians may soon encounter new barriers to financing their education. A package of proposed federal regulations would significantly limit the amount some graduate students can borrow. The shift could reshape access to essential healthcare careers.

The  American Association of Colleges of Nursing (AACN) expressed deep concern about the decision in a statement saying, “Should this proposal be finalized, the impact on our already-challenged nursing workforce would be devastating.”

The change comes to those graduate degrees that aren’t categorized by the Department of Education (DoE) as “professional degrees.” Law, dentistry and medicine are considered professional degrees. APP graduate degrees are categorized as “graduate degrees.”

The DoE hasn’t updated or changed federal definitions, but what may change is how much students can borrow for those programs not categorized as “professional.” 

Rising Education Costs and the Shrinking Return on APP Graduate Degrees

By creating different borrowing caps for graduate versus professional programs, the proposal highlights a long-standing tension in healthcare: the cost of becoming a clinician is extraordinarily high, yet these degrees don’t receive the borrowing flexibility granted to programs like medicine, dentistry or law. Nor do the APPs earn salaries that make it easy to pay back the loans. 

It’s a gap that raises concerns about training pipelines at a time when patient needs are growing. “The biggest problem in the industry is how much these people are charged to get an education when what we really need is a solution that allows more people to enter the field,” says William Sullivan, Executive Vice President of CM&F Group.

How Proposed Federal Student Loan Limits Would Impact APP Graduate Programs

Loan changes stem from the One Big, Beautiful Bill Act, which eliminates Grad PLUS loans — the primary federal mechanism that allowed graduate students to borrow up to the full cost of attendance. Instead, the Department of Education proposes annual and lifetime caps:

  • Graduate programs: $20,500 per year, capped at $100,000 total.
  • Professional programs: $50,000 per year, capped at $200,000 total.

Because APP programs fall under “graduate” rather than “professional,” future students could face significantly lower borrowing capacity than peers in medicine or law. The administration calls these “commonsense limits” that “will help drive down the cost of graduate programs. “It’s possible that limiting access to high-cost federal loans may lower tuition. Whether that’s true or whether the loan changes simply reduce access remains to be seen,” says Sullivan.

These rules aren’t expected to be finalized until 2026, and many details could change before then.

Why APP Degrees Are Not Classified as Professional Degrees Under Federal Loan Policy

Despite their clinical rigor, extensive supervised training and even doctoral-level preparation, APP degrees have never been defined as “professional degrees” in federal student aid policy.

For many, this feels counterintuitive when programs demand years of advanced coursework, board exams and significant clinical rotations. 

The Growing Mismatch Between APP Student Loan Debt and Early-Career Earnings

The cost-to-income ratio for APPs is already problematic. For example, some physical therapists graduate with more than $200,000 in student debt only to enter a workforce that pays around $55,000. Similar gaps exist in nursing, OT, SLP and PA programs.

If federal loan caps tighten, students may need to turn to private loans, which typically have higher interest rates and variable terms. Meanwhile, the healthcare system can’t strengthen its workforce if financial barriers keep rising at the entry point.

What Advanced Practice Professionals Should Watch as Federal Loan Changes Move Forward

As the regulations move through the public comment process, APPs and future students should pay close attention to:

  • Any exceptions or modifications created for clinical training programs
  • Advocacy opportunities from professional associations and accrediting bodies
  • Decreasing graduate tuition
  • Congressional engagement that could alter timelines or loan structures

The road to becoming an APP requires immense academic, financial and personal commitment. The stability of the entire healthcare system depends on making that journey accessible to everyone dedicated enough to try.

Supporting Advanced Practice Professionals Beyond Graduation

CM&F offers reliable liability insurance for over 200 healthcare professions and specialties. If you graduated within the past year and are applying for full-time coverage, you may be eligible for a lower annual premium for your first four years in practice while building your career. Get an instant quote online and speak to one of our agents about any questions.

Frequently Asked Questions

  • What are the proposed federal student loan limits for graduate healthcare programs? The proposed federal regulations would eliminate Grad PLUS loans and replace them with annual and lifetime borrowing caps. Graduate programs, including most advanced practice professional (APP) degrees, would be capped at $20,500 per year and $100,000 total, significantly lower than limits for professional degrees like medicine or law.
  • Why are advanced practice professional (APP) degrees not classified as professional degrees? Under current Department of Education policy, APP programs such as nursing, physical therapy, occupational therapy, and speech-language pathology are categorized as “graduate degrees,” not “professional degrees.” This classification affects how much students can borrow federally, despite the clinical rigor, supervised training, and board requirements of these programs.
  • How could federal student loan limits impact the healthcare workforce? Lower federal borrowing limits may make APP education less accessible, forcing students to rely on private loans with higher interest rates or abandon training altogether. This could worsen existing healthcare workforce shortages at a time when demand for nurses, therapists, and other APPs continues to grow.


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