WHN Statement on The U.S. Department of Education’s “Reimagining and Improving Student Education” (RISE) Proposed Rule
Public comments may be submitted through March 2, 2026.
Pursuant to H.R.1 – 119th Congress (2025-2026), also known as the “One Big Beautiful Bill Act,” the Department of Education has proposed the “RISE” rule which it presents as an effort to improve student education. However, the proposed rule would in fact achieve the opposite by reducing student access to required graduate healthcare education through federal lending caps set below the actual cost of accredited programs. The professions of Advanced Practice Nursing, including Nurse Practitioners and Nurse Anesthetists, as well as Advanced Practice Dental Hygienists, Physician Associates, Physical and Occupational Therapists, Speech and Language Pathologists, and Social Workers require a master’s degree or doctorate for licensure and practice.
The Department of Education claims that “the definition of a ‘professional degree’ is an internal definition used by the Department to distinguish among programs that qualify for higher loan limits, not a value judgment about the importance of programs.” However, they fail to make a compelling case for excluding the designated professions from access to federal loan limits aligned with the actual cost of accredited graduate education, instead suggesting, without providing evidence, that this rule would drive down program costs while failing to address or account for the foreseeable adverse consequences for enrollment, workforce capacity, and access to care. By capping federal lending below the cost of required graduate training, the rule risks reducing enrollment in these programs, worsening workforce shortages, and limiting patient access to care—particularly in rural and underserved communities. Exclusion criteria such as program length or classification categories do not reflect workforce demand, clinical responsibility, or public health necessity.
The World Health Network stands with National Nurses United in opposing the implementation of the proposed plan without justifying its assumptions and without recognizing the likely harmful consequences: “Nurse practitioners currently provide much-needed primary care, particularly in rural and underserved areas. If this rule went into effect, it could have a major impact on nurses’ access to graduate nursing programs. In addition, this proposed rule change would make it more difficult to find nursing faculty with advanced degrees to teach in nursing programs…Millions will lose access to health care…NNU is also concerned how this could contribute to the nationwide nurse staffing crisis…Shutting down nurses’ access to resources to seek higher education will only further contribute to forces driving nurses away from the bedside.”
As well, we support the statements of:
ANA/American Nurses Association,
AANP/American Association of Nurse Practitioners,
AANA/American Association of Nurse Anesthetists,
ADHA/American Dental Hygienists’ Association,
AAPA/American Academy of Physician Associates,
APTA/American Physical Therapy Association,
AOTA/American Occupational Therapy Association,
ASHA/American Speech-Language-Hearing Association, and
NASW/National Association of Social Workers,
many of which provide signable petitions or talking points for public comment.
WHN urges the Department to maintain professional degree loan limits for accredited graduate healthcare training programs and to revise the RISE rule accordingly. The proposed rule would significantly exacerbate the existing healthcare staffing crisis and further impede access to health care. It is open for public comment through March 2, 2026. Comments on the rule can be made here: https://www.regulations.gov/document/ED-2025-OPE-0944-0001
