The Department of Education (DOE) on January 30, 2026, as expected, published a proposed rule intended to implement several higher‑education provisions from HR 1, including new parameters for federal student loan programs.

Among other things, the proposed rule aims to revise the definition of “professional degree,” which now plays a significant role in determining federal loan limits for advanced degree programs.

HR 1 established two tiers of loan caps: students enrolled in graduate programs may borrow up to $20,500 annually with a $100,000 lifetime limit, while students in programs classified as awarding a “professional degree” may access up to $50,000 annually and $200,000 total. Because this rule defines what constitutes a “professional degree,” it will directly affect which students qualify for the higher borrowing limits.

LeadingAge is concerned that the proposed definition excludes several critical fields that underpin the aging‑services workforce, including nursing, physical and occupational therapy, physicians’ assistants, and social work. Rural communities are likely to feel the impact most acutely, as advanced practice clinicians often serve in roles typically filled by physicians in those settings. In addition, limiting borrowing capacity for graduate‑level degrees could impact the number of nurse educators, having a downstream effect on training programs and the broader pipeline.

The proposed rule is open for public comment for 30 days, with comments due by March 2.

LeadingAge will submit comments on behalf of the association, and we encourage state partners and members to continue to share any perspectives, examples, or concerns they would like us to incorporate into our response.

In addition, we have developed this tip sheet to guide members and states in crafting their own responses.