Letter to Congress: Reimagining and Improving Student Education
- ANA California Staff
- Feb 27
- 3 min read
Feb 27, 2026
The Honorable Linda McMahon
Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Submitted electronically to www.regulations.gov
RE: Reimagining and Improving Student Education [ED–2025–OPE–0944]
Dear Secretary McMahon,
The American Nurses Association\California (ANA\C) urges the U.S. Department of Education (ED) to include post-baccalaureate nursing programs as ‘professional’ degrees. ANA\C is a bi-partisan professional nursing organization representing the interests of more than 550,000 licensed registered nurses in California. Our mission is to optimize nursing contribution to the health and well-being of individuals, families, and communities. As a state-level professional advocacy organization, ANA\C has been extensively involved in legislative efforts supporting many bills that became California’s laws and are currently assisting in making California a place of Nursing Excellence. Excluding graduate nursing degrees from a ‘professional’ list of study programs misses the specific and fundamental roles Advanced Practice Registered Nurses (APRN) play in the health and well-being of our patients, communities, and in future public health and economic well-being of the United States.
Completion of post-baccalaureate nursing degrees - Master of Science in Nursing (MSN), Doctor of Nursing Practice (DNP), Doctor of Nurse Anesthesia Practice (DNAP), and Doctor in Philosophy in Nursing (PhD) - is the required first step in education not only for nurses interested in advanced practice nursing specialties but also a crucial prerequisite for becoming nursing faculty. While certified nurse-midwives, nurse practitioners, and clinical nurse specialists are required to hold a master’s degree in nursing, certified registered nurse anesthesiologists are required to obtain a doctoral degree in order to practice in this area.
Starting in 1994, a professional degree was defined as a “degree that signifies both completion of the academic requirements for beginning practice in a given profession and level of professional skill beyond that is normally required for a bachelor’s degree. Professional licensure is also generally required” [34 CFR § 668.2]. Having specific educational requirements for APRNs’ roles should satisfy the U.S. Dept of Education proposed criteria for ’professional’ degree programs. ANA\C is concerned that continued exclusion from the proposed professional studies category will limit the ability of the next generation of advanced practice registered nurses to enter these roles without adequate federal loan support and thus will severely impact the future of the American nursing workforce.
Next to negitively affecting future certified nurse-midwives, nurse practitoners, certified registered nurses anesthesiology, and clinical nurse specialists, the exclusion of graduate nursing degree programs will further directly impact regular nursing students as nursing faculty (professors in nursing schools) in both, the pre-licensure (RN) programs and graduate degree (MSN) programs, must hold a graduate degree in order to teach the next genera=on of nurses. In terms of an ongoing nursing faculty shortage, it is not only that nursing faculty must have a graduate degree in order to teach, but they also earn less than their counterparts in clinical settings. So, decreasing access to graduate federal loans for nurses interested in teaching will undeniably impact all communites across this nation as nursing schools will be decreasing number of accepted students or closing its doors completely, hospitals will be experiencing even deeper nursing shortages and/or closures, and clinics and facilites serving in rural areas will be struggling to offer even basic access to health care services.
Restricting access to more affordable federal student loans will force graduate nursing students to either a) opt for more expensive private loans, or b) opt out of graduate nursing studies altogether. Should that happen, we will not have enough nurse midwives delivering babies, nurse practitioners for follow-up visits in clinics, clinical nurse specialists for mental health care, or nurse anesthesiologists providing anesthesia in smaller community/rural hospitals. Moreover, we will not have enough nursing faculty to teach in nursing programs, thus there will not be future generations of registered nurses ready to take the place of their retiring colleagues. If that situation becomes a reality, we all should be asking who will be taking care of us, our families, and our communities in a few years if graduate nursing programs are excluded from ‘professional’ degrees? It is clear that this decision will be impacting all our lives for years to come.
For these reasons, ANA\C strongly urges the U.S. Department of Education to reconsider its proposed changes to federal loan limits and place graduate degrees in nursing on a list of professional degrees.
Respectfully,
Dr. Marketa Houskova, DNP, MAIA, BA, RN
Chief Executive Office
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