Trump Nursing Professional Degree Changes: How to Fight Back Through Public Comments
Welcome to the final article in our 5-part series on H.R. 1 and nursing doctorates. In Parts 1-4, we've covered what the law actually changes, how to negotiate compensation, what DNP and PhD nurses bring to healthcare, and six strategic opportunities to lead through this transition. But here's what most people don't know: this isn't over yet. The law has passed. But the Department of Education still has to write the actual regulations that implement it. And that's where we come in. This is Part 5 of our series, and it's the most important one. Because while we've talked about long-term leadership strategies, there's a narrow window right now where nursing's voice can directly influence how these regulations are written. Federal law requires the Department of Education to ask for public input before regulations are finalized. That's not optional. That's not a courtesy. That's the law.
H.R. 1 & Nursing Doctorates: Complete Series
Confused about whether nursing degrees are still "professional"? This 5-part series breaks down what Trump's H.R. 1 actually changes, and what it doesn't.
Take ACTION here by downloading or making a copy of the TAKE ACTION TOOLKIT: Responding to H.R. 1's Student Loan Changes here.
There's Still Time to Make a Difference: The Public Comment Period
Before we talk about what to do in response to H.R. 1, let's be very clear about something: this isn't over yet.
The law has passed. But the Department of Education still has to write the actual regulations that implement it. And that's where we come in.
How Federal Rulemaking Actually Works (And Where Nursing's Voice Matters)
Here's what most people don't understand about federal policy: passing a law is only the first step. The Department of Education now has to translate that law into specific regulations, the actual rules that determine how student loans work, what counts as what, and who's affected how.
And federal law requires them to ask for public input before those regulations are finalized. That's not optional. That's not a courtesy. That's the law.
Which means we have a narrow but real window to influence how these regulations are written, and whether nursing is protected, recognized, or thrown under the bus.
The Rulemaking Process: Where We Are and What's Next
1. Early Policy Review (Already Happened)
The Department of Education examined the One Big Beautiful Bill Act and identified areas where regulations need to be written or revised.
2. Public Rulemaking Sessions (Already Happened)
Federal law required the Department to convene a committee of stakeholders connected to student financial aid. Those sessions happened. They were open to observe, but participation was limited to appointed members.
Here's the problem: nursing wasn't represented on that committee.
Neither were many other affected professions. The committee makeup is determined by federal law governing the process, so fixing that representation gap is outside the scope of this rulemaking cycle.
But here's what we can control: what happens next.
3. Drafting the Proposed Rule (Happening Now)
The Department is currently writing the draft regulations based on committee discussions and internal analysis. The language can be revised right up until publication.
4. Notice of Proposed Rulemaking (NPRM) -
THIS IS WHAT WE'RE WAITING FOR This is the moment. The Notice of Proposed Rulemaking (NPRM) will be published in the Federal Register with the official regulatory text. Once it's published, a public comment period opens.
That's when anyone, yes, anyone, can submit formal comments via Regulations.gov.
You don't need to be a policy expert. You don't need to know the ins and outs of federal law. You just need to be able to explain how this will affect you, your students, your practice, or your community, and what you recommend instead.
5. Public Comment Window (Coming Soon)
Once the NPRM is live and assigned a docket number, the comment period opens. Every single comment submitted must be reviewed by the Department of Education. That's the law.
This is where nursing's voice goes on the record.
6. Final Rule
The Department reviews all comments, analyzes the feedback, and decides whether to finalize the rule as written, revise it, issue a new proposal, or withdraw it.
Public comments matter. They have changed regulations before. They can change them again.
What Nursing Needs to Say (And How to Say It Effectively)
When the NPRM is published and the comment period opens, here's how to make your voice count:
1. Be specific about which part of the proposal you're responding to
Don't just say "I oppose this rule." Reference the specific section, page number, or language you're addressing.
Example: "I am commenting on Section [X], which defines professional degree programs. This definition excludes nursing doctorates..."
2. Share the impact
Explain how this will affect real people in concrete terms. Use your experience. Use your students' situations. Use data from your program or practice.
Example: "I am a DNP student carrying $180,000 in federal loans. Under the proposed rule, I will lose access to income-driven repayment and face a 30-year repayment timeline with no economic hardship deferment options. This will make it financially impossible for me to work in underserved communities where I'm most needed."
3. Offer a clear recommendation or alternative
Don't just identify the problem, propose the solution.
Example: "I recommend that the final rule explicitly include DNP and PhD nursing programs in the definition of professional degree programs, consistent with the terminal degree status recognized by nursing accreditation bodies and the American Association of Colleges of Nursing."
4. Cite data or experience when you can
Even brief references strengthen your comment.
Example: "According to the American Association of Colleges of Nursing, there are over 400 DNP programs in the United States enrolling approximately 36,000 students. These proposed regulations would disproportionately impact this workforce pipeline at a time of critical nursing shortages."
Why This Matters: Nursing Is a Powerful Force
Here's what I know about nurses: when we organize, when we speak up, when we put our voices on the record, we change outcomes.
We've done it before with the scope of practice legislation. We've done it with workplace safety regulations. We've done it with professional licensure standards.
And we can do it here.
But only if we show up.
The Department of Education needs to hear from:
• DNP students explaining how these loan caps will force them out of school
• PhD candidates describing how 30-year repayment timelines make research careers unsustainable
• Program directors showing how enrollment will drop if students can't afford to attend
• NP entrepreneurs explaining how educational debt without flexible repayment options prevents us from serving underserved communities
• Dermatology and aesthetic NPs demonstrating how this specifically impacts our ability to address skin of color care gaps
Every voice matters. Every comment gets reviewed. And nursing is a powerful force when we use our voices collectively.
What to Do Right Now
Sign the petition TODAY - Major nursing organizations, including the American Nurses Association, National Association of Pediatric Nurse Practitioners, National League for Nursing, American Association of Colleges of Nursing, NCSBN, and American College of Nurse Midwives, have launched a petition asking the Department of Education to include nursing in its proposed "professional degree" program definition. Add your name here.
This demonstrates our collective nursing voice before the regulations are even finalized.
1. Watch for the NPRM publication - It will appear in the Federal Register. When it does, it will be all over nursing news outlets, social media, and professional organization communications.
2. Read the actual proposed language - Don't rely on summaries. Read what the Department actually wrote.
3. Submit a comment via Regulations.gov - Use your real experience. Be specific. Offer solutions.
4. Share this with your colleagues, students, and networks - Especially those not affiliated with professional nursing organizations who might not otherwise hear about this.
5. If you're part of a professional organization, amplify their advocacy - ACNP, DNA, AANP, AACN, DNPs of Color, NBNA, and others have already submitted organizational comments. Individual comments strengthen the collective voice.
The rulemaking process is how policy actually gets made. The law sets the framework, but the regulations determine the details, and the details are where nursing either gets protected or gets hurt.
Let's make sure our voices are part of that record.
Alliance of Cosmetic Nurse Practitioners
Take Action Now
For DNP Students & Graduates:
• Identify one Quality Improvement, Evidence-Based Practice or Policy project tied to access, equity, or policy impact
• Submit an abstract to a 2026 conference (DNPs of Color, NBNA, AANP)
• Reach out to a faculty mentor about publishing your DNP project
For PhD Nurses & Nurse Scientists:
• Draft one research question related to H.R. 1's impact on your population of interest
• Identify a funding opportunity (NIH, AHRQ, Robert Wood Johnson Foundation)
• Reach out to a potential co-author or collaborator
For NP Entrepreneurs & Educators:
• Audit your business model: Is it sustainable if Medicaid reimbursement drops?
• Identify one community partnership you could build in the next 60 days
• Create one piece of educational content explaining these changes to your audience
For Everyone:
• Write one op-ed, LinkedIn article, or social media post about what you're seeing and what you're doing about it
• Reach out to one media outlet, podcast, or platform to pitch your expertise
• Connect with one international colleague or organization for potential collaboration
Whether you're a DNP student, PhD nurse, NP entrepreneur, educator, or simply someone who cares about nursing's future, there are specific, tactical actions you can take right now.
I've created a comprehensive action guide with: - Specific project examples for DNP students and graduates - AI prompts you can copy/paste to develop research questions, draft abstracts, and write grant proposals - Email templates for reaching out to faculty mentors, potential collaborators, media outlets, and podcasts - Business audit checklists for NP entrepreneurs - Content creation templates for social media, blog posts, and op-eds - Community partnership proposals you can customize and deploy
The best response to a policy that questions our value is work that proves our impact.
Because...
Policy changes.
Patients stay.
And nurse practitioners lead.
Dr. Kimberly Madison, DNP, AGPCNP-BC, WCC, is a Board-Certified, Doctorally-prepared Nurse Practitioner, educator, and author dedicated to advancing dermatology nursing education and research with an emphasis on skin of color. As the founder of Mahogany Dermatology Nursing | Education | Research™ and the Alliance of Cosmetic Nurse Practitioners™, she expands access to dermatology research, business acumen, and innovation while also leading professional groups and mentoring clinicians. Through her engaging and informative social media content and peer-reviewed research, Dr. Madison empowers nurses and healthcare professionals to excel in dermatology and improve patient care.
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