President's Message: Federal Loan Caps: What It Means for Critical Care

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Jose L. Pascual, MD, PhD, FRCS(C), FACS, FCCM
12/18/2025

The Society of Critical Care Medicine (SCCM) recognizes and appreciates the recent bipartisan, bicameral letter from more than 140 members of the U.S. Congress expressing concern about the U.S. Department of Education’s proposed treatment of post-baccalaureate nursing degrees under federal student loan policy.
 
As a multiprofessional organization, SCCM supports this effort and urges the U.S. Department of Education to ensure all essential healthcare programs with advanced graduate training are properly classified as “professional degree” programs in the final rule to align with the needs of the healthcare system and to avoid creating new barriers for clinicians seeking advanced training.

SCCM has been monitoring this issue since the passage of H.R. 1 (the One Big Beautiful Bill Act) and the release of the U.S. Department of Education’s proposed definition of “professional degree” programs. If these definitions are adopted as is, it will impact students' access to federal loans.

H.R. 1 impacted graduate students in three significant ways:
  • Eliminated Grad PLUS loans, which help pay for education expenses not covered by other financial aid for eligible graduate or professional students
  • Created two groups of graduate student borrowers:
    • Professional degree programs (higher loan caps)
    • Graduate (nonprofessional) degree programs (lower loan caps)
The U.S. Department of Education convened the Reimagining and Improving Student Education (RISE) Committee to reach consensus on the caps for federal loans and how degrees would be categorized.1 The committee reached consensus on the loan caps, determining that “professional” degrees are eligible for $50,000 annually and $200,000 total, while those in “nonprofessional” programs will face substantially lower caps of $20,500 annually and $100,000 total.

Right now, many healthcare professions are not on the “professional” list, which means those students pursuing advanced degrees will have lower loan caps and lose access to the extra federal loans that used to fill the gap.

This is very concerning to the field of critical care for several reasons:
  • These experienced professionals are core members of the critical care team. Graduate-prepared nurses, including advanced practice nurses, nurse practitioners, certified registered nurse anesthetists, nurse midwives, and clinical nurse specialists, as well as other professionals such as social workers, physician assistants, and physical therapists, are essential to delivering complex critical care, leading quality and safety initiatives, and sustaining 24/7 intensive care unit (ICU) capacity.
  • Restricting access to graduate education in these areas worsens existing workforce shortages, particularly in ICUs, step-down units, and emergency departments that already face recruitment and retention challenges.
  • Classifying essential healthcare professionals as “nonprofessional” sends a damaging message that is inconsistent with the scientific, leadership, and practice responsibilities that these professionals carry in modern critical care.
SCCM is:
  • Monitoring this issue closely, including ongoing rulemaking by the Education Department and the work of the RISE Committee
  • Engaging in dialogue with nursing and other health professional organizations that are advocating for changes to the current definitions and loan caps
  • Assessing how these policies will affect the critical care workforce, especially in safety-net, rural, and underserved settings where access to graduate education and loan financing is already limited
The principle that critical care is best delivered by a multiprofessional team is core to SCCM’s mission. SCCM members include physicians, nurses, pharmacists, respiratory therapists, advanced practice providers, and many others who work side by side at the bedside and in leadership roles. We recognize these highly skilled positions that require advanced education and should be treated accordingly in policy and financing decisions.
 

Jose L. Pascual, MD, PhD, FRCS(C), FACS, FCCM
Author
Jose L. Pascual, MD, PhD, FRCS(C), FACS, FCCM
Jose L. Pascual, MD, PhD, FRCS(C), FACS, FCCM, is the system section chief of surgical critical care for the Division of Trauma, Emergency Surgery and Surgical Critical Care at the University of Pennsylvania Perelman School of Medicine in Philadelphia, Pennsylvania, USA. He is a professor of surgery and neurosurgery and has a cross-appointment in the School of Nursing. Dr. Pascual is also an attending surgical intensivist at Penn Presbyterian Hospital, the Hospital of the University of Pennsylvania, and the Philadelphia VA, and is co-medical director of the surgical ICU at the Hospital of the University of Pennsylvania.
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