Federal student loan changes could threaten the EP allied workforce

The Honorable Linda McMahon

Secretary of Education

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202

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On behalf of Heart Rhythm Advocates and the electrophysiology (EP) community, we write to express serious concern regarding the Department of Education’s proposed reinterpretation of the definition of “professional degree” under the One Big Beautiful Bill (OBBBA) regulations. Excluding nursing graduate programs, inclusive of advanced practice and EP specialty training, from professional-degree classification for federal student loan eligibility would significantly harm the cardiovascular workforce and patient access to care.

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For decades, the federal definition codified in 34 CFR §668.2 emphasized that professional degrees were not limited to an exhaustive list, but rather defined by advanced post-baccalaureate education, licensure requirements, specialized clinical training, and direct responsibility for patient care. Nursing graduate education has long met these standards. Advanced practice and EP-specialty nurses complete rigorous training, obtain professional licensure or certification, deliver high-acuity care, and assume responsibilities comparable

to other recognized health professionals.

 

The Department’s proposed reinterpretation - through doctoral-only degree criteria, rigid program-length requirements, and restrictive CIP-code limitations - effectively removes nursing from professional-degree status despite meeting both the letter and spirit of the longstanding definition. This represents a sharp departure from prior regulatory intent and practice.

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While the Department has cited the goal of reducing aggregate graduate borrowing, this approach does not address the underlying cost drivers of education or create alternative funding pathways. Instead, it erects an immediate (and for many, insurmountable) financial barrier for students pursuing essential clinical careers, destabilizing one of the nation’s most critical healthcare workforce pipelines.

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The implications for heart rhythm care are both direct and urgent. These procedures rely heavily on highly trained nurses to support catheter ablations, complex device management, remote monitoring coordination, peri-procedural care, arrhythmia triage, and longitudinal patient management. Many of these roles depend on graduate nursing education and specialty training. Restricting access to federal financing will deter qualified nurses from pursuing these pathways, further constraining a critical workforce capacity precisely as procedural volumes and patient demand continue to rise.

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More broadly, limiting loan eligibility for nursing graduate education will exacerbate the national nursing shortage already impacting both inpatient and specialty practice environments. Advanced practice nurses, clinical specialists, educators, and researchers are foundational to cardiovascular care delivery and vital to innovation, training, quality improvement, and patient safety.

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In Cardiac Electrophysiology, workforce shortages translate directly into delayed procedures, reduced throughput, greater burnout across multidisciplinary teams, and impaired patient access, particularly for high-risk arrhythmia populations. These impacts are already being felt in many regions and would intensify under the proposed policy.

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We respectfully urge the Department to reconsider this restrictive reinterpretation and to restore nursing graduate education to its appropriate status as a professional-degree pathway for federal student loan eligibility. A regulatory framework that weakens nursing training does not promote fiscal responsibility; it undermines the healthcare infrastructure patients depend on.

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We further encourage engagement with specialty societies and workforce stakeholders, including Heart Rhythm Advocates and the Heart Rhythm Society, to fully assess the downstream consequences for arrhythmia care, patient safety, and system resilience. Any effort to control educational borrowing should target institutional cost drivers rather than restrict access for clinicians entering essential patient-care professions.

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Thank you for considering the Cardiac Electrophysiology community’s perspective. We stand ready to provide workforce data, clinical briefings, or regulatory analysis to support solutions that protect both educational access and fiscal stewardship.

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Kenneth A. Ellenbogen, M.D., FHRS, Co-Chair, Heart Rhythm Advocates

Andrea Natale, M.D., FHRS, Co-Chair, Heart Rhythm Advocates