Nurses starting a PhD in nursing this academic year face a federal borrowing limit that their MSN and DNP classmates have, for now, escaped. As of Oct. 14, 2026, the Education Department's interim list of professional degree programs covers the Master of Science in Nursing (MSN), Doctor of Nursing Practice (DNP) and nurse anesthesia doctorate (DNAP), but not the research-focused PhD. That leaves nursing PhD student loans for new borrowers capped at $20,500 a year and $100,000 in total for graduate study, instead of the $50,000 a year and $200,000 allowed for professional students.

The gap in nursing PhD student loans is wider than it used to be because Grad PLUS loans, which once covered the rest of a student's cost of attendance, ended for new borrowers on July 1, 2026. Two of the lawsuits challenging the department's definition specifically name the nursing PhD, but neither has produced a ruling on it yet.

Why the PhD Was Left Off the Interim List

The department's RISE final rule, published May 1, excluded every nursing degree from the professional category. During the comment period, nursing groups asked the department to add "Nursing (MSN, DNP, Ph.D.)" to the list. It declined. The rule did say that MSN, DNP and DNAP programs "may satisfy the operative definition's three-part test," a statement it did not make about the PhD.

After a federal judge stayed part of the rule on June 24, Federal Student Aid issued GENERAL-26-42, listing programs it would treat as professional while the stay lasts. A July 10 update extended MSN and DNP status to other programs in CIP group 51.38 that award the same credential. A PhD awards neither, so even a nursing science PhD coded in that group does not qualify. The department has not published an explanation for leaving the PhD off.

The statutory test asks whether a degree marks completion of the academic requirements for "beginning practice" in a profession, with licensure generally required. Most nursing PhD students are already licensed nurses. In an Aug. 10 opinion, Judge Patti B. Saris of Massachusetts noted that PhD students "usually already hold an MSN" and train to become leaders and educators. Whether a research doctorate can meet the test is a question the courts have not answered.

Where the Nursing PhD Student Loans Fight Stands in Court

In American Association of Nurse Practitioners v. McMahon in Washington, the plaintiffs, including the American Association of Colleges of Nursing (AACN), filed an unopposed motion on July 30 to amend their complaint. Judge Beryl A. Howell granted it Aug. 3. The amended complaint challenges the interim guidance itself, arguing that it "continues to exclude other doctoral nursing programs, including Doctor of Philosophy (Ph.D.) in Nursing."

In Massachusetts, the American Nurses Association and other groups asked for immediate relief covering the MSN, DNP, DNAP and PhD. Saris found the rule likely unlawful but denied the request on Aug. 10. She wrote that some PhD students "may currently face the choice between forgoing enrollment or taking on burdensome private loans," but said the plaintiffs had not identified a member actually seeking a PhD in nursing. The denial was without prejudice, so they can add evidence. Summary judgment briefing in that case is set to close Nov. 13. In Washington, it closes Dec. 4.

In Congress, the Nursing is a Professional Degree Act (S. 4568 and H.R. 8691) would name "Nursing (MSN, DNP, DNAP, or Ph.D)" as professional. Both bills remained in committee as of Oct. 14. A House spending bill provision covers programs that prepare students for advanced practice registered nurse licensure, so it is unclear whether it would raise the limit on nursing PhD student loans.

An 11th Straight Year of PhD Enrollment Decline

The loan fight lands on a degree that was already shrinking. AACN reported May 7 that enrollment in nursing PhD programs fell for the 11th consecutive year in 2025, down 3.05% (127 students) from 2024. Since 2013, enrollment has dropped 20.8%, from 5,145 to 4,077 students. Over the same year, DNP enrollment grew 5.9% to 44,976.

Interest has not vanished. AACN counted a 50.0% rise in applications to PhD programs, and schools turned away 500 qualified PhD applications. The survey was taken in fall 2025, before the new limits on nursing PhD student loans took effect, so it does not measure their impact.

"Strengthening pathways into PhD programs is critical to advancing the science that drives healthcare innovation and evidence-based practice forward," AACN chief executive Deborah Trautman said in the release.

The Faculty Shortage Link

AACN says PhD programs are not producing enough potential nurse educators to meet demand. Its faculty shortage fact sheet, updated in October 2026, cites an October 2025 survey that found 1,588 full-time faculty vacancies at 863 nursing schools, a vacancy rate of 7.2%. Of those openings, 80.9% required or preferred a doctoral degree.

The same fact sheet puts the average age of doctorally prepared full professors at 60.2. It contrasts an average master's-prepared professor salary of $82,762 with a median of $134,920 across advanced practice nursing roles. AACN says faculty shortages are among the main reasons schools turned away nearly 17,000 qualified graduate applications in 2025.

Nursing PhD Student Loans and Other Funding Now

Students enrolled before July 1, 2026: those enrolled in their program as of June 30, 2026, who had received a Direct Loan for it keep the old limits, including Grad PLUS, for the lesser of three academic years or the time left in the program, according to the department's loan limits FAQ.
Nurse Faculty Loan Program: the federal Health Resources and Services Administration's 2026 funding notice, open from June 8 to July 10, 2026, describes low-interest loans through participating schools, with up to 85% canceled for up to four years of full-time faculty work.
School funding: assistantships, fellowships and scholarships vary by school and are set by each program.

Our report on the end of Grad PLUS covers the general graduate limits.

What Happens Next

Oct. 16: the department's cross-motion is due in the Massachusetts case.
Nov. 6: the department's cross-motion is due in the Washington case.
Nov. 13: briefing closes in Massachusetts.
Dec. 4: briefing closes in Washington.

No court has set a date to rule, so for new borrowers, nursing PhD student loans stay at the graduate limit for now. Follow each case in our nursing loan limits lawsuit tracker, and confirm your own limit with your school's financial aid office.