If this proposed definition is adopted, the ability to borrow for federal student loans would be severely reduced, threatening to limit the physical therapy workforce at a time of nationwide shortages.
Key talking points:
Adds Another Threat to Workforce Pipelines in Critical Roles and Specialties
Health professionals across multiple disciplines provide essential care in areas such as mental health, primary care, anesthesia services, maternal and infant health, rehabilitation and rural communities.
- These professions require graduate-level education for licensure.
- New loan caps will significantly restrict who can afford to enter these professions.
- New loan caps fail to account for rising cost of living for graduate students.
- Access to professional education will increasingly be limited to students with substantial financial means, negatively affecting workforce diversity.
- Lifetime loan caps will also limit second-career professionals and discourage graduate-trained professionals from pursuing advanced education in areas such as public health, leadership, and healthcare administration.
Threatens the Faculty Pipeline and Access to Educational Programs
Graduate programs may experience declining enrollment, leading to fewer student slots. With fewer graduate-trained professionals, programs will struggle to recruit and sustain the faculty needed to educate future healthcare providers, further constraining workforce capacity.
Creates Barriers for Second-Career Healthcare Workers
Lifetime loan caps will disproportionately affect second-career professionals and those seeking additional education to expand their contributions to healthcare.
The Bottom Line
A robust health care workforce pipeline is essential to the health of our communities, state, and country. Access to health care across the country will be adversely affected if this proposal is accepted by the Department of Education. Connecticut’s multi-year investment in its healthcare workforce, spanning state agencies, higher education institutions, and hospitals, will be compromised if students are unable to access affordable graduate education financing.
We urge APTA CT members to comment on the proposal, before March 2, 2026, following the process outlined below:
When a Notice of Proposed Rulemaking (NPRM) is published, the public may submit comments through the federal portal at Regulations.gov.
How to Comment
These comments:
- Become part of the official administrative record
- Are publicly viewable
- Must be reviewed and considered by the agency
- Influence final regulatory language
This is how individuals and institutions formally respond to proposed federal regulations.
How to Submit a Public Comment
- Go to Regulations.gov
- Search for the rule using the docket number or rule title
- Click the specific rule
- Select “Comment”
- Upload your written comment or type directly into the portal
- Submit before March 2
Do not include:
- Misinformation about the regulation
- Emotionally charged language
- Identical verbiage in other comments
- Comments that undermine credibility
Legislative messages help ensure Members of Congress understand the workforce and constituent impact of federal decisions.
Public comments help shape the final regulatory language and create an official record that agencies must address.
Together, they strengthen our collective advocacy efforts.