Clasp Analysis of 19,620 Public Submissions Finds More than 98% of Comments are Opposed to Loan Limits Citing Healthcare Workforce Concerns

• Public opposition was nearly unanimous. More than 98% of submissions opposed the loan limits as written, while only 63 submissions supported them.
• Healthcare workforce shortages appeared in 29% of opposing submissions, while patient access and quality of care concerns appeared in 28%.
• While public attention focused on nursing, concerns extended across social work, physician assistant programs, therapy, counseling, and behavioral health professions.
• Programs including nursing, physician assistant studies, physical therapy, counseling, and social work face lower borrowing limits under the updated framework, while medicine, law, and dentistry retain higher limits.
• The findings come as states file legal challenges and bipartisan lawmakers push changes to how healthcare programs qualify for higher borrowing limits.

Clasp, a company that helps healthcare employers recruit and retain clinicians by tying student loan repayment to employment, today released an analysis of 19,620 public submissions related to federal graduate borrowing changes scheduled to take effect July 1, 2026. The analysis examined public comments submitted to the U.S. Department of Education. The dataset included 17,844 text-based submissions and 1,776 attached documents and formal letters, which were reviewed individually as part of the broader analysis to identify patterns across workforce, affordability, and educational access concerns.

The findings come as debate around the updated borrowing framework intensified in May. Bipartisan legislation introduced in Congress would include advanced nursing degrees within the Department of Education's professional-degree designation following concerns that some nursing pathways could exceed the new borrowing limits. Thousands of public submissions analyzed by Clasp raised similar concerns around workforce access, educational pathways, and downstream impacts on patient care.

View the full report here.   

Nearly 20,000 Public Submissions Were Reviewed
Clasp analyzed 19,620 unique public submissions, including 1,776 attached documents and formal letters reviewed individually as part of the broader dataset.

Among all submissions:

• 19,243 opposed (98.1%)
• 314 neutral (1.6%) 
• 63 supported (0.3%)

Healthcare Workforce and Patient Access Emerged as Central Themes

The analysis found that commenters repeatedly connected borrowing policy to broader concerns about healthcare access and future workforce capacity.

The most frequently raised concern centered on which healthcare programs qualify for professional-degree borrowing treatment. Many commenters argued that programs requiring clinical training, state licensure, board examinations, and graduate-level education now receive different borrowing treatment than medicine, law, dentistry, and other traditionally recognized professional pathways.

Additional themes repeatedly appeared across submissions (all percentages out of opposing submissions only):

• Healthcare workforce shortages: 5,594 mentions (29%)
• Patient access and quality of care: 5,311mentions (28%)
• Loan caps and borrowing limits: 5,232 mentions (27%)
• Education cost and debt burden: 4,903 mentions (26%)
• Rural and underserved communities: 4,508 mentions (23%)
• Private loan reliance: 1,879 mentions (10%)
• Mental and behavioral health workforce concerns: 3,117 mentions (16%)

Many Healthcare Programs Now Face Lower Borrowing Limits

Background materials submitted during the public comment process also highlighted how healthcare programs are treated under the updated borrowing framework. Historically, schools had flexibility in classifying certain healthcare programs for administrative purposes under the Higher Education Act's definition of professional degrees. The updated framework made those distinctions financially meaningful by applying a narrower interpretation of which professional-degree programs qualify.

Analysis cited in a letter from the American Council on Education estimated an approximately 56% reduction in qualifying programs under the narrower interpretation now being applied. As a result, programs including nursing, physician assistant studies, physical therapy, occupational therapy, counseling, and social work face lower graduate borrowing caps, while medicine, law, dentistry, and certain other professional pathways retain higher borrowing limits.

Concern Extended Well Beyond Nursing

While public attention around the updated borrowing framework has largely focused on nursing programs, submissions analyzed by Clasp reflected concern across a much broader group of healthcare professions, including social workers, physician assistants, therapists, counselors, nurse practitioners, and behavioral health providers.

The findings suggest many commenters viewed the issue as a broader healthcare workforce question rather than a challenge isolated to one profession.

Universities Warned of Enrollment Declines and Pipeline Gaps

Beyond individual submissions, 729 organizations submitted formal responses, including 143 colleges and universities, many of which projected downstream effects on healthcare workforce pipelines and access to training.

• Johns Hopkins University projected a 25% decline in nursing master's enrollment and a 15% decline in doctoral nursing enrollment and noted that 53% of affected Grad PLUS borrowers are Pell-eligible.
• The American Association of Colleges of Nursing reported that 78% of nursing school deans believe the changes would negatively affect enrollment and 77% believe they would damage the future faculty pipeline.
• The American Occupational Therapy Association noted that applications to occupational therapy programs are already down 33% since 2018 and stated that only approximately 29 of more than 322 occupational therapy programs fall below the proposed $20,500 annual borrowing limit.
• The American Academy of Physician Associates reported median physician assistant program tuition of approximately $96,900, while Russell Sage College noted that nurse anesthesia tuition can reach $240,000 and warned of substantial funding gaps under the proposed cap structure.

What Healthcare Systems Are Doing to Strengthen Talent Pipelines
As financing pressures increase for future clinicians, many healthcare employers are expanding programs that help reduce education-related barriers to entering and remaining in the workforce. Loan repayment, tuition support, and employer-sponsored financing programs are increasingly used to recruit and retain hard-to-fill clinical roles.

For healthcare systems already facing shortages across nursing, behavioral health, therapy, and advanced practice roles, these programs are becoming part of broader workforce strategies designed to strengthen talent pipelines and improve retention.

Clasp partners with healthcare employers to connect student loan support with long-term employment pathways, helping organizations attract clinicians earlier and create stronger retention outcomes.

“Physical therapy is already facing significant workforce challenges, and the cost of education continues to be one of the biggest barriers preventing talented people from entering and advancing within the profession,” said Brent Mack, DPT, Chief Executive Officer, Therapy Partners Group. As policymakers debate changes to graduate borrowing, healthcare employers have an important role to play in supporting their future workforce. That's why we've invested in student loan repayment with Clasp as part of our broader workforce strategy. It's not just about recruiting and retaining talent; it's about making physical therapy a more sustainable career path and helping ensure patients have access to the care they need for years to come.”

Many of the Most Frequently Mentioned Healthcare Professions Have Predominantly Female Workforces

Several professions appearing frequently throughout submissions are predominantly female according to workforce data from the Bureau of Labor Statistics and HRSA:

• Nurse practitioners: 87% female
• Speech-language pathologists: 98% female
• Social workers: 82% female
• Physicians: 39% female

The findings suggest many of the professions discussed throughout the submissions represent workforce segments that already face staffing challenges and rely heavily on women entering and advancing through clinical training pathways.

"We saw people repeatedly connect borrowing policy with workforce access and patient care," said Tess Michaels, Founder and CEO of Clasp. “The discussion extended beyond tuition costs. Many submissions raised broader questions around who enters healthcare professions, whether patients can access care, and how existing shortages could become harder to solve.”

"We already have hospitals across the country struggling to hire nurses, therapists, behavioral health providers, and advanced practice clinicians," Michaels added. “Many commenters raised the same concern. If barriers to entering those professions increase, existing workforce shortages become harder to solve.”

Methodology 
Clasp analyzed 19,620 publicly posted submissions on regulations.gov related to federal graduate borrowing changes between January 30 and March 23, 2026. The dataset included 17,844 text-based submissions and 1,776 attached documents and formal letters, which were reviewed individually as part of the broader analysis. Submissions were classified by profession mention, theme, geography, and sentiment.

Sentiment analysis categorized submissions as oppose, support, or neutral. Explicit oppose and support classifications reflect submissions using clear, unambiguous language. Neutral submissions primarily included personal stories, patient experiences, photographs, or submissions that did not express a clear position. Theme percentages are calculated as a share of the 19,243 opposing submissions. Individual submissions may reflect multiple themes.

Background information related to Classification of Instructional Program (CIP) (i.e. major or field of study) categorization and qualifying program classifications was drawn from publicly available materials and supporting documentation submitted as part of the public comment process.

Gender statistics were sourced from the BLS Spotlight on Healthcare Occupations (2022) and HRSA’s 2024 State of the Health Care Workforce report.