The NUS believes the change from a bursary, which doesn't need to be paid back, to a loan, which does, will affect equal opportunities.
NUS President Megan Dunn, said: "It’s scandalous that the consultation looks only at implementation and fails to seek any views on whether or not scrapping NHS bursaries is actually the right thing to do.
"We believe driving students further into such enormous debt is not the solution and will limit access, rather than widen it.
"The government’s equality impact assessment fails to properly analyse the impacts the changes will have."
One former healthcare student told The Huffington Post UK the bursary was crucial to their decision to study.
My bursary put a roof over my head and food in my fridgeZeta, Nursing graduate
Zeta, who studied a diploma of higher education in nursing before graduating in 2009, said: "My bursary put a roof over my head and food in my fridge, courses applicable to the NHS bursary take a lot of work.
"Students are often forbidden to take work outside of their studies and we often have 'placements' where we worked alongside NHS staff, doing the same shifts and weekends but for no extra allowances.
"Why would anyone get themselves into debt to gain degrees where your starting salary is often lower than other degree qualified careers?"
Since the wider reforms to higher education our universities are offering more placesBen Gummer, Health Minister
The decision to end the NHS bursary programme for healthcare students was announced by Chancellor George Osborne in December.
The Department for Health says that currently two-thirds of those applying to become a nurse aren't accepted for training.
It says the change from bursaries to loans will fund up to 10,000 additional places.
Health Minister Ben Gummer said: "Since the wider reforms to higher education our universities are offering more places and those from disadvantaged backgrounds are more likely to access an undergraduate degree.
"Our proposed reforms will extend these benefits to nurses, midwives and allied health professionals, who have so far been excluded from these benefits.
"It is vital that the changes are implemented in the right way, which is why I would encourage as many people as possible to contribute to the consultation."