Category Archives: nccaom

Acupuncture Education 2015 – The State of the Profession

Posted on by

If we want people who want acupuncture to receive it from an Acupuncturist, acupuncture education deserves our attention.

There aren’t good statistics on how many Acupuncturists or acupuncture students there are in the US. But those handy maps printed in Acupuncture Today can give us some idea. The December 2013 issue (with an article on AT’s unprecedented growth) showed 24,342 Acupuncturist and 3,124 student issues mailed. In December 2015 – 24,231 Acupuncturist and 2,624 student issues mailed. That’s not growth. The 2014 NCCAOM Annual Report (the most recent available) also reveals – we are not a growing profession.

There is a lot of churn in Acupuncture education — schools close, schools open, programs merge, new degree programs are established. New Gainful employment rules adopted in late 2014 may well contribute to that churn. They require for-profit schools (about 50% of acupuncture programs) to provide at least some debt and jobs data to prospective students.

Small class sizes can skew the data. Still, check out these reports (selected because they came up first in Google): Emperors, ACAOM (the school not the agency), Arizona School of AOM, Midwest, AIAM, and Colorado School of TCM.

Only two schools reported job placement, at 50% and 67%. Median loan amount (omitting a 1.5 million figure given by Midwest that must be a mistake) ranged from 17K to 72K. A real eye opener was the percentage of students completing the program in the expected time frame. The average across all 6 programs was 55%. Omit the 100% reported by Arizona, currently on probation with ACAOM (the agency), and it’s 46%.

It’s not encouraging. Add student uncertainty that the degree they obtain will enable them to practice and it is no surprise our profession isn’t growing.

Imagine if we could tell prospective practitioners –  “A Master’s Degree in Acupuncture from any ACAOM accredited program will fulfill the educational requirements to practice in any state.”

I may not love the ACAOM standards but I’ll accept them to help the profession. Is there a downside to offset the upside?

NGAOM you have a stated goal of establishing uniform standards, yet are fighting to keep California schools out of the ACAOM system. Please explain.

We had some significant losses in Acupuncture education in 2015.

Spring brought news that Dianne Connolly and Bob and Susan Duggan would no longer teach or be part of the program at MUIH (which Bob and Dianne founded in 1974 as The Maryland College of Chinese Acupuncture). Bob and Dianne are part of the foundation of this medicine in the US. They profoundly influenced my acupuncture journey and it is a significant loss that they won’t be part of every MUIH student’s education. I am glad they are continuing to teach and share their wisdom in other settings.

Bob Duggan played an integral role in establishing acupuncture standards, credentials, agencies, and commissions. His goal in so doing was to enable this safe and effective medicine to be legally available to more people. He shared in a personal communication his ambivalence at how things turned out – that though his work enabled so many people to be healers and to be healed, “If I had real courage I’d have gone to jail and insisted this was the people’s medicine and we shouldn’t allow it to be professionalized.”

2015 closed with another loss, the death of Dr. Richard Teh-Fu Tan. Dr. Tan was an excellent teacher, deeply committed to teaching. Directly, and through his students, he eased the suffering of countless patients. Dr. Tan made no secret of his doubts about the caliber of acupuncture education most of his students received in their degree programs. Many seminar attendees reported learning more about effective acupuncture in four days with Dr. Tan than in four years of acupuncture school.

Attention must be paid.

 

 

 

 

 

 

Acupuncture Organizations 2015 – State of the Profession

Posted on by

The 40ish days between January 1st and the Lunar New Year are perfect for reviewing the past year and preparing for the next year. What worked, what didn’t? What direction will we go in when the days warm, the yang rises, and we spring forward?

There is much to consider when evaluating our practices and our profession. To understand how it all fits together we need to dive into the weeds. It’s going to take a few posts, but it will be shorter than the tax code!

Associations/Organizations/Guilds —

AAAOM (The American Association of Acupuncture and Oriental Medicine): Historically, our national professional association. And, historically may be all. The website shows no action items since 3/13/14, and no President’s blog post since 10/9/14. Is there anybody there? Is the AAAOM still alive?

ACAOM (The Accreditation Commission for Acupuncture and Oriental Medicine: Graduation from ACAOM-accredited schools is a requirement in many states. 2015 ended with an announcement of a Degree Titles and Designation Project. This should be interesting – there are already graduates of and students in the existing range of programs and there are widely varying state rules. Better late than never? (Wouldn’t it be easier for the public if we were all Acupuncturists?)

ANF(Acupuncture Now Foundation): Finally, there is an international charitable organization dedicated to educating the public, other health care providers, and those who work in health care policy. For too long we’ve relied on piecemeal efforts to educate others.The ANF is just getting started and needs our support to provide a visible, accessible and positive message about who we are and what we do.

ASA(American Society of Acupuncturists): This non-profit collaboration of state associations launched in 2015. The ASA has potential, and challenges. One challenge – “six degrees of separation” between individual practitioners and the group. A planned website should help bridge the gap. Of greater concern – at the state level, the ASA defers to the preferences of the state association. If an ASA-member state association supports a law or regulation that serves its current members to the detriment of all other LAcs, too bad, so sad for the profession as a whole. There are good people involved with this group so I remain cautiously optimistic. I hope that, before too long, the member groups will see that a victory that disadvantages other Acupuncturists isn’t a win.

CCAOM (Council of College of Acupuncture and Oriental Medicine): The membership association for schools and colleges of AOM with ACAOM accredition or candidate status. They administer the NCCAOM required CNT course, and released an updated (available free!) CNT manual this month.

IHPC (Integrative Health Policy Consortium): The IHPC “advocates for an integrative healthcare system with equal access to the full range of health-oriented, person-centered, regulated healthcare professionals” and has been working to build enforcement of Section 2706 of the ACA to end insurer discrimination against classes of licensed health professionals working within their scope. I don’t know of any LAc that doesn’t support this group’s mission, so it is odd that many LAcs support legislation that would create this sort of discrimination.

NCASI (National Center for Acupuncture Safety and Integrity): One individual? Silent for many months now.

NCCAOM (National Commission for the Certification of Acupuncture and Oriental Medicine): The NCCAOM “validates entry-level competency in the practice of AOM through professional certification.” Their vision is that AOM “provided by NCCAOM credentialed practitioners will be integral to healthcare and accessible to all members of the public.” They are powerful, organized, effective, and better funded than any other acupuncture group. They have had a major role in the path to licensure in many states. However, if you are not an NCCAOM diplomate, feel that the credentialing process is out of hand, and/or if you value traditions other than TCM, the NCCAOM is probably working against your interests.

NGAOM (The National Guild of Acupuncture and Oriental Medicine): A professional medical society organized as a guild under the OPEIU, affiliated with the AFL-CIO. The NGAOM list of 13 VP’s includes the VP, Immediate Past President,Treasurer and one additional board member of the AAAOM and following in that tradition there is significant mystery around their membership and their decision-making process. They want the profession of acupuncture to be more like other health professions. Many LAcs affected by their work aren’t pleased with the consequences. You’ll learn more in upcoming posts.

POCA (The People’s Organization of Community Acupuncture): Mission — “to work cooperatively to increase accessibility to and availability of affordable group acupuncture treatments.” 708 Punk (Acupuncturist) members, 138 clinic memberships, and 1348 patient members. Minutes of meetings posted in their forums, 8 free CEU’s for practitioner members, loads of member support, and a school (POCA Tech) working towards ACAOM accreditation and currently accepting applications for the third cohort of students. This is a successful acupuncture organization.

State regulatory boards are not professional organizations or associations. Their mission is to protect the public, not promote licensees.

An exploration of acupuncture education, events in the states, legislation and regulation, and other items of interest, including more about these organizations, will be coming soon.

 

Act Now – Help the Acupuncture Profession With Sensible Regulation

Posted on by

We have a little more than a week to influence regulations that will impact our profession. The regulatory and legislative process typically includes long periods of incremental movement suddenly replaced by small windows of major activity. One of those windows is open in the District of Columbia, but only until December 26th.

The proposed regulations are especially important because Washington DC is the seat of our Federal Government. If Acupuncturists hope to influence policy at that level we’ll need a strong community of practitioners, the more experienced the better, ready to serve in our governmental agencies.

The good news is that a small group of practitioners worked diligently to move the regulatory activity in a positive direction over the past three years. The bad news is that amidst the positive proposed changes are a few problematic sections. The additional bad news is that we are now late in the process. But maybe not too late. It would be good for the profession and for individual practitioners if we were able to correct those problematic sections. Let’s try.

You can see the text of the new regulations here. Comment by clicking on the blue “Make Comment” box at the bottom of the page (the tab at the top doesn’t seem to work). The comment form will only accept 500 characters, which meant a boatload of editing and three separate comments for me. Feel free to borrow my Three Issues DC2 language for your comments.

In addition, I’ve sent this Dear NCCAOM letter to Mina Larson, (MLarson@thenccaom.org) and Kory Ward-Cook (kwardcook@thenccaom.org) asking for their assistance. Again, the more letters the better. Feel free to use my letter as a template.

Remember, a regulatory change anywhere sets a precedent for changes everywhere. If we want people to get their acupuncture from LAcs, we need to remove obstacles to licensure. Please submit comments and share this post with other’s who would like to weigh in. It doesn’t cost anything except a little bit of time. Imagine what we could do if we took the energy and funds used to battle other professions and focused more on improving our own situation.

I limited my comments to the issues I consider most problematic and easiest to correct.

As I discussed in this post, these regulations will impact us all. Some of our colleagues thought it best to keep these proposed changes from the greater community, and that’s a shame. We need to be in the loop. The more we know, the more we can do to bring about positive change.

 

Herbal Regulation and the Acupuncture Profession – A Better Way.

Posted on by

We’ve got competition. PT’s, MD’s, and DC’s are excited about filiform needles and LAcs are freaking out.

While our energy has been focused on that competition (our training and skills are superior, right?) we haven’t been paying attention to increasing restrictions on our ability to practice the fullness of our medicine. Adding insult to injury, the restrictions on practice are “coming from inside the house.”

I’m talking about restrictions on our use of herbs.

Yes, herbal medicine is powerful and complex and carries both potential risk and potential benefit. Yes, it takes many thousands of hours to come close to mastery of this branch of our medicine. Yes, people have been harmed by the improper use of herbs and supplements. And, yes, at some point the damage done by the misuse of herbs may result in stricter regulation. We may indeed lose access to more herbs.

It’s good that we want to be proactive, protecting the public and the profession from harm. It’s not so good if our actions don’t have the desired result. And not good at all if our actions increase risk to the public and the profession.

Let’s consider the terrain —

  • What portion of harm from herbs/supplements is the result of poor practice by Acupuncturists?
  • What portion of harm from herbs is from the use of raw herbs, what portion is from pre-made herbal formulas?
  • Does preventing certain LAcs from recommending herbs or supplements limit public access to these products?
  • Is the average LAc, even without herbal training, likely to have a positive or negative impact on client’s proper use of herbs and supplements?
  • Which are better tailored to the individualized treatment that is a hallmark of Chinese Medicine — pre-made/patent formulas or raw herbs?
  • Which are more likely to be contaminated with banned substances or prescription medicine – patent formulas or raw herbs?
  • Is it possible to draw a bright line between dietary therapy and herbal therapy?
  • Does limiting LAc recommendation of herbs interfere with the ability of other health care providers or salespeople to recommend or sell herbs or supplements?

See where I am going with this?

Anyone can get Chinese herbs, even dangerous ones. Increasing the regulatory burden on Acupuncturists would make sense if it would protect the public or our access to the full pharmacopoeia on an ongoing basis. It would make sense if LAcs were routinely endangering the public through unregulated use of herbs.

It doesn’t make sense for a subset of our profession to become the only group of health professionals not able to recommend herbs to their clients.

If the only groups weighing in are the schools and NCCAOM, formal (and expensive) training and credentialing will be increasingly required.

Let’s stand united against unnecessary restrictions. LAcs have an excellent safety record. Stay tuned for real-time developments and your opportunity to weigh in on the regulation of herbal medicine for Acupuncturists.

 

How we Grow – The Acupuncture Profession in 2015

Posted on by

One Physician per 371 non-institutionalized civilians was the US average in 2012.

One Acupuncturist per 20,000 non-institutionalized civilians was the US average in 2014.

NCCAOM’s 2014 Annual Report is an important read for anyone who cares about Acupuncture in the US. From it we learn:

  • Applications for certifications dropped from 1744 in 2013 to 1494 in 2014.
  • The number of new certifications dropped from 1144 in 2013 to 972 in 2014.
  • 532 of those new certifications were in Oriental Medicine. Another 16 were for Chinese Herbology (likely existing LAcs choosing or being required to add the Herb certification).

I don’t know how many practitioners are leaving the profession, but many of my peers who were licensed 20+ years ago are stepping back from active practice.

Several current initiatives, including HR 3849 and state-level efforts to mandate insurance coverage of acupuncture would increase demand for acupuncture. (There are 49,435,610 Medicare beneficiaries in the US and 5.5 million Gulf War Vets.) If fully trained Acupuncturists aren’t able to meet the demand, who will provide those services?

At this rate, how long will it take to grow the profession to even one Acupuncturist per 2000 people?

Shouldn’t we focus on that?

I’m baffled. We’ve sued, signed petitions, and marched in the street, all to try to stop the “greatest threat to our profession” – other professions wanting to use the acupuncture needle.

But there’s been silence, or even approval, when Florida (with one DOM for every 17,760 people) changed their regulations in 2014 to require all 4 NCCAOM exams for licensure. Ditto in NJ where new practitioners will need the NCCAOM herb exam to use herbs in their practice. (How many citizens had been harmed by use of herbs by practitioners without the herbal credential? Was regulation needed?) In Nevada (approximately 1 Acupuncturist for every 47,000 citizens) the Board of Oriental Medicine is moving to require a DAOM of all licensees. Meanwhile, many insurance plans are limiting their provider pool to those with active NCCAOM certification, even in states that don’t require that credential. (After all, the vision of the NCCAOM is that “Acupuncture and Oriental medicine provided by NCCAOM credentialed practitioners [emphasis mine] will be integral to healthcare….”)

If we want the public to obtain services from well-trained Acupuncturists we need to make sure providers are available. One thousand new practitioners a year and growing self-inflicted restrictions on where and how we can practice aren’t going to do it.

The greatest threat to our future is an Acupuncture workforce insufficient to meet demand or effectively advocate for ourselves. Allowing or supporting credential creep, educational bloat, and practice restrictions are sowing the seeds of our demise.

Can we please focus on growing our profession?

 

Demographic Information From:

Acupuncture Today Density Map

Physician Data

Population Data

Medicare Data

Veteran Data

NCCAOM Code of Ethics & Grounds for Professional Discipline, Part II

Posted on by

The NCCAOM’s call for comments on the Code of Ethics and Grounds for Professional Discipline ends September 12, 2015 .We owe it to ourselves and our profession to share our thoughts with them.

Here’s what I’ll tell them —

Dear NCCAOM,

Thank you for the opportunity to comment on the Code of Ethics and Grounds for Professional Discipline. My significant concerns with these documents can be traced to three overarching issues —

  1. The NCCAOM credential is required to maintain state licensure for many acupuncturists. You advocate for this arrangement. Yet the current Code of Ethics is more suitable for a voluntary exceptional standard adopted by choice.
  2. States that require NCCAOM credentials have their own regulatory boards, ethical codes, and disciplinary process. The NCCAOM Grounds for Professional Discipline empowers you to pull a practitioner’s credential, removing them from practice, even when a state board would allow continued practice for the same violation. This turns the NCCAOM into de facto regulators and creates double jeopardy for practitioners.
  3. The NCCAOM reserves the right to take disciplinary action against any practitioner who violates the Code of Ethics. The Code covers behaviors ranging from serious threats to the public safety to those in the realm of Public Relations. The NCCAOM should explicitly limit the use of disciplinary action to violations that risk the public safety.

A few specific examples —

  • “Exceeding the scope of practice as defined by law or certification” is grounds for discipline. Scope is defined by the state, and may not be accurately determined by written language in code or regulation. Since state regulatory boards ultimately rule on whether or not a procedure is within scope, and since that board would determine proper discipline for any violation, no action from the NCCAOM is needed. References to scope should be removed from the NCCAOM document.
  • “I will continue to work to promote the highest standards of the profession” is listed in the Code. Must practitioners promote the FPD or DAOM, the addition of herbal exams to licensure requirements, and the expansion of the NCCAOM credential requirement to all states? Who determines the highest standard? This language is coercive at best.
  • The Code of Ethics requires credential holders to report peers who violate the Code. It is untenable to expect Diplomates to report every peer in violation of any aspect of this far-reaching code, and it is unfair to wield the power to hold us responsible for any failure to do so.

I support rigorous professional ethics and respect the NCCAOM’s intent to establish high standards for the benefit of our patients and our profession. However, your role for the profession is to validate entry-level competency. Much of the current Code of Ethics and Grounds for Professional Discipline goes far beyond this role. Continued overreach into areas best left to regulators and voluntary affiliations puts at risk the NCCAOM’s position as a credentialing organization.

Thank you for your consideration of these comments,

Elaine Wolf Komarow, L.Ac, Dipl. Ac. (NCCAOM)

Those of you who would like more background on the role of the NCCAOM in our profession should look at Part I of this post.  I encourage those who are interested in another viewpoint of the NCCAOM and its impact on the profession to review these comments and consider signing this petition.

NCCAOM Code of Ethics & Grounds for Professional Discipline

Posted on by

The NCCAOM is preparing to update the Code of Ethics and Grounds for Professional Discipline and is asking for input. Informed comment requires not only a review of the documents, but also an understanding of the role of the organization.

The path to become an MD in the US is straightforward. Go to college and medical school, sit the licensing exams, complete a residency, apply to a state regulatory board, and, if desired, obtain a board certification in a specialty.  (It is not necessary to be board certified to become a licensed medical doctor, and it is not possible to become an m.d. without successful completion of the licensing exams.)

When the NCCAOM (then the NCCA) was established in 1982 few states had formal licensure. Rigorous credentialing was thought necessary to gain acceptance by the medical establishment. Having a group supported by the profession to ease the regulatory burden on states regarding this new profession was also helpful. Some states weren’t (and still aren’t) at all interested in licensing acupuncturists. In those states, a formal credential to attest to an ongoing fitness to practice was appealing.

But conflict in the early days of the profession, both within the community and from the outside led to disparate paths to practice. There was disagreement about how to test and evaluate the huge knowledge base and varied traditions of the medicine, and how much power to give to any one group. Additionally, the political climate in the various jurisdictions differed greatly.

The NCCAOM‘s official role is to validate “entry-level competency in the practice of acupuncture and Oriental Medicine through professional certification.” But, the NCCAOM is really a chimera, a hybrid, due to the factors mentioned above. It has become a quasi-regulatory agency in some states, establishing practice standards and acting as a disciplinary agency. In other ways it is more like a specialty board — attesting to a particularly high level of qualification (but not exactly, since some states require NCCAOM certification for entry level practice). And, the ongoing weakness and dysfunction of the AAAOM (I’m still waiting on membership numbers, but the practitioner search function reveals the weakness) has led the NCCAOM to fill promotional needs and provide professional support, roles typically handled by professional organizations.

So, does the Code of Ethics and Grounds for Professional Discipline support the NCCAOM’s role of validating entry-level competence? Should it fill the role of a regulatory agency with control over whether or not individuals can obtain or maintain their license? Should it uphold a particularly high standard of practice, suitable for a selected subset of practitioners? Should it fulfill a PR need for the profession? These all need to be considered as we get ready to provide feedback to the NCCAOM.

The NCCAOM has requested input by September 12th.  In part II of this post, coming soon, I’ll share more background information and provide my own thoughts about the documents. I look forward to hearing what you think about the documents and encourage all of us to offer input by September 12th.

AOM Leaders?

Posted on by

Who decides the future of the profession?

Did you know about the meeting of the Acupuncture and Oriental Medicine “leaders” last weekend?

Who represents working acupuncturists at these meetings?

These meetings started in 2005. You can read about previous meetings here, here, and in CCAOM newsletters. Attendees typically include reps from ACAOM, CCAOM , NCCAOM, SAR, NFCTCMO, CSA, AAAOM, AOBTA, and sometimes COMRE. It’s good (I think) that these groups are communicating. It’s not good that most acupuncturists in the US are several degrees of separation away from representation there.

There’s not yet a publicly available report of the 2015 meeting. I do know —

The AAAOM continues to be invited and to attend, despite being out of compliance with their bylaws for years. The AAAOM website currently has no news of the recent elections, the board information is outdated, and there is still no whistleblower protection policy. Word is that the current board overlaps significantly with the board of the NGAOM. Michael Jabbour continues to fill the board position of Immediate Past President (what happened to the real immediate past President Don Lee?) and was present at the AOM Leaders meeting. Membership numbers of the organization are a mystery and I hear the AAC continues to provide much of their funding.

The others present at these meetings know that the AAAOM is a deeply troubled organization that represents only the smallest handful of practitioners. Why, oh why, does the AAAOM rate a seat at the table?

Representatives of the Council of State Associations are also in attendance at these meetings. I am glad that the CSA exists, working to mitigate the damage done by the lack of a functional national organization. I’m concerned, though, that few practitioners have any direct knowledge of this group and what they have to say at the AOML meetings. If you are involved with a state organization, and if the state organization participates in the CSA and communicates back to the membership, then you’ll find out about the CSA. Otherwise, you’re in the dark.

Why isn’t POCA invited? I don’t suppose they’d enjoy being there, but if the AAAOM with their mystery membership is invited, and the NFTCTCMO is invited, why isn’t POCA?

It’s difficult to find the right tone for this post.  I know the groups representing acupuncturists depend on volunteers who are doing their best. I also know that working practitioners too often find themselves at the mercy of the “good ideas” of credentialing agencies, accreditors, schools, and a few powerful colleagues. To make it worse, most practitioners have been misled about what actions are likely to be effective and create positive change.

When I look at who is invited to the AOM Leaders meetings, and how far most of us are from what happens there, it’s no surprise that so many of the developments within the profession seem to work against the best interests of acupuncturists. It reminds me of Congress, and that’s not a good thing.

 

 

It was Twenty Years Ago Today

Posted on by

….. that I was granted my Virginia Acupuncture License (#4). I’d been licensed in Maryland for a few months, but the Virginia License was special. Throughout my years of acupuncture school I’d been involved with the Acupuncture Society of Virginia, working to establish a practice act. We were finally successful in 1994, and my documents were ready and waiting when the regulations were promulgated.

I’m happy I found this wonderful medicine when I did. I feel lucky to be doing this work, and look forward to continuing to practice for decades to come. And yet, these days, I’m mostly sad about the acupuncture profession.

Back in the day, when only MD’s could do acupuncture in Virginia, we argued that the public should have the right and the ability to choose their provider.

We discussed how our medicine could treat the whole person, and that treatments were uniquely tailored to the individual.  We didn’t see patients as a collection of ailments, to be sent from one specialist to the next.

We talked about the good value of our medicine and our belief that it could reduce health care spending.

We got used to the medicine being dismissed by the medical establishment, but held out hope that, some day, they would see the value of what we did.

We knew that this medicine would require lifelong study and learning, but experience told us that about 1500 hours of training was sufficient to produce competent practitioners.

We were happy when we were finally able to receive student loans to attend acupuncture school.

We had concerns about relying on one standardized exam as a precursor to licensure, especially one that was based primarily on one tradition. But we knew that it would relieve some of the burden on the states, and so might help with national acceptance.

It was a time of promise.

Now, my Facebook feed is full of rants — we’ve now decided that, just as the MD’s wanted to protect the public from us, we now must protect the public from the PT’s.

Rather than celebrating the professionals who see the value in this medicine and want to offer it to their clients, we scream that they are stealing our medicine and must be stopped.

We’ve justified our increasing fees (after all, if the MD’s deserve it, we deserve it), and, then chased the insurance dollar so that our patients can afford our services. We’ve adopted the billing games that come along with that, fudging fees, adding services, figuring out what diagnoses to use to get reimbursement, and expressing outrage when we’re called on our behavior. Some of us have gone so far as to attack those who have designed a system to make acupuncture truly affordable to the majority of the population.

We decided that more education would get us more respect, and so increased and increased, and increased again the hours required for entering the profession.  The number and complexity and cost of the exams increased. In a solution to a problem that didn’t exist, practitioners in some states decided an acupuncture education was not enough.  Acupuncturists now must also learn and be tested on herbal medicine, whether they want to use it or not. Various states added additional requirements, so any relocation runs the risk of shutting a practitioner out of the profession. The student loans we celebrated enabled schools to ignore the disconnect between the cost of the education and the likely income of graduates.

I could go on. I won’t.

Shaking my head at the missteps we’ve made, I comfort myself with the confidence that the medicine will survive, even if the profession won’t. Happy Anniversary.

 

 

 

Gainful Employment and Strategic Errors

Posted on by

The Gainful Employment final regulations have been announced. Forgive my commenting prior to a complete and thorough analysis of the 941 page document. (You can see some analysis here.) The gist is that for-profit schools (which includes half of US acupuncture programs) will soon have to show that graduates’ student loan payments are manageable with the profession’s available employment (not taking IBR into account). If they can’t, federally guaranteed student loans will no longer be available.

Why should taxpayers continue to provide loans for educations that history shows aren’t worth the investment? Imagine tuition rates and post-graduate employment assistance if the schools provided and guaranteed loans, and took the hit if they weren’t paid back in a timely fashion.

It is no surprise that for-profit schools are displeased about the impending end of the gravy train. Many for-profit schools, and their related organizations, did everything they could to block the regulations. And, just under the wire, the acu-educational establishment contributed comments (see ACAOM gainful employment word).

(The more expensive FPD, and pressure away from “acupuncture-only” degrees now carry a significant downside for the schools.)

Did ACAOM think their letter might exempt them from the rules or impact the final regulations? It seems unlikely that this little community would shift the tide. It was an unforced error for ACAOM to write a letter that reveals such little concern for graduates and such a strong desire to dodge responsibility. (Some of the more significant issues in ACAOM’s letter are discussed here.)

But our own strategic errors have allowed ACAOM and other other alphabets to disregard our well-being.

The petition that asked the alphabets to stop denying their role in our circumstances received 227 signatures. Petitions to stop dry needling often receive thousands of signatures. Which is more likely to limit professional success — a school that leaves students with extensive debt, poor business skills, and no job placement or alumni support, or a little competition? If we can’t survive the competition from those “untrained” professionals our education is surely lacking.

The Feds and the taxpayers pay a price when schools sell an education for far more than it is worth. We graduates pay a far more personal price. It’s too late for us, but at least the Feds are willing to look out for the interests of those who will follow in our footsteps.