Gainful Employment and Strategic Errors

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.


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© Elaine Wolf Komarow and The Acupuncture Observer, 2013-2033. Unauthorized use and/or duplication of this material without express written permission from Elaine Wolf Komarow is prohibited. Excerpts and links are encouraged, provided that full and clear credit is given with specific direction to the original content.

18 thoughts on “Gainful Employment and Strategic Errors

  1. The Gainful Employment Guidelines represent a wide response led by the White House to end the shameful exploitation of students to earn degrees in fields that have proven to be boondoggles. Acu training programs are being swept up like so much tidal flotsam from the wreckage of mega degree mills Corinthian and Devry . Government loans made to students are the prize schools that strongly encourage students to take on loans that approach $100,000. NCCAOM’s own workforce outcomes suggest nearly half of all LAcs earn incomes at or below $40,000. The likelihood they will be able to pay back the loans is grim. But you already knew that. The May 23 ACAOM letter suggests the alphabets (borrowing your term) do not have a Plan B. The reporting requirements are onerous.More data are and have been available demonstrating the inevitable outcome (many school closures). New reporting guidelines should cause concern for the “training programs.” AOM schools in California have been required to submit reports with similar data to at least 4 separate entities since at least 2011: ACAOM, BPPE, CAB and NCES. The new guidelines duplicate much of those data. The new guidelines include the calculation of metrics such as Debt to Earnings ratio and program Cohort Default Rates. Schools that have counted on filing “inaccurate” reports that would not be shared among regulatory bodies will find the new standards are considerably higher. Reminds me of the Jurassic Park scene when the hunter gets trapped by the cooperating Raptors.

  2. Elaine, this in reference to petitions – do online petitions actually make a difference? Do the parties involved use them when weighing the issues? I admit I tend to steer clear of them.


    • Kathleen, every signature on the petition sent emails to the leaders of the alphabets, asking them to care. In this case, it would have shown the leaders that we were paying attention and that we didn’t want them speaking on our behalf when they aren’t representing our views. Yes, I think it would matter. So far, they do what they want and we ask nothing of them.

  3. All of this is long overdue. I was quite certain that ACAOM’s rather weak and irrelevant response to these proposed rule changes would not change the outcome. It is now clear that all schools and colleges of acupuncture and Oriental Medicine (both for profit and not for profit) have a lot of work to do if they intend to avert their impending fate. I am particularly interested in what the response to the rule change requiring greater transparency will be. To wit [from here on institutions must operate while]:

    “Providing transparency about student success: The rule also provides useful information for all students and consumers by requiring institutions to provide important information about their programs, like what their former students are earning, their success at graduating, and the amount of debt they accumulated.”

    I believe that an ethical and functional system should not be required to make a change like this. Instead, disclosures like this should have been part of its standard operating procedure from the very beginning. I am quite certain that in many states, if I operated my business this unethically, I would be required to surrender my license to practice. In any event it will be very interesting to see who is left standing after this winnowing and how things will be changing (as they certainly must) after transparency policies are instituted.

  4. For profit or non profit…all the same. Just means that the owners and boards of directors take more salary and never show a profit. They may also be taxed differently, but very easy to never show a profit.

    • Well, non-profits have a board of trustees that do not have financial reward based on how much the school makes. Also, different reporting procedures.

  5. This is important. Too many for-profit school owners (at least in my area, Los Angeles) have focused on their own economic well-being to the detriment of the profession.

    But it won’t be enough. I see two other areas where those of us who give a damn still need to focus.

    1) Bringing our skillsets out of the TCM intellectual ghetto. As much as TCM has to offer, over thirty years of watching this field evolve tells me, at least, that we need to add more contemporary skillsets (ie: functional medicine) to our repertoire, and especially develop an understanding of how to educate patients about how their health habits contribute to their complaints. The web changes everything, and we need to develop economic practice models that empower patients to heal themselves, because that’s the direction medicine is moving. We can be in the forefront of this change … or we can continue the old business model of “expert healing the passive recipient of our expertise” which is conventional medicine’s business model … dressed up in TCM clothing.

    2) While we work to master the education-as-healing model … we need to mobilize our patient base to agitate for meaningful compensation for our work and meaningful courses of work from third-party payors.

    • I’m trying this from my phone, so forgive any abruptness. While I concur about the “TCM ghetto”, for me that means not knowledge of the various traditions within acupuncture and asian medicine. I don’t see any better, at this point, for us to add in things outside of our medicine. And, appropriate compensation is a meaningless term. Our entire system of paying for medicine is broken, and ultimately the consumer always foots the bill…..

      • I suppose we all get to decide what and who we are … healers licensed as acupuncturists, or simply acupuncturists. I’ve always considered myself a healer first … with TCM and acupuncture being just one of the skillsets in my ever-expanding doctor bag. YMMV …

        • Acupuncture covers a lot of ground, imo. There is always naturopathy for those who are interested in it all. I’m all for people expanding their knowledge, but when we make it past of the profession up goes educational costs, confusion in the mind of the public, and potentially a loss of coherence. It’s a good topic. One I look forward to addressing more fully when I have a real keyboard.

          • There are many ways to acquire expertise that fall outside the realm of formal (and yes, often expensive) training and credentialing programs. The argument can be made that these less formal approaches might even be more effective, given how many folks graduate from formal training programs feeling unprepared for clinical or business success.

            (and yes … I’ll be here if this thread intrigues you when you’ve got a real keyboard in front of you! x>)

  6. Correction: The Finger Lakes School of AOM Of NYCC in non-profit. Please correct on your list.

  7. thanks for the info, and your continued vigilance in this area…. do you know andy thing about the non-profit schools; will they be held to any standard?

    • At the moment, I believe non-profit schools that grant certificates rather than degrees will have to meet some standards. But, initially, that’s about it. I think it will be a long haul before even the for-profits regs are accepted — there will probably be a lawsuit or two along the way. Here’s hoping that the attention gets all of the schools to take notice and begin CARING. If they acted ethically and responsibly there would be no need for regulations.

  8. This is a quick list and MAY WELL CONTAIN ERRORS! Please double-check!


    1. Academy of Chinese Culture and Health Sciences, Oakland CA
    2. Acupuncture and Massage College- Miami
    3. Alhambra Medical University-Alhambra CA
    4. American Academy of Acupuncture and Oriental Medicine- Roseville MN
    5. American College of Acupuncture and Oriental Medicine- Houston
    6. American Institute of Alternative Medicine- Columbus OH
    7. AOMA Graduate School of Integrative Medicine- Austin
    8. Arizona School of Acupuncture and Oriental Medicine- Tucson
    9. Colorado School of Traditional Chinese Medicine- Denver
    10. Daoist Traditions College of Chinese Medicine- Asheville NC
    11. Dragon Rises College of Oriental Medicine- Gainesville FL
    12. East West College of Natural Medicine- Sarasota FL
    13. Eastern School of Acupuncture and Traditional Medicine- Montclair NJ
    14. Emperor’s College of Traditional Chinese Medicine-Santa Monica CA
    16. Florida College of Integrative Medicine- Orlando
    17. Han University of Traditional Medicine- Tucson
    18. Institute of Clinical Acupuncture and Oriental Medicine- Honolulu
    19. Middle Way—Mt Vernon WA
    20. Midwest College of Oriental Medicine- Chicago & Racine WI
    21. Pacific College of Oriental Medicine- San Diego, Chicago and New York
    22. Phoenix Institute of Herbal Medicine and Acupuncture- Phoenix
    23. Seattle Institute of Oriental Medicine- Seattle
    24. Southern California University (SOMA)- Los Angeles
    25. Southwest Acupuncture College- Albuquerque, Santa Fe, and Boulder
    26. Texas Health and Sciences University- Austin
    27. Tri-State College of Acupuncture- New York
    28. University of East West Medicine- Sunnyvale CA

    1. Academy for Five Element Acupuncture- Gainesville FL (AFEA)
    2. Acupuncture and Integrative Medicine College-Berkeley (AIMC)
    3. American College of Traditional Chinese Medicine- San Francisco (ACTCM)
    4. Atlantic Institute of Oriental Medicine- Ft Lauderdale
    5. Bastyr University- Kenmore WA
    6. College of Oriental Medicine at Northwestern Health Sciences U- Bloomington MN
    7. Dongguk University- Los Angeles
    8. Five Branches University-Santa Cruz and San Jose
    9. Institute of Taoist Education and Acupuncture-Louisville CO
    10. Jung Tao School of Classical Chinese Medicine-Sugar Grove NC
    11. Kings Park University Corporation- Alexandria VA
    12. Maryland University of Integrative Health-Laurel MD (formerly Tai Sophia & TAI)
    13. National College of Natural Medicine- Portland (NCNM)
    14. National University of Health Sciences-Lombard IL
    15. New England School of Acupuncture- Newton MA
    16. New York College of Health Professions- Syosset NY
    17. New York College of TCM- Mineola NY
    18. Oregon College of Oriental Medicine- Portland OR
    19. South Baylo University- Anaheim and Los Angeles CA
    20. Southern California University of Health Sciences- Whittier CA
    21. Stanton University- Garden Grove CA
    22. University of Bridgeport- Bridgeport CT
    23. Virginia University of Oriental Medicine- Fairfax VA
    24. WON Institute of Graduate Studies- Glenside PA
    25. World Medicine Institute- Honolulu
    26. Yo San University of TCM- Los Angeles
    27. Samra University of Oriental Medicine- Los Angeles
    28. Nine Star University of Health Sciences- Sunnyvale CA
    29. Finger Lakes

  9. Oops, I missed the line at the beginning of the post that mentioned that about 1/2 of the US acup programs are for profit. So, no need to respond to my previous question.

  10. I’d be curious to know how many, or if any of he acup schools in the U.S. are incorporated as for-profit. Any info on that?

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