ACAHM Straw Poll

There is a fourth possibility. Poll closes 6/21.

In May, I wrote about the story of Icarus. I was using this story to show how extremes can be fatal and we need to honor those ideas as we navigate the current crisis in our profession. We’re discussing a graduate-only degree future that flies really close to the sun, expecting all acupuncture students to be able to pay out of pocket. And then there are discussions about radical deregulation that sink too close to the sea. I believe we need to find a middle way

On May 29th, the Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM) released a straw poll offering three proposals for revising their program accreditation standards. The deadline to respond is June 21st.

I’ve spent time with the proposals and tried to work out the math. I’m sharing what I found here in case you want to use it as you vote and in case anybody sees something different in their own math and wants to discuss it. The spreadsheet I built is linked below and you’re welcome to check my work (please do!)

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Proposal 1: Decreased MAc — 1590 hours

Prerequisites (60 semester credits = 2 years of nothing-to-do-with-acupuncture credits)

Cuts total hours from 1,905 to 1,590.

• Lowers tuition by cutting important hourly requirements by 315 hours — taking away 30% of biomedicine content and significant clinical training hours! These are both areas that employers are telling us we need more (not less) of. Saves approximately $3000-4000 from hundreds of thousands in debt.

• Cuts 15% of the East Asian Medicine content while keeping two years of prerequisite requirements that cost the student an incredible amount of money and don’t help them with an understanding of acupuncture medicine.

• Clinical observation hours are cut by 50%.

• Still a graduate program: student has to pay total tuition and living costs out of pocket (subject to the AHEAD earnings metrics that are threatening schools’ federal financial aid eligibility)

This proposal does very little to cut the debt, doesn’t address AHEAD earnings premium metric problem, does nothing to increase jobs, does nothing to increase insurance reimbursement, carries real clinical risks (and risk of loss of scope).

Cost (using 35K/year if the student cannot work full time while attending school) and current MAc prereqs at PSU rates (60 semester credits = 90 quarter credits). If you create a program where the student can work, you can change these values in the spreadsheet.

• Prereq tuition: 90 × $217 = $19,530

• Prereq Pell (maxed over 2 years × $7,395): −$14,790

• Net prereq tuition after Pell: $4,740

• Prereq living: 2 years × $35,000 = $70,000

• Prereq total: ~$74,740

ACUPUNCTURE PROGRAM COSTS (3 years)

• Program tuition: ~$71,016

• Program living: ~$105,000 (3 years × $35,000/yr)

• Less Pell Grant: $0 (graduate program — not eligible)

• Program total: ~$176,016 (completely out of pocket with AHEAD)

Prereq total: $74,740

Program total: $176,016

Grand total: $250,756

A quick note about prereqs for P2 and P3:

These are quite specific and detailed. They’re not just “30 credits of anything.” They require: Writing and communication, Public speaking/oral communication, General psychology, Natural sciences, Mathematics/quantitative reasoning, Social and behavioral sciences, and Humanities.

That’s a structured general education curriculum. Which raises the obvious question: if these subject areas are important enough to require before entering an acupuncture program, why aren’t they part of the acupuncture program? Instead they seem invisible to the costs, but they are real to the student debt experience and we’re going to count them here!

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Proposal 2: BSAc — 1,590 hours

Identical clock hours to Proposal 1: the same 1,590 hours, the same cuts to biomedical sciences, the same halving of clinical observation. The only differences are the credential label (bachelor’s instead of master’s) and one fewer year of prerequisites.

Prerequisites (30 semester credits = 1 year)

• Prereq tuition: 45 QC × $217 = $9,765

• Prereq Pell (maxed at 1 year × $7,395): −$7,395

• Net prereq tuition after Pell: $2,370

• Prereq living: 1 year × $35,000 = $35,000

• Prereq total: ~$37,370

Acupuncture Program Costs (3 years)

• Program tuition: ~$31,968 (UG rate ~$296/QC × 108 QC)

• Program living: ~$105,000 (3 years × $35,000/yr)

• Less Pell Grant: −$22,185 (maxed 3 years × $7,395, undergraduate program)

• Program total: ~$114,783

Prereq total: $37,370

Program total: $114,783

Grand total: $152,153

Saves approximately $98,600 vs. the current MAc. This proposal addresses the AHEAD earnings metric problem and meaningfully reduces debt, primarily through the undergraduate classification and Pell eligibility, not through the hour reduction. The savings are real but the program content is identical to Proposal 1, which means the same clinical risks apply. Phrases like “de-professionalization,” “bifurcation,” and “subordinate or protocol-driven roles” appear in the threats column without any corresponding evidence that these outcomes actually follow from a bachelor’s entry credential, especially under a federal administration supporting more technician programs, apprenticeship opportunities and less credential inflation.

The more immediate problem is with timing, since ACAHM cannot accredit a bachelor’s program and if they could get it approved it would take 12-24 months, which gives no help to schools in crisis right now. And if the hours stay at 1,590, with a 30% cut to biomedical sciences and observation halved, the profession will have traded professional status risk for a program that is harder to defend on clinical grounds, at a savings that could have been achieved without cutting a single hour.

Conditional support: but only if hours are increased to at least 1,800, biomedical sciences are restored to a defensible floor, and ACAHM files for DOE scope expansion immediately rather than after the straw poll closes.

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Proposal 3: Applied BS + MAc — 1,200 + 735 = 1,935 combined hours

This is the only proposal that results in a master’s credential through an undergraduate entry pathway. BUT Proposal 3 calls itself a bachelor’s pathway, but it still requires 30 semester credits of prerequisite coursework before the applied bachelor’s program begins. That makes it functionally a 1+2+1 structure: one year of prerequisites, two years of applied bachelor’s content, one year of master’s. A genuine bachelor’s degree doesn’t require prior college credits for admission. A BSN in nursing doesn’t. A BS in physical therapy didn’t. You enter from high school and everything happens inside the degree (which, btw is a four year degree, just like this).

The combined hour total of 1,935 is actually 30 hours more than the current MAc, and practice management hours double (60 + 60 = 120 vs. the current 90). Maybe that’s good to help folks out with self-employment skills?

Both tiers require ACAHM accreditation, which requires the same 12–24 month DOE scope expansion as Proposal 2. This means that neither tier is available to schools and students who need relief now.

Prerequisites (30 semester credits = 1 year)

• Prereq tuition: 45 QC × $217 (PSU UG rate) = $9,765

• Prereq Pell (1 year × $7,395): −$7,395

• Net prereq tuition after Pell: $2,370

• Prereq living: 1 year × $35,000 = $35,000

• Prereq total: ~$37,370

Applied BS Program Costs (2 years, undergraduate)

• Program tuition: ~$27,824 (94 QC × $296/QC NUNM UG rate)

• Program living: ~$70,000 (2 years × $35,000/yr)

• Less Pell Grant: −$14,790 (2 years × $7,395)

• BS program total: ~$83,034

MAc Post-BS Costs (1 year, graduate)

• Program tuition: ~$21,520 (40 QC × $538 NUNM QC grad rate)

• Program living: ~$35,000 (1 year × $35,000/yr)

• Less Pell Grant: $0 (graduate program — not eligible)

• MAc program total: ~$56,520 (must be paid completely out of pocket by the student due to AHEAD).

Prereq total: $37,370

BS program total: $83,034

MAc program total: $56,520

Grand total: $176,924

Saves approximately $73,832 vs. the current MAc. The savings come from the undergraduate tuition rate and Pell eligibility during the BS years, not from the hour structure.

Better Proposal: No-Prerequisite BSAc (1,800 hrs, 4 years total including Paid Supervised Practice Year

A three-year undergraduate degree entered from high school: no prerequisites, no prior college credits required. General education content (writing, sciences, psychology, mathematics, humanities) is integrated into the degree in year 1. Core acupuncture content, biomedical sciences, and supervised clinical training occur in years 1, 2 and 3.

Graduate after three years with BSAc program and then sit for NCBAHM boards

Year 4: 500 hours of paid supervised practice

• Direct supervision by a licensed preceptor

• Preceptor may be in solo practice, group practice, community clinic, hospital, or integrative setting, using NCBAHM Route 4 preceptor and documentation standards as the supervision framework

• Student is employed by the clinic during this year

• No tuition. No loans. No living cost burden beyond what they’re already earning. At 500 hours this is roughly 12–14 hours of clinic per week, leaving room to work another job alongside it.

• Completion results in full independent licensure

Cost (no prerequisites, NUNM UG rate)

• Prereqs: $0

• Program tuition: ~$37,000 (3 years at NUNM UG rate)

• Living (3 years × $35,000): $105,000

• Pell Grant (3 years × $7,395): −$22,185

• Year 4 supervised practice: $0 tuition (student is paid)

Grand total (if borrowing full COL): ~$119,815

Compared to the current MAc at ~$250,756, this is a reduction of ~$131,000 without cutting a single clinical training hour.

At 400-450 hours per academic year, this is a full-time intensive program, about 15 hours per week over a 30-week academic year. At a public university where 1 credit equals 10 contact hours rather than the 12-hour model used at private acupuncture schools, students still have meaningful flexibility. Courses structured in evenings or weekends allow part-time work alongside the program, which would significantly reduce or eliminate that $35,000/year living cost figure. Students entering directly from high school may also continue living at home during at least the early years, further reducing the real cost of attendance.

Also: ACAHM already has authority to accredit professional certificate programs. This is a pathway not included in this survey. A strong 15-18 month acupuncture pathway for other allied health professions should exist so that they are not forced to choose dry needling pathways due to economic constraints.

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The straw poll closes June 21, 2026:

I’ve written up my own responses to each proposal separately, including specific language for the Additional Models and Final Comments fields.

The full cost model and program comparison spreadsheet I keep tweaking is here. You can copy it and use it too.

The yellow cells are editable. if you’re at a program with different tuition rates, you can put your own numbers in and see what the math looks like for your institution.

If you find errors in my math, please tell me.