Changing the Acupuncture Rules
A proposal for diversifying the route to licensure
Oregon’s dependency on ACAHM accreditation isn’t a statute written into law by the legislature. It’s a rule the Oregon Medical Board made about the acupuncture training and assessment route to licensure.
The specific requirement for ACAHM accreditation lives in Oregon Administrative Rule 847-070-0016. This is a rule the Board created and can change.
Changing a statute requires legislative action and take a long time. Changing administrative rules requires OMB rulemaking: petition, public comment, Board vote. It can happen within a realistic time frame.
This distinction is everything. Oregon can act now, through OMB rulemaking, without waiting for the Legislature.
The Precedent Already Exists: Breaking Accreditation Monopolies
In Oregon, massage therapy has a similar structure. What matters about that model is it’s regulatory diversity and state control, I’m not referring to “less rigorous” training.
The massage board doesn’t outsource competency determination to a single national accreditor that controls the entire pipeline. Instead, the Board defines what competent practice looks like, then approves multiple pathways that meet those standards: community college programs, private schools, different training models, multiple examination options.
This creates competition, affordability, and innovation while maintaining safety standards. Programs can’t price-gouge students because alternatives exist. Training models can evolve based on employer needs rather than accreditor preferences. And Oregon, not a private national organization, retains authority over its own licensing capacity.
Employer-Driven Competency Standards
Training can be restructured around what healthcare systems actually need.
ACAHM schools train acupuncturists for solo private practice. But healthcare is increasingly organized around team-based care.
In Nepal, where I work with the Acupuncture Relief Project, acupuncturists function as medically literate frontline providers. They recognize red flags, interpret basic labs, understand medication interactions, make appropriate referrals, and document for team-based care. Our employees work inside a health system. And, some Nepali acupuncturists also work in solo practice, which means the struggle and flexibility of self-employment too. Both things are true.
To open additional employment opportunities beyond solo practice, it means asking potential employers: What competencies would make acupuncturists hireable? The answers are consistent: team-based care skills, basic lab literacy, EMR documentation, enough pharmacology to avoid dangerous interactions, training in what Medicaid actually covers.
This isn’t about turning acupuncturists into doctors. It’s about training competent frontline providers who can be employed, which also gives acupuncturists leverage to advocate for better reimbursement and expanded scope from within the system.
Why This Raises Standards Where It Matters
Competency-based training focused on employability changes the standards for what should be taught and it allows cutting away the unnecessary fat that federal tax payer dollars have been funding. (And yeah, if we didn’t use all the money for war or things we didn’t agree with and there weren’t billionaires and all this—but we have to work inside the actual reality).
ACAHM’s model prioritized classroom theory and oads programs with unnecessary credit hours. And, the state can still use ACAHM an accreditor. It just wouldn’t be the only one. So, if an ACAHM-accredited school graduates a student who self pays throughout that school, spending 3.5 years studying classical texts and can’t recognize a medication interaction, that’s fine. That person can happily be in their solo practice, where they and they'll likely build successful practices because they have the financial runway to do so.
But we also need some options for schooling for people that can’t afford to pay out of pocket (even the $30,000 POCA-tech costs or the $60,000 that Middle Way costs) where the debt makes sense. And that means a program that costs less than $50,000 for both tuition and living expenses.
For this person to be trained in acupucncture, the question isn’t “how many credit hours?” It’s “can this person go into an entry-level job and practice safely in real healthcare settings while they continue learning?”
So we need diversity in schools and examinations for licensure and the programs that are able to accept Title IV funding (federal tax dollars) need to show that they are training graduates that have justifiable debt for the amount an acupuncturist earns the first few years out of school ($35-45K) and that those graduates are doing something that makes sense for the federal or state government (like working in the fed/state supported healthcare system). That’s fair and these routes need to be allowed.
People that want other, expensive routes that they can pay out-of-pocket for can keep them too. Nobody’s trying to take bougie education pathways and examinations away.
The Strategy
Petition the Oregon Medical Board to amend OAR 847-070-0016. This would:
Allow OMB to approve programs meeting state-defined competency standards, regardless of ACAHM status
Recognize multiple examination pathways (creating the diversity Oregon’s massage board uses)
Define the basics of what graduates must demonstrate for federal and state employers: safe needling, red-flag recognition and referral, documentation proficiency, basic medication literacy, lab interpretation, clinical judgment
Allow community colleges and public universities to create affordable programs within federal loan caps ($30,000-$50,000 total instead of $250,000)
This is not about lowering safety standards, nor is it about rescuing ACAHM schools, nor is it about asking for scope expansion.
This is preserving Oregon’s legal capacity to license acupuncturists, creating affordable training aligned with workforce needs, and breaking the accreditation monopoly that created this crisis.
I’ve written up the idea here in a document with implementation details so we can have the discussion.