The Pipeline
What is the predicament we are trying to respond to?
Oregon has a major risk of losing its acupuncture training pipeline.
OCOM closed in 2024. NUNM (the other major Oregon program that accepts federal financial aid) faces likely loss of federal financial aid eligibility as early as 2028, which would effectively end enrollment and require its students to go to a teach out. Oregon’s only remaining program is the Oregon College of Community Acupuncture (ORCCA, formerly POCA-Tech), which can graduate up to 20 practitioners a year in a model specifically designed for community acupuncture.
ORCCA and its counterpart in Washington, Middle Way Acupuncture Institute (MWAI), don’t accept federal financial aid. That might sound like insulation from the predicament. It isn’t.
Both schools are still ACAHM-accredited.
ACAHM is a private non-profit that the government has outsourced regulation to. ACAHM decides if a school is performing to their standards and if so, they can receive financial aid.
However, Oregon and Washington (and most states) require either explicitly that a student graduate from an ACAHM-accreditated school or take the NCBAHM-exam, which requires the same. There is currently no other route. So these schools must maintain expensive ACAHM accreditation regardless of whether they take federal loans.
ACAHM’s financial viability depends substantially on membership fees and revenue from the larger schools that do enroll students on federal financial aid. If ( [when] those programs close (which is what the earnings test is projecting) ACAHM could [will] lose enough of its revenue base to become unviable as an accreditor. They already ran at a deficit last year.
The states haven’t set real competency standards to protect the practice of acupuncture. Curiously, they have made safety standards for licensure dependent on the approval of an entity whose actual job is gatekeeping Title IV student loan access.
Acupuncture schools that don’t take federal financial aid, who are graduating students with no debt, should be unscathed by these loans caps and the OBBBA Earnings Premium test. But what happens when their required accreditor can’t accredit them?How would students be able to meet licensure requirements?
It’s fascinating that these schools solved the problem but it’s still precarious, not because of anything they did wrong, but because they’re structurally tethered to a fragile accreditor whose financial survival depends on the very institutions whose behavior created the crisis in the first place. They have no exit from that dependency as long as licensure runs through ACAHM.
There may be some possible off-ramps here:
Another accreditor absorbs the position (an unlikely new acu accreditor, regional accreditor, etc.), but that takes time
States emergency-amend their rules to recognize the programs through another pathway. This is what I’m working with the OAA now to do, but rulemaking is a slow process
If a school doesn’t accept federal financial aid, the entire rationale for accreditor oversight evaporates. Accreditation exists to protect the federal lending system from bad actors. If there are no loans, there’s no need for a gatekeeper for loans.
The state’s only legitimate interest is entry-level safety and competency. That’s a question states are fully equipped to answer through their licensing boards and it’s their job to answer it, not outsource it to an entity whose mandate is protecting the federal lending system, not the public.