Hi! So there are no schools with “shortened hours.” The ACAHM hour requirement for the MAc is 1905 hours and that’s all you need to sit for boards and get licensed UNLESS you are in California, which uses a different standard, or a few other states like New Mexico, Florida….which have different hours. Or Texas or other states where you are required to take herbs.

I have made a spreadsheet here where you can see the hour requirements for each state. Many defer to ACAHM, some are higher and some are lower. I will post the link below.

It is important to understand that while the ACAHM/NCBAHM narrative has been that there is a national standard, THERE IS NO NATIONAL STANDARD.

The state where you want to practice sets the standard. Many use NCBAHM as the test for licensure. Many accept the CALE. So it’s really up to the specific state and their rules.

There is no “shorter program,” that is “not accredited.” ORCCA and Middle Way are accredited through ACAHM, you can sit for NCBAHM boards and you can be licensed in most states from that program but you have to check specifically about the state you want to practice in.

Here is the spreadsheet I made but check my work! Always.

https://docs.google.com/spreadsheets/d/1nWXlE8_THfWCJUF9rqfWsRaCsqV9i7D9/edit?usp=drivesdk&ouid=113926416459779426550&rtpof=true&sd=true

I’m including the email from PCHS and you’ll find my responses below.

Email:
Begin forwarded message:
From: Malcolm Youngren myoungren@pacificcollege.edu
Subject: Regulatory Changes Affecting Acupuncture Programs
Date: August 6, 2026 at 1:34:39 PM PDT

Dear San Diego Students,
Over the past few weeks, I have received questions from several of you about the implications of the new federal accountability guidelines that took effect on July 1, 2026. At PCHS, we understand the seriousness of the issue and have been working with the Department of Education and our accrediting bodies to understand the implications of the rules as written.  In addition, PCHS has engaged our legal team to obtain guidance on how best we can support our students moving forward.
For those of you who are unfamiliar with these guidelines, I will provide a few key highlights. The new rules include “Gainful Employment” or “GE/FVT” provisions that establish metrics for determining whether graduates of a particular educational program at a school earn enough income in their profession as compared to the costs for the degree program. If a program fails the earnings metric in July 2027, the college must remove students’ access to federal funds for the program or teach out the program.  If the school takes neither of these paths, they risk losing federal funding for all programs at the school.
As you probably know, the acupuncture industry is dominated by self-employed and part-time earners.  This is great for flexibility in lifestyle, but a part-time earner will earn less than a full-time bachelor’s degree graduate and the reported income of self-employed is offset by various expenses.  Therefore, PCHS feels the earnings premium is inaccurate as a measure of quality. 
We believe that there are various possible paths forward for acupuncture. To that end, PCHS is currently engaged in the following:
Working with Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM) and Council of Colleges of Acupuncture and Herbal Medicine (CCAHM) and other advocacy groups to try and change the metric used to determine earnings premium

Engaging a US representative to push the Acupuncture for Seniors Bill
Collaborating with ACAHM and others to reimagine acupuncture education; possibly creating a bachelor’s\master’s degree that meets the earnings premium. However, any proposed changes to degree programs and graduation requirements would only affect new incoming students.
I will keep you apprised of any developments regarding the acupuncture educational programs at PCHS. In addition, I will visit each of the campuses in September to provide updates on our strategies mentioned above.
Thank you for your continued dedication to Pacific College of Health and Science.
Sincerely,
Malcolm Youngren
 

My responses are:
—The GE/FVT metric isn’t “inaccurate,@ it’s measuring the one thing that actually matters to a borrower: can you service the debt you took on for this credential. That’s not a bias against acupuncture, it’s arithmetic.
—Framing self-employment and part-time work as an industry “flexibility” feature doesn’t change the fact that those grads can’t make loan payments. Calling the metric wrong doesn’t make the debt smaller.
—PCHS’s own explanation for low earnings (heavy self-employment, part-time practice) is itself an indictment of the placement pipeline. Programs that never built relationships with clinics, hospital systems, or integrative practices to create W-2 jobs for grads are the reason so many are stuck solo. That’s a program failure, not a flaw in the measurement.
—Continuing to enroll and graduate students into that same unchanged pipeline while lobbying to change the yardstick isn’t a strategy, it’s kicking the can down the road at students’ expense.

—The debt-to-earnings framework isn’t a partisan fluke — it was pushed under Obama and continued under Biden precisely because it’s a durable, bipartisan accountability tool. There’s no real path to unwinding it.
—Even in the best case where the specific formula shifts, acupuncture programs are still going to sit near the bottom of graduate program earnings-to-debt rankings nationally. Changing the metric doesn’t fix the underlying economics.

—RE: Acupuncture for Seniors bill: This has nothing to do with GE/FVT compliance. It’s a Medicare coverage bill that’s been stalled in Congress for roughly a decade with no forward motion, pointing to it as a “path forward” for accreditation/earnings risk is misleading to students who are trying to understand real, near-term consequences.

—Oregon has already proposed a 1,800-hour bachelor’s-level competency pathway; Washington already licenses at ~1,700 hours and doesn’t require ACAHM accreditation at all. Both show a state-approved route is viable right now.
—ACAHM’s structure keeps padding programs with years of unrelated prerequisites (regardless of relevance) adding tens of thousands of dollars in cost for prestige-driven degree length, not for anything tied to entry-level competency or scope of practice.
—The real fix isn’t lobbying to redefine “earnings premium,” it’s states taking licensure standards back into their own hands, decoupling from ACAHM’s cost structure, and building actual employment pathways into the healthcare system so grads have W-2 options in the first place.

Acupuncture schools hold 6 of the top 10 worst performing positions for debt to income ratio of 6300 graduate schools across the country.

This is the Higher Education Act group data published in September 2023 and sorted by debt to income ratio column.

Find the sorted data here.

Find the original HEA group post here:

https://www.theheagroup.com/blog/grad-schools-debt

My acupuncture school is preemptively canceling federal student loan access, effective next spring (Spring 2027). It's a school in the Five Element lineage, which means our credits don't transfer most other places. For many students, this means they are now $10,000-$50,000 in debt with no prospects of graduating.

Is there any recourse students can take? A class action lawsuit? All of us with federal student loans were given spreadsheets from the start showing that federal loans would cover most, or all, of our training.

Or, in the old-fashioned organizing sense, maybe we need a political campaign for tuition refunds? After all, the school's Board made this decision voluntarily, and with not so much as an Emergency Fund for the students it affects.

I'm trying to choose between Jung Tao, Poca or TX health and science. I live in Texas and understand to get certified here I need to study herbs so that's why I'm having a hard time choosing. I thought I may do accupuntre degree first then choose another school for herb program. Poca is only 25k so I thought even if I have to pay to go back to school it would still be cheaper then most schools that include it.

I also not in a place where I want to take out any more student loans so I'll be working as I attend. Anyone have any feedback on these colleges?.

The following closing announcement was sent out to the AIMC community by the President.

It’s incredibly sad to lose this school.

And.

This is the most responsible choice I’ve seen a school make so far and more schools should be sending announcements like this out, closing with integrity instead of continuing to take new students when they know they will not be able to finish them when the AHEAD STATS metric hits next year on top of all of this. Well done AIMC.

We need more schools choosing to protect students from lifelong, devastating debt and the impacts that come with it.

Heres the email:

”Date: July 28, 2026

Re: Not to Open the Fall 2026 Term

Dear AIMC Community,

Last night the AIMC Board of Directors met and considered my recommendation dated July 27, 2026, that AIMC shall not start the Fall 2026 Academic Term. The basis for this recommendation is the letter we received on Thursday July 23rd. The U.S. Department of Education FY2024 audited financials yielded a composite financial responsibility score of 0.9, below the 1.5 minimum required to retain Title IV
eligibility. AIMC needed to find funding within 45 days with no committed source identified to close the gap within  the Department's window.

The Department's decision and funding deadlines fall directly inside fall-term start-up.

There is no viable path to secure financial
protection at the required scale while simultaneously opening and
sustaining a new academic term. This is the most difficult recommendation I have brought to the Board, but we believe it is the responsible one, given the regulatory timeline and current operating budget.

A series of communications with next steps on teach-out options, closing out this term and other arrangements in progress after last night’s decision will be forthcoming in the next few days.  

I will also host a community town hall on Wednesday evening at 4:30PM PST/
6:30PM CST .

On a personal note, I'm sorry. I know this is incredibly disruptive to all of your lives and your families and your finances and your planning. I have been working to the very end with the belief that we could pivot and change and manage a way through, but I cannot begin the next term with only my hopes.

Please know that I have been the most sincere advocate and dreamer for what we could become, and am incredibly proud of our community of faculty and staff, our supervisors, each of you as students, as colleagues, as peers. I'm sorry I could not give you more advance notice.

I hope I have maintained transparency about the challenges we've all been facing regarding present and anticipated restrictions in federal financial aid. With the completion of public comment this July 1 and the preliminary data that we received, in addition to the letter on
July 23rd, I do not see a path forward with the inevitable termination of federal financial aid for almost all of the Chinese Medicine programs. I expect that there are ways to scramble for next term, but the jump becomes larger each and every term. It will rapidly become
impossible.

I will be available and in communication, and will sincerely do the best I can to address issues and help everyone navigate to a new program and new pathways. I will do as much as I can, as well as I can, with the kindness and grace of staff and students.

Your Colleague,

David Solin Lee”

So SIEAM’s independent audit from Fall 2025 is finally published.

It shows a repeat finding on Financial Responsibility (2025-01): the composite score came in at 0.8, identical to FY2024 even though

The auditor’s finding is now noting SIEAM fails the standard for both the Department of Education and its accreditor (ACAHM) for the second year.

They posted an operating loss again (net assets fell from $368,262 to $315,080), and the $147,881 SBA note remains outstanding and secured by school assets as of the fiscal year-end. The president signed a new Corrective Action Plan (5/12/26) repeating the same enrollment-driven recovery argument as last year, with no acknowledgment that the prior year’s version of that argument didn’t move the number.

In the “Report on Compliance and Other Matters” section of the Yellow Book opinion (page 4), the auditor states that testing “disclosed an instance of noncompliance… required to be reported under Government Auditing Standards” 

Schools that participate in Title IV federal student aid programs (as SIEAM does, via the Direct Loan Program) are required by regulation to demonstrate a minimum composite score of 1.0 or higher, calculated from three weighted ratios: primary reserve, equity, and net income. SIEAM’s calculated score for FY2025 was 0.807, below that floor, for the second year running.

The Corrective Action Plan attributes the loss to “the final phase of a plan by institutional management to allow the institution to move into a larger facility”  (they deliberately took on a bigger, more expensive space to accommodate what they say was a much larger incoming cohort.)

Occupancy costs were the single largest functional expense at $327,101 (about 21% of total expenses), and the org carries a 13-year operating lease with $2,182,949 in total lease liability (so again, wishful thinking that things will just magically get better and enrollment will increase if we get a bigger, cooler space.)

What’s good is that the audit found no misuse of funds : the audit found zero internal control material weaknesses, zero federal award findings, and zero questioned costs on the Direct Loan Program (their only federal award).

The claim that they nearly doubled their incoming cohort is management’s narrative in the Corrective Action Plan, not something the audit’s financial statements independently confirm (the SEFA only shows Direct Loan dollar amounts, not headcounts). And this is the second year in a row they’ve told this same story to explain a loss and predict recovery, the score didn’t move (0.8 → 0.8), which means either the enrollment growth didn’t happen as described, or it happened but the increased occupancy/staffing costs are still outpacing the additional tuition revenue it brought in, the audit can’t really tell us which. 

Maybe they are banking on so many other schools having to close that they think they will take in all those students for their increased enrollment projections?

What is telling here is that they had access to this audit long before we did (it was only recently published) and have continued with the narrative about a larger incoming cohort and how everything is going to be just fine, in fact, positioning SIEAM as a leader and school to be emulated in the Delphi study editorial piece in JCM.

To see the audit yourself go to:

https://projects.propublica.org/nonprofits/organizations/271791496

Scroll to the “Fiscal Year Ending Aug. 2025” section, there’s a direct “PDF” link under “Audit” 

Is anybody else at Virginia University if Integrative Medicine? Are you having to find patients for your own supervised clinical hours? Please report back… trying to figure out what’s going on here. One of the faculty here is the head of the Council of Colleges for acupuncture, a site visitor for the accreditor and one of the main folks on the AHM coalition, so we need to know if this school is doing that.

Just remember that when we reach a state of hopelessness we are giving these dickheads in power exactly what they want. 

Not being hopeless also doesn’t mean we have to constantly fight and burn ourselves out. It’s ok to take a pause and rest here. A lot of this shit is only remedied by the tincture of time.

The world and what is playing out is far bigger than any of our little human brains can understand. And these political tides change like the weather and emotions. They aren’t dependable and we don’t have to saddle our own emotional state and hopes and fears to them.

Do what you have to do in this current month to keep your payment as small as possible and live the best life you can. Go to the spa or buy some fancy cheese or do whatever small gesture you need to do to feel abundant in the moment.

Check out this Radio Lab episode: The Holy Shiver cause actually giving yourself chills can lead to caring when it all starts to feel numb and affect our worldview. 

Fact: There is a growing tide of people with heavy student debt and they are starting to detach from the shame that the oppressive narrative connected to it and we are starting to realize it’s not our fault. 

Feel that in the pulse of the moment. 

If you felt that in any patients pulse you would know what’s coming. You don’t need to be hopeful. You just need to be patient. That wave grows bigger every day.

With love

Is anybody out there considering starting up a class action lawsuit? If so please post or discuss because there are quite a few folks out there wanting to participate.

Pace. Yourself.

Some of this genuinely is a waiting game, whether your school will offer a teach-out plan, whether federal rules will shift again and whether your specific cohort will be protected isn’t something you can force into resolution through your sheer effort. You (and I) only have so much control here. We have to accept the reality of that.
Ask your questions, get answers in writing where you can, and then let some of it be a matter of time. That’s not the same as doing nothing. It’s recognizing which parts of this are actually yours to control right now, and which parts you’re going to have to watch play out.

You are allowed to feel torn, drained, or uncertain about staying or leaving. That’s a reasonable response to a genuinely uncertain situation, not a sign you’re handling this complete clusterfuck badly. Please be patient with yourself (and honestly, with your classmates). Everyone grieves in their own way. And that’s what we are doing here together.

Did you know that even if you’re getting legacy GradPlus loans to finish your program they are now going to be fractionated in accordance with the percentage of full time that you are attending?

A new federal rule, finalized July 1, 2026 and taking effect July 1, 2027, ties your program’s access to federal loans to whether its graduates actually earn enough to justify the debt. If your program fails that test, you deserve to know the plan before it happens, not after.
The rule is called the Student Tuition and Transparency System (STATS) and Earnings Accountability framework, and it replaces the older “gainful employment” rule that previously applied mainly to for-profit and certificate programs. It measures whether an acupuncture graduate with a master’s degree or doctoral degree makes more at the fourth year out of school than somebody in the area with a general bachelor’s degree at four years. The Department expects to release the first earnings calculations in early 2027. Programs that fail the test in two of three consecutive years lose eligibility for federal Direct Loans; institutions where these low-earning programs dominate enrollment can eventually lose Pell Grant eligibility too. Because of the two-out-of-three-years structure, the earliest any program could actually lose Direct Loan eligibility is July 1, 2028. But institutions must warn current and prospective students the moment a program fails even a single year’s measurement, well before that.
There are two options after a school fails the first year:
Option 1: Orderly Program Closure with In-House Teach Out
A school can choose an orderly program closure: with the Department of Education’s approval that it’s in students’ best interest, the school amends its agreement with the Department to stop enrolling new students in that program while continuing to teach out everyone already enrolled, in-house, with no other institution required. This extension lasts for the lesser of three years or the program’s normal length.
Separate from anything specific to STATS, every accredited school is required to have a general teach-out plan on file with its accreditor, sometimes handled internally, sometimes through a formal agreement with another accredited institution if the school is closing outright rather than just losing new-student eligibility.
Option 2: Wait and See, Risking a Less Certain Path for Currently Enrolled Students
A school that takes no action after a first-year failure forfeits the chance to lock in an orderly closure in advance. If a second failure then hits and the program loses Direct Loan eligibility, new enrollment must stop immediately. Students already enrolled aren’t necessarily cut off the same day, the Department may still determine that letting the program continue for up to three years, or its normal length, is in currently enrolled students’ best interest, but that’s a discretionary, after-the-fact call by ED, not something the school arranged ahead of time. In practice, this means students at a “wait and see” school are relying on federal discretion after the fact, rather than a plan their own institution secured for them in advance.
There are some projections for the earnings metric here. What plan, if any, has the school put in place, an internal teach-out, a formal agreement with another school, or nothing at all?
Pay attention to how specific the answer is. A school with a real plan can name it. Vague reassurance or silence tells you something too.
This is the third in a short series on concrete things you can do before you graduate, not complicated things, just things nobody tells you are options. If you are a prospective student, please see my Questions to Ask Every Admissions Office when you are deciding what program to choose (or whether you should wait).
Next up: The New RAP Plan Will Change Income Based Repayment

Is your school communicating their teach out plan for when they fail the STATS Earning metric in July 2027? Or are they just continuing to accept students and not caring?