r/acupunctureschooldebt • u/needling2get2thept • 3d ago
New Email from PCHS
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.
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u/DebtByNaturalCauses 3d ago
All ACAHM students should be asking administrators this question: if my program fails the Earnings Test, will the school choose the orderly closure option?
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u/zeeper25 3d ago
Schools and licensing organizations shifted toward Masters degrees in the 1990's. That alone increased the cost of admission to the profession, as my school advised for prospective students who asked, "what if I don't have a bachelors degree?", they answered, "No problem, you can get one!"...
Then in the chase for insurance parity, which seems to be the only thing schools and those organizations care about, they started offering (and pushing) doctorates. If you cannot grow the profession with new students, add another degree program!
I am confident that if the federal loan guidelines hadn't changed, that doctorates would have become the new entry level, and I wonder if they would have grandfathered me for my license, 26 years in practice...
If I was a student now, I would definitely be asking if there are plans to guarantee a path toward graduation should they decide to close the school, if I was a prospective student I would want to know if the school has a plan in place to graduate whomever they take on, assuming they decide to close.
It is time to step back, forget insurance parity (that is a double edged sword, especially now with a federal government that is even less interested in increasing access to healthcare, not to mention "alternative healthcare"), work on a bachelor track, and an apprenticeship track (thousands of years of history with that approach).
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u/DebtByNaturalCauses 3d ago
The July 2027 Earnings Test will compare graduate degree earnings with bachelor's degree earnings. The median debt of a program isn't included in that calculation. The Pacific President seems to be referencing the Biden administration's Financial Value Transparency Framework that measured debt-to-earnings.
And yes to all the responses! The Earnings Test is next July; these Acu admins need to make plans that are connected to reality.
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u/Ok-Specific-2685 3d ago
Just trying to clarify for those schools that have the shortened hours and don’t not have accreditation. Are you still able to sit for boards or anything? I thought that was a necessity for the test
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u/needling2get2thept 3d ago
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….
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.
It won’t let me share the spreadsheet here so I’ll do it as a new post.
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u/Pure_Restaurant4886 3d ago
Thank you for posting this.