Tag Archives: debt

Gainful Employment and Strategic Errors

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The Gainful Employment final regulations have been announced. Forgive my commenting prior to a complete and thorough analysis of the 941 page document. (You can see some analysis here.) The gist is that for-profit schools (which includes half of US acupuncture programs) will soon have to show that graduates’ student loan payments are manageable with the profession’s available employment (not taking IBR into account). If they can’t, federally guaranteed student loans will no longer be available.

Why should taxpayers continue to provide loans for educations that history shows aren’t worth the investment? Imagine tuition rates and post-graduate employment assistance if the schools provided and guaranteed loans, and took the hit if they weren’t paid back in a timely fashion.

It is no surprise that for-profit schools are displeased about the impending end of the gravy train. Many for-profit schools, and their related organizations, did everything they could to block the regulations. And, just under the wire, the acu-educational establishment contributed comments (see ACAOM gainful employment word).

(The more expensive FPD, and pressure away from “acupuncture-only” degrees now carry a significant downside for the schools.)

Did ACAOM think their letter might exempt them from the rules or impact the final regulations? It seems unlikely that this little community would shift the tide. It was an unforced error for ACAOM to write a letter that reveals such little concern for graduates and such a strong desire to dodge responsibility. (Some of the more significant issues in ACAOM’s letter are discussed here.)

But our own strategic errors have allowed ACAOM and other other alphabets to disregard our well-being.

The petition that asked the alphabets to stop denying their role in our circumstances received 227 signatures. Petitions to stop dry needling often receive thousands of signatures. Which is more likely to limit professional success — a school that leaves students with extensive debt, poor business skills, and no job placement or alumni support, or a little competition? If we can’t survive the competition from those “untrained” professionals our education is surely lacking.

The Feds and the taxpayers pay a price when schools sell an education for far more than it is worth. We graduates pay a far more personal price. It’s too late for us, but at least the Feds are willing to look out for the interests of those who will follow in our footsteps.

What’s your Acupuncture Degree Worth?

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Answer: Less than it used to be.

(Please, sign the petition.)

If you earned an MAc and Dipl. Ac (NCCAOM) twenty years ago, you thought you had it made. You could get a license in almost all states with licensure. The schools and the NCCAOM touted the caliber of the education and credentials. You knew you had plenty to learn about this medicine, but you could practice safely.

In the gainful employment letter ACAOM points to the (supposed) earnings of those long-ago grads to minimize the financial struggles of recent grads.

But in 1995 the NCCAOM added the Herbal exam, and later the OM. Some states now require those additional credentials of all practitioners. ACAOM has increased hourly requirements for school accreditation several times. And the NCCAOM has put additional limits on who can take their exams.

Some of our most esteemed teachers do not meet the current requirements for sitting the exams. Many practitioners are trapped, unable to relocate.

By increasing the range of degrees and credentials available before our “brand” was established and our profession was strong, the alphabets increased division and confusion. No wonder the public can’t figure out how an LAc’s education compares to that of other providers.

And here comes the First Professional Doctorate. With this new degree, my alma mater announces,

“[graduates] will be recognized as doctors, both professionally and publicly, and will have increased credibility and standing.”

If graduates with an FPD have increased credibility and standing, what has happened to the credibility and standing of graduates of Masters programs?

According to ACAOM’s gainful employment letter, licensure requirements just happen, and practice success is a simple matter of practitioner choice.

Really, though, the “alphabets” have played a significant role in the expansion of requirements and credential creep, and most of the schools do little to teach students how to make wise business choices.

If, as ACAOM wrote, the graduates of twenty years ago do so well, why have entry level requirements been increased so much? Why are grads struggling to pay off existing loans encouraged to return to school to maintain their credibility? Will the NCCAOM require an FPD to sit their exams? Will the alphabets encourage states to require it for licensure?

ACAOM/NCCAOM/CCAOM/AAAOM — if you represent us, defend the value of our degrees and credentials. Your “options” too often become a requirements.

Colleagues, did the gainful employment letter represent your views? If not, sign the petition. 129 people have, which means ACAOM etc. can still claim to represent 32,871 of us.

For additional information and analysis about educational costs and value, check out this from The New York Times and two posts from Dr. Phil Garrison

 

 

Loans for Acupuncture School

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It’s been too long. September brought a rush of obligations. And my post of X things (X to be replaced with a number when the list was completed) wrong with ACAOM’s gainful employment letter made it to 25 things by the time I got to the bottom of page 2 (of 7).

The gist of ACAOM’s letter — It’s not our fault. The cost of the education and the inability of many of our graduates to pay off their loans in a timely fashion has nothing to do with ACAOM, the schools, or CCAOM. It’s the fault of the system and the poor choices of our grads.

If you believe the schools and professional organizations should spend less time denying responsibility and more time taking responsibility, let them know by signing this petition.

My top 7 issues with the letter:

  • The authors absolve the schools of responsibility for the success or failure of their graduates. Where is their evidence that “the primary determinant for success in earnings is dependent upon the students who make their own personal choices….”  And doesn’t an effective education include helping students make choices that lead to success?
  • The organizations claim to represent the entire profession without justification.
  • With the exception of CCAOM, the participating organizations are operating far outside their missions. For example, NCCAOM’s job is to provide a means of credentialing practitioners to protect the public. Why are they weighing in on student loans?
  • The authors conflate the impact of the proposed gainful employment rules with the impact of student debt on establishing a practice. It is student debt that limits practice choices, not plans that would prevent excessive debt for ineffectual schools.
  • While the authors blithely refer to the “realistic” time frame to establish a health care practice, materials provided to prospective acupuncture students are silent on such matters.
  • Putting schools in charge of the metrics (like graduation rates) that determine loan availability is a classic fox guarding the hen-house scenario.
  • The salary figures reported in the letter are questionable at best and mostly irrelevant. Even if it were true that the median salary of practitioners with 20+ years of experience is $122,500, which is doubtful, an acupuncture education 20+ years ago was far less expensive and shorter. (Perhaps the lack of federally guaranteed student loans had something to do with that?) Graduates who could not establish a successful practice are not around twenty years later. What are grads supposed to do about their loans for the first twenty years of their professional life?

It’s requiring a good deal of self-restraint not to continue with my list, but enumerating the failings of ACAOM’s letter doesn’t create momentum for positive change. A petition signed by some of those 30,000 people the organizations claim to represent might create momentum. It isn’t easy to determine how best to lower costs and increase practitioner support. It will require careful analysis and consultation with experts. But if the powers don’t care enough to ask the questions, we’ll never approach the answers. Sign the petition.

(Before you say it isn’t possible, here is a school that has designed an affordable acupuncture program with a focus on creating successful practitioners.)

Who Speaks for You?

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ACAOM’s letter to the Department of Education regarding the proposed gainful employment rules begins —

On behalf of the Commissioners of the Accreditation Commission for Acupuncture & Oriental Medicine (ACAOM), and in partnership with the Council of Colleges of Acupuncture & Oriental Medicine (CCAOM), the National Certification Commission for Acupuncture & Oriental Medicine (NCCAOM) and the American Association of Acupuncture & Oriental Medicine (AAAOM), we write to offer comments…. Collectively, we represent over 33,000 students and graduate acupuncturists in the United States, and 56 colleges of Acupuncture & Oriental Medicine.

Are there 33,000 students and graduate acupuncturists? Where did they get that number? Do they represent me? Reading the rest of the ACAOM gainful employment letter confirmed it – their letter doesn’t reflect my position on the proposed rules, or on the state of the profession.

ACAOM‘s existence depends on the schools and a steady flow of students, CCAOM represents the schools, and the NCCAOM‘s income depends primarily upon new graduates taking credentialing exams.  Once these groups get their money the future of acupuncture school grads is of little consequence to them.

Of course they would make the case for maintaining the status quo, but they should not be telling the DOE that they represent me.

I’ve just sent this email to the ED of ACAOM (mark.mckenzie@acaom.org) with CC’s to the leaders of NCCAOM, CCAOM, and AAAOM (kwardcook@thenccaom.org; executivedirector@ccaom.comcastbiz.net; DonLeelac@gmail.com), and to ashley.higgins@ed.gov (of the DOE) and bduran@mpamedia.com (of Acupuncture Today) —

 

ACAOM’s May 23rd letter to the DOE regarding the proposed gainful employment rules includes this phrase —

“Collectively, we represent over 33,000 students and graduate acupuncturists in the United States.”

Neither ACAOM nor any of the other organizations mentioned represents me.

The only organization listed that even pretends to serve graduate acupuncturists is the AAAOM. Their professional and student membership is a thousand or so, optimistically, and they were not in partnership with you for this letter.

I am not surprised that organizations that profit off students and new graduates would write a self-serving letter avoiding responsibility for the number of acupuncturists struggling to pay off huge educational debt.

I am not even surprised that you would claim to represent me. But I am angry that you did so.

Unless you can provide documentation that you do represent 33,000 students and graduate acupuncturists please retract your statement to the Department of Education and make clear that you are speaking on behalf of your organization, which depends on schools and a steady flow of students to survive.

Speaking for myself,

Elaine Wolf Komarow, LAc

In coming weeks I’ll explore more of the distortions and spin in the ACAOM letter. But for now I hope you agree that standing by while these organizations claim to speak for us is a mistake.

Borrow my text or use your own, but, let ACAOM and the other alphabets know they don’t represent you — and make sure the Department of Education knows that too.

Acupuncture Careers

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ACAOM gainful employment — This deserves its own post.  I don’t have the head-space to write such a post at the moment.  I don’t even have the time to fully read and digest this document.  The little bit I can digest is making me sick to my stomach. I’m betting some of my readers would like to dig into this. I’d love to hear what you think.

Acupuncture and Insurance

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I keep hearing questions and complaints about insurance billing and acupuncture.  I don’t have an original post ready. This is adapted from an email exchange with some colleagues and thought it might be a good starting point for a conversation, despite the odd lack of context. But if you’ve been around for a while you can probably imagine what preceded it! (Then again, we should probably be out enjoying a holiday weekend rather than pondering our profession’s future.) —

“I am absolutely fine with practitioners pursuing all of the various business models that are available to us.  I want anyone who wants acupuncture to find a way to access it. Depending on both the practitioner and the patient, there may be certain models that are more appropriate or appealing than others.  Private room treatments at varying levels of cost with the money coming directly from the patient or indirectly via an insurance company, sliding scale models, in group or private settings, treatments as part of other medical care, I’m good with all of it.  I don’t believe that a patient’s willingness to make life changes is related to what they are paying for treatment. I don’t believe that lots of talk and time is necessary for people to benefit from treatment, though I believe it can have benefits.

“I do believe that lots of graduates come out of acupuncture programs with very little information about how to choose which model might be best for them or for the community in which they wish to work. I believe they often come out having been told some version of “if you build it they will come.” It makes me sad and angry when folks who invested so much in their education don’t have the business skills to make a go of it, especially when there are so many areas so underserved by LAcs.

“I don’t believe that fraud is necessary to make a living from an insurance based practice, and, I have seen many conversations about insurance billing for acupuncture that revolve around questionable practices. I certainly don’t think all practitioners engage in these practices, but some do. I also see practices that are by the book, but are still likely to have unconsidered consequences.  How many acupuncture treatments that are not billed to insurance involve three distinct sets of needle insertions, compared to those that are billed.  Does it take more sessions to treat back pain with acupuncture when the treatments are covered by insurance?  (Does the billing provider think of the treatments as being preventative once the back pain is in remission while the non-billing provider might not be thinking about back pain at all and instead pondering the client’s inability to relax even when on vacation?)  How do the answers to these questions impact data on the cost effectiveness of acupuncture?  As purchasers of health insurance, how do we feel if we think an MD is doing a more complicated procedure, with a higher reimbursement rate, than another, cheaper procedure that is equally effective?

“I did not mean to give the impression that offering a higher level of service when warranted will get a provider kicked out of a plan. However, if a provider’s patients consistently need a higher level of service that will get noticed by an insurance company. It may well be audited. And, it will be taken into account when the insurance company is deciding whether to continue to contract with a particular provider.  When you refer to this as an urban myth is it your position that insurance companies do not care whether a provider consistently bills for more services than other providers serving a similar population?”

Thoughts?

Talking about our Education

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“We have over (2000 hours, 4000 hours, 3 years, 4 years) of education and they want to do acupuncture with (a weekend, less than ten, 200 hours) of training!The public is in danger.”

“The (PT’s, Chiropractors, MD’s) doing acupuncture are significantly undertrained! If they want to do acupuncture they need to go to acupuncture school, or at least take (400, 500,1000) hours of training.”

It’s a no brainer, right? But ….

1) We are comparing our total professional education to additional post-professional-degree hours.

An MSAOM curriculum includes: Biochemistry, Introduction to Organic Chemistry, Anatomy and Physiology, Microbiology, Introduction to Western Pathology, and a Survey of Western Clinic Sciences (3 semesters). M.D.’s have already covered these classes in their education.

2) Does the aspect of “our” medicine they want to use require a full TCM education?

Is Tai Qi, Qi Gong, Introduction to Botany, 40 credits of herbal medicine, a semester of auricular acupuncture and 3 semesters of point location needed for a PT to safely use a needle to release a trigger point? (If you insist they learn all of that, won’t they then argue that they can also do auricular acupuncture and distal points?)

3) How well-educated are most acupuncture school graduates? How worthwhile was most of their time spent in school?

ACAOM standards were based on the programs that existed at the time credentials were being established. They were not based on a careful analysis of what was needed to train safe, effective, successful practitioners. Acupuncture related Facebook groups include posts asking about using moxa to turn breech babies, how to treat TMJ (no pulse, tongue, or presentation information provided), and recommendations for treating people undergoing chemotherapy. With our thousands of hours of training, shouldn’t we know the answers to these questions? (Or have a better source than Facebook for answers?)

4) Is there a correlation between the length of a program and the quality of the graduates? Were the early U.S. practitioners (many of whom had less than 1300 hours of training) harming the public?

It is an article of faith in the acupuncture community — our training of X hours is necessary for safety, and anything less is an affront and a danger. Yet a colleague recently wrote “I am at a medical acupuncture conference. Exceeding my expectation. The presenters know their stuff. Lots of depth…. I am going to find out about their training. Maybe they are a special group….what i am seeing here meets any high standards TCM conference…. Very surprised.”

The more (as defined by us) = better has done us no favors. The numbers we fight for are arbitrary. The argument is easily refuted by other providers. Adopting it within our profession has increased the business strangling debt-burden new grads carry. And created internal divisions which only further harm our growth. (How long before a state (or the NCCAOM) demands the FPD to become an LAc?)

Please, let’s let the knee-jerk “less is dangerous, more is better” argument go.

Acupuncture Education

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Between conversations on Facebook, dialogues on list serves, and college tours with my child, I’ve been thinking about acupuncture education a lot recently. There are several topics I plan to address in the next few weeks.  First off —

To those considering becoming an acupuncturist:

  • Talk to practitioners in your area. Do they recommend the school they attended? (Ask if they are employed by the school in any capacity to help evaluate their response.) Are most of their classmates are still in practice? How long did it take them to establish a successful practice? (How do they define success?) Are they easily able to make their student loan payments? Are they on an income-based repayment plan?
  • What percentage of the school’s graduates are still in practice 3/5/10 years out. The admissions office should be able to tell you this. They won’t be able to. Don’t be fooled – knowing the percentage of students passing the credentialing exams is not sufficient data to make a major investment. And make sure to ask what they mean by “still in practice.”  Here’s one school’s information about graduate success.
  • Will the education you receive at the school enable you to practice in the states you might want to practice in. Verify the information the schools provide, as many students have been misled. State requirements vary and are changing. Some only approve graduates of particular schools, some require additional education in certain subjects, some are very specific about whether the school has full ACAOM accreditation (ACAOM approved, or ACAOM candidate status won’t do it).
  • While schools may say that LAcs are employed in hospitals and other health care settings, know that this is a tiny percentage of practitioners. The vast majority of practitioners are establishing their own private practices upon graduation. What are the schools business classes like? Do they bring in marketing experts, accountants, lawyers, to give you guidance?
  • In a recent NCCAOM survey 62% of respondents reported a personal income, before taxes, of less than 65K.  Most “employment” situations for LAcs do not include sick time, paid vacation, family leave, health insurance, disability insurance, retirement savings plans, or payment for time spent on administrative tasks. If you are thinking oh, 30 clients/week at $80.00 = $124,000 — I’ll be rich, you should think again.Your ongoing expenses are likely to include fees for licensure, your NCCAOM credential, the CEU expenses to maintain that credential, malpractice insurance, liability insurance for your office, rent and utilities, marketing, supplies, taxes (of course) which are higher for the self-employed. If you intend to work within the insurance system know that while you may build a practice more quickly, the amount you receive as reimbursement can be changed at the whim of the insurance company. Expect that some amount of your time and money will be spent on additional services to help you track and pursue reimbursements.

Don’t get me wrong.  Many practitioners love what they do and wouldn’t trade it for anything.  This includes people who admit that they are struggling financially. I’m not saying don’t go to acupuncture school. I am saying do the research you would do before any other 80K (or more) purchase.

It’s Like Herding Cats

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It’s a common refrain about reaching consensus in the acupuncture profession. But why try to herd cats? I learned a long time ago that opening a can of tuna would bring kitty running.

If there were an attainable action that would:

  • Increase patient access to Licensed Acupuncturists,
  • Assist in national marketing for the profession,
  • Decrease educational costs and student debt,
  • Decrease licensing expenses,
  • Increase political power,
  • Expand professional opportunities, flexibility, and mobility, and,
  • Increase the value of your practice,

Would that be like tuna to a kitty?

(Whirrr of can opener)

Tuna for me = Identifying the least restrictive licensure requirements necessary to protect the public and create successful practitioners and working to establish that as a standard in all states.

Before panic ensues, consider some of the situations I’ve heard about in the past few years:

  • Highly experienced and qualified LAcs unable to obtain licensure, even in states where there are so few LAcs that the public has little choice but to get their acupuncture treatment from Chiropractors.
  • Practitioners who want to sell their practices but have a limited pool of buyers because of the unique licensure requirements in their state.
  • Practitioners travelling many, many hours in order to practice, or leaving the profession, because life has taken them to a state in which they can’t obtain a license.
  • Practitioners and students who have no interest in using herbs being required to spend tens of thousands of dollars and thousands of hours learning herbal medicine in order to obtain an acupuncture license.
  • Acupuncturists supporting discriminatory laws or regulations such that the only group of people in a state who can not practice herbal medicine are other Acupuncturists.
  • Practitioners having to maintain licenses in multiple states because changing regulations mean that if they give up a license they will be unable to obtain it in that state again.
  • Acupuncturists being unable to advance reasonable state or national legislation because restrictive practices keep practitioner numbers so low that political support is unavailable.
  • The profession being unable to effectively educate the public about their excellent education and credentials because those credentials vary so much from state to state.
  • Acupuncturists struggling to build a practice in overserved areas, but unable to obtain licensure in nearby underserved areas.
  • Acupuncture organizations fighting for inclusion in managed care and federal health programs, even though many states have too few LAcs to serve the population. (Demographic data can be found at these links: Acupuncture Today LAc Map, US Population, Physicians per State.)

The current system in which some states require graduation from particular schools, others have their own exams, and others have their own educational requirements does not serve us as a profession. The situation is getting worse, not better, as states like Florida increase their requirements. Yes, states have differing scopes. (Those who advocate for scope changes should be required to consider and advertise the impact the changes will have on licensure requirements.) Yes, it is in the interest of the public and the profession to insist that practitioners limit their practice to the tools and skills in which they have been trained. Additional, optional, training can always be required for those who wish to practice more advanced techniques or modalities. The least restrictive licensure requirements have shown themselves to be sufficient for safe practice.

Limited, standardized, licensure requirements would lower practitioner expenses, promote mobility, ease national marketing, and help the profession grow. It sounds great — as good as tuna smells to a cat. Does it make you make you want to come running? Many changes in licensure requirements could be made at the regulatory level and are within our reach. It does not depend on establishing reciprocity. One problem — the LAcs within a state have the power to make or block change, and, especially in restrictive states, the small group that set up the rules is often in power. Another problem — many LAcs don’t care about this until they are directly impacted.

This is a place where national coordination is needed. I hope the CSA sees that this is a place where they could make a positive difference. Let your state association know if you support a more standardized and simpler licensure environment. It should not require any herding.

Cat Food

Cat Food

 

 

Late March Update

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The weekend is winding down and I didn’t make it to my planned “The Biggest Problem Facing the Profession” post.  However, there is lots of news in Acu-World. Here are some items to keep you busy until I get back to the keyboard.

  • Want to support the profession in a positive way? You may have contributed to funds for inter-professional squabbles or federal legislation. That money hasn’t helped us in a lasting or tangible way. Support POCATech and you’ll be supporting an acupuncture school committed to providing an affordable education. How would your practice be different if you didn’t have educational debt? Check it out here! POCATech will help more people get acupuncture from acupuncturists — it is a win/win.
  • ACAOM is considering changes to the post-Graduate Doctoral Program and they want to hear from you.  The survey took me about 15 minutes, most of that for reading. Personally, I support a Doctoral track open to those who have an acupuncture-only education. There is a long history of practitioners choosing one specialty.  The movement in some states to insist on complete OM or Herbal training and credentialing is discriminatory against acupuncturists and expensive! It is important that we all weigh in, whether or not we plan to pursue a doctoral degree. Deadline for response — April 17th.
  • In January NCASI was celebrating a ruling they believed meant PT’s would not be able to do dry needling in Utah. In March, Utah HB 367, legislation which would add dry needling to PT scope of practice, went to the Governor’s desk for a signature. Shouldn’t be a surprise to anyone. Utah has fewer than 100 LAcs and about 4000 PT’s.
  • Likewise, “despite the warning” of AZSOMA, SB 1154, which would add dry needling to PT scope of practice, has passed the Senate and made it through two committees of the House. The votes have not been close.
  • Last, and maybe least, the AAAOM collapse continues.  Acupuncture Today printed part II of their article, now with updates. The AAAOM came out with a response (prior to the latest updates). Given the latest updates it probably isn’t worth the time to go through the AAAOM response. Suffice it to say, it contains plenty of spin and quite a few inaccuracies. Mostly, I continue to note that we’ve heard nothing from the AAAOM about who is currently in charge there. And, no practitioners really seem to care.

That should be enough to keep everyone busy.  Back soon, with “The Biggest Problem Facing the Profession.” (No, it isn’t Dry Needling.)