Editor’s Note: Article authored by Thomas Kouo, DAOM, LAc, Dipl. OM, CCAHM president; Benjamin W. Griffith II, DAc, LAc, Dipl. Ac., CCAHM vice president and chair, Legislative Advocacy Working Group; and Kristin Richeimer, CAE, CCAHM executive director.
In July 2025, Congress passed the "One Big Beautiful Bill Act," (OBBBA) a sweeping piece of legislation that, among many other provisions, directed the U.S. Department of Education (DOE) to convene a series of Negotiated Rulemaking Committees to reshape federal higher education policy. Most Americans were not focused on these aspects of the OBBBA. But, for Acupuncture and Herbal Medicine (AHM) schools, students, practitioners, and patients, these regulatory proceedings carry significant and immediate stakes. The Council of Colleges of Acupuncture and Herbal Medicine (CCAHM) and the AHM profession are responding with unprecedented unity.
This article focuses primarily on the first of those committees – RISE – and what it means for AHM education and the wider profession. We also provide a brief preview of two additional rulemaking committees, AHEAD and AIM, whose outcomes we will be monitoring closely in the months ahead.
What Is the RISE Committee?
The RISE (Reimagining and Improving Student Education) Committee was convened by the DOE under the authority of the new legislation to address student loan repayment and eligibility; the elimination of grad PLUS loans; to define which graduate programs qualify as "professional degree" programs for federal student loan purposes; and to set the borrowing limits in line with that designation.
Graduate students whose programs are designated as "professional degree" programs can access higher annual and lifetime federal loan limits. Graduate students in programs that do not carry the professional designation are capped at $20,500 per year, with a lifetime graduate loan maximum of $100,000.
For graduate programs that lead students through years of rigorous clinical training before they are even eligible to sit for national certification exams, that cap represents a potential barrier to entry that could meaningfully reduce the future AHM workforce.
The Problem of Omission
The law and existing federal regulation already define "professional degree" using a clear three-part test: a program must (1) satisfy the academic requirements for beginning practice in a given profession; (2) require a level of professional skill beyond that normally required for a bachelor's degree; and (3) lead to professional licensure that is generally required for practice.
AHM programs satisfy every element of that test. AHM graduates hold master's or doctoral degrees, complete extensive clinical hours, and must pass national board certification exams before obtaining licensure in the 47 states and the District of Columbia where the profession is regulated.
And yet the RISE proposed rule, released in early 2026, did not include AHM programs (along with many other healthcare and other degree programs) in its list of designated professional degree programs, despite the fact that multiple federal agencies have independently recognized AHM as a professional healthcare field. The Bureau of Labor Statistics assigned acupuncturists a dedicated Standard Occupational Classification (SOC) code, alongside physicians and dentists.
The Centers for Medicare and Medicaid Services covers acupuncture for chronic low back pain. The Department of Veterans Affairs employs licensed acupuncturists within its Whole Health model. The DOE itself recognizes the Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM) as the specialized accrediting agency for AHM programs.
AHM is not alone in this position. Physical therapists, occupational therapists, naturopathic physicians, certain nursing professions, certain therapists, and several other licensed health professions found themselves in similar situations under the RISE proposed rule. These are professions that clearly meet the functional definition of "professional degree" yet face uncertainty because the proposed list became exclusive. The breadth of affected professions has been a critical factor in building a credible, cross-sector advocacy response.
The Profession Responds Together
CCAHM and the AHM Coalition have been engaged in this rulemaking process since its earliest stages. Formal public comment was submitted in May 2025, prior to the passage of the OBBBA; again during the initial comment period in August 2025; and then again on March 2, 2026, the deadline for the comment period on the RISE Notice of Proposed Rulemaking.
Those comments laid out the legal, factual and policy case for including AHM programs in the professional degree designation. This comment period had significant response from all sectors, with over 125,000 total comments documented on the DOE public comment page.
CCAHM has also issued briefing memos to member schools, established communication and resources in its online collaboration portal, CCAHM Connect, and hosted monthly or bimonthly member meetings to ensure members are staying abreast of this rapidly evolving landscape.
In addition, CCAHM has worked closely with the founding partners of the AHM Coalition, ACAHM, ASA, and NCBAHM, to coordinate messaging and maximize the profession's collective impact. The AHM Coalition, which now includes the Acupuncture Herbal Vendors Coalition, held a profession-wide Town Hall Webinar on March 18, 2026, drawing participants from across the AHM community to review the issues and outline next steps. That webinar was the first in what is now a monthly series by the AHM Coalition on these topics. The next webinar takes place April 29, 2026. Readers may visit www.AHMCoalition.org for more information.
CCAHM has also joined the Advanced Professional Workforce Alliance (APWA), a broad multi-profession coalition that submitted coordinated comments to the DOE representing dozens of healthcare and medical education organizations.
"We are in an active rulemaking environment that requires both sustained attention and coordinated, credible engagement," said Benjamin W. Griffith II, DAc, LAc, Dipl. Ac., CCAHM vice president and chair of the Legislative Advocacy Working Group. "CCAHM is committed to ensuring that the department has the information it needs to recognize AHM programs appropriately, and we are grateful for the broad support that has emerged across the higher education and health profession communities during this process."
The CCAHM Strategic Plan and This Moment
The federal advocacy work described above reflects a deliberate strategic commitment that CCAHM's member schools endorsed when they approved the 2026-2028 CCAHM Strategic Plan in November 2025.
Among the plan's four top priorities for 2026 is to: “Advance Legislative Advocacy and Regulatory Engagement,” which has an explicit focus on protecting access to Title IV funding, developing a federal legislative agenda, and building CCAHM's capacity to respond rapidly to emerging regulatory or legislative action.
Equally relevant are priorities that strengthen and improve the identity of AHM schools and the profession, efforts to advance educational excellence through nationally aligned competencies, and developing a consortium approach for supplementary topics, as means to simultaneously provide excellence in instruction and address affordability.
"Our colleges are already doing outstanding work," said Thomas Kouo, DAOM, LAc, Dipl. OM, CCAHM president. "CCAHM supports thoughtful, common-sense regulation of higher education. Our concern with the RISE proposed rule is not an argument to maximize student debt but to provide parity. AHM programs meet every standard the law establishes for professional degree designation. At the same time, we are committed to working across the profession to ensure that AHM education is rigorous, affordable, and accessible, without compromising the clinical standards and patient safety outcomes our graduates are known for."
Looking Forward: AHEAD and AIM
Two additional DOE-negotiated rulemaking committees are underway and deserve the profession's attention:
The AHEAD Committee (Accountability in Higher Education and Access through Demand-driven Workforce Pell) is focused on Pell Grants, institutional accountability, earnings metrics, and financial responsibility standards for institutions participating in Title IV programs. The rulemaking sessions have concluded, and a proposed rule on the new earnings and accountability framework is anticipated in spring 2026.
According to CCAHM and other specialized health profession educators, one-size-fits-all earnings metrics may fail to account for the realities of AHM career trajectories, whereby graduates build income gradually through practice establishment, board certification and licensure in multiple states.
The AIM Committee (Accreditation, Innovation, and Modernization) will hold its first meeting mid-April. It involves federal standards for accreditation and institutional eligibility under Title IV. CCAHM and the AHM Coalition are monitoring developments closely.
Unifying and Staying Connected
The AHM profession in the U.S. has faced defining moments before. CCAHM, along with the AHM Coalition, is committed to leading with persistence, credibility and a unified voice.
The strength of this profession rests on well-prepared graduates, quality institutions and the trust that patients place in licensed AHM practitioners every day. Protecting and building on that strength, while ensuring education remains accessible and affordable, is the work ahead of us.
Unity doesn't require universal agreement. We must engage and debate the difficult questions together, then unite to support the future of this profession. We hope you will stay connected through your institutions of higher education, your state and national associations, the AHM Coalition's monthly webinars, and CCAHM.org. The future of AHM education is at a pivotal point, and we aim to ensure the profession is strong and protected.
Editor’s Note: For resources, links to public comment letters, and upcoming webinar registration, visit http://www.CCAHM.org and www.AHMCoalition.org. Look for updates as they are made available via AcupunctureToday.com, AT's social media pages and breaking news email.
