Public Comment Opportunity | CCAHM

Public Comment Opportunity: Urgent Action Needed

Protect access to Acupuncture and Herbal Medicine education by submitting a public comment before March 2, 2026.

Overview

Docket ID: ED-2025-OPE-0944
Comment Deadline: March 2, 2026

The U.S. Department of Education has issued a proposed rule through the RISE (Reimagining and Improving Student Education) Committee negotiated rulemaking process defining which graduate programs qualify as “professional degree programs” for federal student loan limits.

As drafted, the rule does not explicitly include licensure-leading Acupuncture and Herbal Medicine (AHM) programs, despite these programs being accredited, graduate-level, and required for licensure in a regulated healthcare profession. If AHM programs are not explicitly included in the definition of “professional degree program,” students in these programs would face significantly lower federal loan limits, creating substantial financial barriers to entry.

Below are focused comment templates tailored for different audiences. Commenters may use these as a starting point and are encouraged to personalize them.

Submitting a comment takes only a few minutes but can have a lasting impact on the future of AHM education and patient access to care. You are able to allow your information (name, etc.) to display publicly or display anonymously. Thank you for your support!

Contact admin@ccahm.org for more information.

Why This Matters

Accredited AHM programs are rigorous clinical programs that prepare students for national certification and state licensure. Acupuncture is recognized at the federal level, including Medicare (CMS) coverage for chronic low back pain and incorporation into the Department of Veterans Affairs Whole Health model. Excluding these programs from “professional degree” status would:

Eliminate Grad PLUS loan access
Lower federal borrowing limits
Create financial barriers for students
Shrink the acupuncture workforce
Reduce patient access to nonpharmacologic care

This outcome would be inconsistent with federal workforce goals related to healthcare access, opioid reduction, and integrative care.

DOE is required to consider public comments when finalizing proposed rules. Well-reasoned, profession-wide comments help establish an administrative record that can influence the final rule and inform future policy decisions.

Templates for Public Comment

Institutions | Faculty | Administrators

[Insert 1-3 sentences about your background, expertise and experience, including any personal/professional details about federal loans and how they impacted your education and career and impacts on the community you serve. Personalize the message below as necessary.]
        As an administrator/faculty member at an accredited Acupuncture and Herbal Medicine institution, I am concerned that the Department’s proposed rule would exclude AHM programs from the definition of “professional degree programs.” Our programs are rigorous, post-baccalaureate clinical programs that prepare graduates for national certification and state licensure in a regulated healthcare profession.
        AHM programs require extensive didactic and supervised clinical training in biomedical sciences, diagnosis, patient assessment, and treatment planning. These levels of education and licensure standards are essential to maintaining a high standard of care and ensuring patient safety. Graduates must meet accreditation standards recognized by the U.S. Department of Education and qualify for licensure in nearly every state where the profession is regulated. Excluding these programs from professional degree status would significantly reduce access to federal student loans for otherwise qualified students.
        Approximately 30,000 licensed acupuncturists currently practice in the United States.
        This proposed exclusion would have direct consequences for healthcare access and workforce stability. Licensed acupuncturists provide evidence-based, nonpharmacologic care for pain, chronic disease, and mental health conditions. These services align with federal priorities related to opioid reduction, whole-person care, and access in underserved communities.
        I respectfully urge the Department to explicitly include accredited, licensure-leading Acupuncture and Herbal Medicine programs in the definition of “professional degree programs.” Federal higher education policy should strengthen healthcare workforce pipelines, not create unintended barriers for established, licensed professions.
        Sincerely,
        [Your Full Name]
        [City, State]

Practitioners | Medical Professionals

[Insert 1-3 sentences about your background, expertise and experience, including any personal details about federal loans and how they impacted your education and career. Personalize the message below as necessary.]
        As a licensed acupuncturist, I am concerned that the Department’s proposed rule would exclude Acupuncture and Herbal Medicine programs from the definition of “professional degree programs.” This change would limit future students’ access to federal student loans and ultimately reduce patient access to care.
        Approximately 30,000 licensed acupuncturists currently practice in the United States, and demand for nonpharmacologic care continues to grow. My profession requires graduate-level education, national certification, and state licensure. Many practitioners, myself included, serve patients seeking nonpharmacologic options for pain management, stress-related conditions, and chronic illness. These levels of education and licensure standards are essential to maintaining a high standard of care and ensuring patient safety and these services are increasingly relied upon by patients who need alternatives to medication-based care.
        Without access to professional-level federal loan limits, many qualified students will be unable to pursue this education. This will shrink the workforce at a time when demand for nonpharmacologic and integrative care is growing.
        I respectfully request that the Department revise the proposed rule to explicitly include accredited Acupuncture and Herbal Medicine programs that lead to licensure as professional degree programs, ensuring continued access to education and care for the communities we serve.
        Sincerely,
        [Your Full Name]
        [City, State]

Students

[Insert 1-3 sentences about your background, expertise and experience, including any personal details about federal loans and how they impacted your education and career. Personalize the message below as necessary.]
        As a current/prospective student in Acupuncture and Herbal Medicine, I am concerned that the Department’s proposed rule would exclude my program from the definition of a professional degree. This would limit access to federal student loans and create a significant financial barrier for students pursuing licensure in a regulated healthcare profession.
        AHM programs require years of graduate-level study and extensive supervised clinical training. Federal student loans provide essential stability for students like me as we complete this rigorous education.  These levels of education and licensure standards are essential to maintaining a high standard of care and ensuring patient safety. Without access to the professional loan limit, many students will be forced to delay, abandon, or never pursue this career.
        Restricting access to student loans for licensure-leading AHM programs will reduce the future healthcare workforce and limit patient access to safe, effective, nonpharmacologic care. I respectfully ask the Department to include accredited Acupuncture and Herbal Medicine programs in the definition of professional degree programs.
        Sincerely,
        [Your Full Name]
        [City, State]

Patients | Supporters

[Insert 1-3 sentences about your background, expertise and experience. Personalize the message below as necessary.]
        As a patient/family member/supporter of acupuncture care, I am concerned that the Department’s proposed rule would exclude Acupuncture and Herbal Medicine programs from the definition of professional degree programs. My community relies on licensed acupuncturists for nonpharmacologic care, particularly for pain management and chronic conditions. This level of education is critical for standards of care and patient safety.
        I have personally experienced the value of acupuncture as part of my healthcare. If students cannot access the financial support needed to complete licensure-required education, fewer practitioners will be available to serve patients like me.
        At a time when healthcare systems are seeking effective, non-drug approaches to pain and whole-person care, federal policy should support, not restrict, the education of licensed acupuncture professionals. I respectfully request that the Department explicitly include accredited Acupuncture and Herbal Medicine programs as professional degree programs.
        Sincerely,
        [Your Full Name]
        [City, State]

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