Dr. Rebecca Groebner DAc, LAc – 2026

The Acupuncture Crisis and What You Can Do About It

Introduction

Oregon's acupuncture training pipeline is collapsing. Within the next two to three years, most acupuncture schools in the United States will lose access to federal student loans and close. When that happens, Oregon will have no way to train new licensed acupuncturists.

This is not speculation. It is already underway. The Oregon College of Oriental Medicine closed in 2024. At least ten accredited programs have closed nationwide since 2019. The federal government has begun measuring whether graduate programs produce earnings sufficient to repay student debt, and acupuncture programs are failing that test more dramatically than any other graduate field in the country.

But, this is fixable at the state level, and Oregon has the legal authority to act right now. I’ve also written a White Paper for the Oregon Association of Acupuncturists that details some action that can be taken now.

The requirement that Oregon acupuncturists graduate from nationally accredited schools is not written into Oregon law. It exists in administrative rules that the Oregon Medical Board created and can change. Oregon can establish its own program approval system (the same way Oregon's massage therapy board has operated successfully for decades) and preserve the capacity to license acupuncturists regardless of what happens nationally.

This guide explains what's happening, why Oregon can act independently, and what needs to happen for that to work. If you care about acupuncture existing in Oregon ten years from now, this is the most important professional issue you will face in your career.

The window to act is narrow. But the authority exists, the path is clear, and the timeline works, if Oregon acupuncturists organize and move quickly.

This document serves as a call to action piece built from the longer piece I wrote.

Part 1: The Crisis in Plain Terms

What's Happening Right Now

Since 2019, at least ten acupuncture schools have closed, including Southwest Acupuncture College in Boulder (2023), AOMA in Austin (2024), Emperor's College in Santa Monica (2025), and Oregon College of Oriental Medicine in Portland (2024). These aren't isolated failures. They are symptoms of a structural collapse that is accelerating nationwide.

The collapse is driven by federal accountability. In January 2026, the U.S. Department of Education released program-level earnings data under new rules created by the "One Big Beautiful Bill Act" (OBBBA). These rules evaluate whether graduate programs produce earnings sufficient to justify the federal student loans used to pay for them through the Earnings Premium Test (EPT). Programs are tested four years after graduation: if graduates don't earn more than typical bachelor's-degree holders, the program fails.

When the federal data came out, acupuncture and East Asian medicine programs ranked as the single worst-performing category of any graduate field in the country. Approximately 98% of students in these programs attend schools that fail the federal earnings test. This isn't a judgment about whether acupuncture works clinically: it's a measurement of whether graduates earn enough to repay their loans. And the data is clear: they don't.

Here's why: most acupuncture programs require 3.5 to 4 years of full-time study. Tuition alone runs $80,000–$150,000, but students also borrow for rent, food, transportation, and healthcare throughout training. By the time they graduate, total debt routinely reaches $250,000–$300,000. Yet graduate earnings in the first 5–10 years (when loan repayment matters most) typically fall in the $35,000–$55,000 range. The math doesn't work. It never did.

What Happens Next

Under OBBBA, programs that fail the earnings test once must issue formal warnings to all current and prospective students. Programs that fail twice within three years lose access to federal loans entirely. The first warnings will be issued in July 2027, just sixteen months from now.

When schools receive federal warnings, enrollment collapses. Students avoid programs labeled "low financial value." Small private schools cannot survive even a single weak admissions cycle. And when programs fail the test twice, Title IV loans disappear, removing 70–95% of the revenue that keeps schools operating. Without federal loans, schools cannot pay faculty, run clinics, or meet accreditation standards. Closure becomes unavoidable.

Early federal earnings analyses already show nearly all acupuncture programs will trigger warnings in July 2027. For most, warnings will begin the collapse. Loan loss will finish it. Within two to three years, the majority of acupuncture schools in the United States will close.

However, the crisis is accelerating faster than many realize. Federal loan caps take effect in summer 2026, limiting annual borrowing to $20,500, approximately half of what most programs currently charge. Many schools will face enrollment collapse before OBBBA warnings even arrive in July 2027. The timeline is compressed: financial pressure in 2026, warnings in 2027, complete loss of federal funding by 2028-2029.

Why This Matters for Oregon

Oregon requires that acupuncturists graduate from schools accredited by the Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM) and pass exams administered by the National Certification Board for Acupuncture and Herbal Medicine (NCBAHM). These are the national organizations that accredit programs and test competency.

Oregon has no public acupuncture programs. Community colleges and public universities cannot create affordable programs because they will not meet ACAHM's graduate-level requirements. The state is entirely dependent on expensive, private ACAHM-accredited schools for its training pipeline.

When those schools lose federal funding and close, Oregon will have no pathway left to train new licensed acupuncturists. Existing practitioners keep their licenses, but no new graduates enter the field. Over the next decade, the profession shrinks through attrition, retirement, and relocation.

But the crisis is not just that schools are closing. The crisis is also that the training these schools provided was never aligned with what Oregon's healthcare systems actually need. Graduates were trained for solo private practice in a healthcare landscape increasingly organized around team-based care. They lack the medical literacy (medication review, lab interpretation, red-flag recognition, referral protocols) and interdisciplinary communication skills that hospitals, FQHCs, tribal health centers, and behavioral health programs require. Even where workforce demand might exist, current training makes graduates unhireable for larger health systems (that also have more power to fight for expanded insurance reimbursements, scope and many of the other challenges acupuncturists have attempted to change in their own).

Oregon faces a dual crisis: no training pipeline, and training that was never designed to produce employable healthcare workers in the first place.

Part 2: Why Oregon Has the Power to Fix This

The Key Legal Distinction: Statute vs. Rule

Most acupuncturists don't understand how Oregon licensing actually works. This distinction is critical, because it determines what Oregon can do without waiting for the Legislature.

Oregon Revised Statute (ORS) 677.759 is the law that governs acupuncture licensure. It says the Oregon Medical Board has authority to "examine the qualifications of an applicant and determine who shall be authorized to practice acupuncture" and directs the Board to "adopt rules" governing licensure.

Oregon Administrative Rule (OAR) 847-070-0016 is where the specific requirements live. This rule says applicants must graduate from ACAHM-accredited programs and pass NCBAHM exams.

Here's what matters: ACAHM and NCBAHM requirements are not in Oregon statute. They are in administrative rules that the Medical Board created over time.

Changing a statute requires legislative action: bill sponsor, committee hearings, floor votes, Governor's signature. That process takes 18–24 months minimum and requires navigating the full political process.

Changing administrative rules requires Oregon Medical Board rulemaking: petition or Board-initiated proposal, public notice, comment period, Board deliberation, and vote. That process can be done in a much shorter time and proceeds on the Oregon Medical Board's administrative calendar, not the Legislature's biennial schedule.

Oregon's dependency on ACAHM and NCBAHM is structural, but it is not legally inevitable. The Oregon Medical Board retains the delegated authority to define alternative pathways that meet competency and public protection standards. Oregon can act independently to preserve its licensure capacity when the national system collapses.

The Oregon Massage Board Model

Oregon already has a working example of state-level professional oversight that does not depend exclusively on national accreditation. The Oregon Board of Massage Therapists operates under a framework where the state defines curriculum standards and approves programs directly.

Massage therapy programs don't need approval from a single national accreditor to produce licensed practitioners in Oregon. The Board evaluates programs based on Oregon-defined competency standards, and programs that meet those standards can operate. This model has worked successfully for decades without safety issues.

Acupuncture can follow the same path. The Oregon Medical Board can establish competency standards for acupuncture training, approve programs that meet those standards (whether housed in community colleges, public universities, or private institutions), and recognize multiple examination pathways (including but not limited to the NCBAHM exam). Oregon can preserve the capacity to license acupuncturists regardless of what happens to ACAHM-accredited schools.

This is not experimental. It is how Oregon already regulates massage therapy. The authority exists. The precedent exists. The mechanism exists.

Utah's 2026 Legislative Action

In January 2026, Utah introduced H.B. 202 (2026), demonstrating that states are already moving to establish independent licensure pathways. The bill creates an alternate route to licensure that doesn't require NCCAOM/NCBAHM certification.

Under Utah's proposed alternate pathway, applicants can qualify by completing a two-year curriculum (rather than the typical 3.5-4 year ACAHM-accredited programs) that includes:

450 hours of East Asian medical theory, diagnosis, and treatment
75 hours of clinical observation
500 hours of supervised clinical internship
225 hours of biomedical clinical sciences
100 hours of counseling, communication, ethics, and practice management

This totals approximately 1,350 hours (significantly less than ACAHM's typical 3,000+ hour requirement) while maintaining core competency standards.

Utah's action confirms what Oregon can do: states have the authority to define their own competency-based pathways without depending on national accreditation. Utah is doing this through legislation; Oregon can accomplish the same goal through administrative rulemaking, which is faster and doesn't require legislative action.

Part 3: What Needs to Happen

The Strategy: Request Rule Change Through OMB Rulemaking

The viable path forward is to petition the Oregon Medical Board to amend OAR 847-070-0016. This is an administrative process that can begin immediately and does not require legislative action.

What the rule change would accomplish:

Allow the Oregon Medical Board to approve educational programs that meet state-defined competency standards, regardless of ACAHM accreditation status
Recognize multiple examination pathways, including NCBAHM (preserving the current route), California's state exam (CALE), Board-developed Oregon assessments, or other validated competency exams
Define what graduates must actually demonstrate: safe needling technique, point location accuracy, red-flag recognition and appropriate referral, documentation proficiency, basic medication literacy, lab and imaging interpretation sufficient for safe practice, and demonstrated clinical judgment in supervised settings
Allow community colleges and public universities to create affordable acupuncture training programs that meet Board-defined standards

This represents a shift from proxy-based regulation ("ACAHM-approved = competent") to direct competency-based oversight where the Board evaluates outcomes rather than outsourcing that determination to a single national accreditor.

How to Make the Case

Oregon can petition for rule reform based on regulatory independence alone: the state has legitimate authority to preserve its licensure capacity when national systems fail. This argument is legally sound and does not require extensive preparation.

However, the strongest case combines regulatory independence with employer documentation. When healthcare systems document unmet workforce needs, evidence can be given to the Oregon Medical Board to show that rule reform serves public benefit, not just professional survival. Employer input also identifies the specific competencies that training programs should emphasize, ensuring graduates are prepared for actual employment opportunities.

Employer documentation involves structured conversations with potential employers: rural hospitals facing severe provider shortages, Federally Qualified Health Centers needing affordable frontline care for chronic pain and mental health, tribal health centers seeking culturally responsive care models, behavioral health programs and county public health departments addressing the opioid crisis and chronic disease prevention.

The key questions are straightforward: What health needs are currently unmet? What prevents you from hiring acupuncturists now (cost, training mismatch, lack of medical literacy, or insufficient supply)? If Oregon created affordable training pathways emphasizing medical literacy and team-based care skills, would you hire graduates? What roles would they fill, and what competencies would make them employable?

The goal is to secure brief written statements documenting workforce gaps and willingness to hire if barriers were removed. These statements transform the petition from "preserve the profession" to "address documented public health needs,” a distinction that can make a big difference in whether the Oregon Medical Board acts.

The Rulemaking Process and Timeline

Administrative rulemaking follows a defined sequence:

Phase 1: Drafting the Petition

Assemble core group (practitioners, former educators, legal expertise)
Draft proposed rule language (can model on Oregon massage therapy rules: ORS 687.051, OAR 334-010-0046)
Prepare justification memo citing regulatory independence, public protection rationale, and well-defined fiscal feasibility
Conduct potential employer outreach

Phase 2: Petition Submission and Public Notice

Submit formal petition to Oregon Medical Board requesting rulemaking
OMB reviews petition and determines whether to initiate rulemaking
If approved, OMB publishes notice of proposed rulemaking
60-90 day public comment period begins

Phase 3: Public Comment and Board Deliberation (3-6 months)

Stakeholders submit written comments (this is where employer statements strengthen the case)
OMB staff likely prepare fiscal impact statements
Acupuncture Advisory Committee reviews proposal
Full Board deliberates and votes

Phase 4: Rule Adoption and Implementation

If approved, new rules take effect
Programs can begin seeking Board approval under revised standards

If petition drafting begins in early 2026, submission could occur by summer 2026, with rule changes potentially adopted by spring 2027, before July 2027 OBBBA warnings trigger catastrophic enrollment collapse. The timeline is tight but viable.

What the Board Must Consider

The Oregon Medical Board's mandate is public protection. Any rule reform must demonstrate competent and safe providers, standards to protect patients from unqualified practitioners, administrative feasibility and fiscal responsibility.

Oregon's current system externalizes oversight costs to ACAHM and NCBAHM. Rule reform must address how OMB will manage program approval without building expensive new bureaucracy.

A viable approach uses attestation combined with selective audit (common across allied health professions): programs attest to meeting defined competencies, the Board audits a small percentage on a rotating schedule, oversight scales with existing capacity, and application fees offset review costs. Programs must be housed in regionally accredited institutions or legally authorized Oregon entities (ensuring institutional quality), while OMB evaluates acupuncture-specific competencies.

For examinations, the simplest approach retains NCBAHM as an accepted route while adding California's CALE as an alternative and has language leaving open an option for a Board approved exam local to Oregon. The immediate objective is preserving the licensure pipeline, not building a new testing bureaucracy.

Part 4: What This Means for You

If You're a Current Licensed Acupuncturist

Your license is safe. Rule reform does not change existing licenses or affect practitioners already licensed in Oregon.

But if you care about acupuncture existing in Oregon in ten years, this matters. Without new graduates entering the field, the profession shrinks through attrition, retirement, and relocation. Clinics close when practitioners retire and no one is available to take them over. Communities lose access to care.

If you have built a practice, trained students, want to hire employees in the future or have otherwise or invested significant time in this medicine, the question is whether you're willing to participate in preserving a viable future for it in Oregon.

If You Know Someone Considering Acupuncture School

Tell them to wait. Current ACAHM-accredited programs who are also receiving federal aid will likely lose federal funding within two years. Students who enroll now face the risk that their program closes mid-degree, leaving them with debt and no credential.

If Oregon successfully establishes state-level program approval, new affordable training pathways could open by 2027-2028. Community college programs designed within federal loan caps could cost $30,000–$50,000 total for a full program (not $250,000). Public university pathways could offer in-state tuition rates and employer partnerships that lead to actual jobs.

The best advice right now is to wait and see whether Oregon creates viable alternatives before committing to expensive private programs that may not survive.

If You Work With Other Healthcare Providers

Those relationships matter for employer documentation. Do you know someone who works at an FQHC? A tribal health center? A rural hospital? A behavioral health program? Introductions and connections help build the case that licensed acupuncturists could fill real workforce gaps: if training were aligned with employer needs.

If you're willing to facilitate conversations between people organizing the rulemaking petition and potential employers in your network, that's valuable. Employer documentation strengthens the petition significantly, but it requires practitioners willing to make connections and have conversations.

What This Is NOT

This proposal is not:

Fighting to reverse dry needling or 5NP legislation
Trying to rescue failing ACAHM-accredited schools
Asking for scope expansion or new practice authority
Defending ACAHM, NCBAHM, or national organizations
Creating a fully tiered credential system (that would require legislation)

This proposal is:

Preserving Oregon's legal capacity to license acupuncturists
Creating affordable training pathways within federal loan caps
Aligning training with actual healthcare workforce needs
Ensuring point-based medicine remains available in Oregon

This is about Oregon taking responsibility for its own regulatory future rather than depending on a failing national system.

Part 5: How You Can Help

Immediate Actions Anyone Can Take

1. Understand the issue (you just started by reading this document and can get even more by going here. Follow the Debt by Natural Causes Substack.

2. Talk to other acupuncturists

Forward this document to colleagues
Have conversations about whether Oregon should pursue rule reform
Gauge whether there's willingness to organize

3. Connect people who can help

Know educators with regulatory expertise? Connect them to organizing efforts
Know lawyers familiar with Oregon administrative law? Same
Know practitioners willing to do employer outreach? Same
Have relationships with potential employers (FQHCs, tribal health, hospitals)? Those connections matter

4. Watch for updates

If a core organizing group forms, they'll need community support
Rulemaking involves public comment periods where practitioner voices matter
The Board needs to hear that Oregon acupuncturists want this

If a Core Organizing Group Forms

A successful rulemaking petition requires a small committed group willing to:

Draft petition language and justification memo
Coordinate employer outreach and interview
Prepare materials for public comment period
Show up when the Oregon Medical Board deliberates
Work in a unified way to represent diverse perspectives (immigrant providers, NUNM alumni, OCOM alumni, community acupuncture practitioners, etc.)

This work is not glamorous. It involves understanding Oregon administrative procedures, working with people who may have different training backgrounds or practice philosophies, and sustained effort over 12-18 months. But it's the work that determines whether Oregon preserves the capacity to license acupuncturists.

What Unity Looks Like

Oregon's acupuncture community includes immigrant practitioners from many different countries graduates of different programs, practitioners trained in different lineages, and people with different practice models and philosophies. Some emphasize EAM integration with modern medicine, others practice classical Chinese medicine. Some focus on community acupuncture. Some work in dual-degree naturopathic practices.

For rulemaking to succeed, these different "camps" must find shared ground on basic competency standards. The Oregon Medical Board will not be persuaded by fragmented arguments rooted in pedagogical or political identity. If acupuncturists cannot agree on what "competent practice" looks like in general terms, the Board has no reason to believe that state-level program approval would serve public protection.

Unity doesn't mean everyone agrees on everything. It means agreeing that preserving Oregon's capacity to license acupuncturists matters more than defending particular training philosophies and being willing to work together toward that shared goal.

The Bottom Line

This is doable. The legal authority exists. The precedent exists (Oregon massage board). The timeline works if we start now. But only if Oregon acupuncturists are willing to organize and do the work.

No one is coming to save us. ACAHM is not reforming. The AHM Coalition is suing the federal government, not addressing structural problems. National organizations have spent a decade defending the system rather than fixing it.

If Oregon acupuncturists want a future for this profession in this state, we have to build it ourselves: at the state level, using the authority Oregon already has.

The question isn't whether this CAN be done. The question is whether Oregon acupuncturists will organize the effort to make it happen.

What Happens If We Do Nothing

If Oregon acupuncturists do not make the time and do the uncomfortable work of organizing to petition the Oregon Medical Board for rule reform:

July 2027: Federal warnings will be issued to most acupuncture programs
2027-2028: Enrollment collapses, schools begin closing
2028-2029: Programs fail earnings test twice, lose federal loans, remaining schools close
2030: No ACAHM-accredited programs in operation
2030-2040: Oregon's existing licensed practitioners retire, relocate, or leave the profession while other provider types practice point based therapies within their paradigms (which might be great, it will just look very different than it does now)
2040: Licensed acupuncture in Oregon effectively ceases to exist

This is not catastrophizing. This is the predictable outcome of a system built on unsustainable debt, isolated governance, and no employer integration, now measured by federal accountability that makes the economic mismatch impossible to ignore.

But there is an alternative. Oregon can act independently. The authority exists. The path is clear. The timeline works.

If you want acupuncture to exist in Oregon in ten years, this is the work.

Next Steps

If you are interested in participating in organizing a rulemaking petition, or if you have expertise that could help (legal, regulatory, employer connections, former educator experience), please reach out:

rebecca.groebner@gmail.com

The immediate need is to determine whether there is sufficient interest and capacity among Oregon acupuncturists to move forward. If a core group forms, the work can begin. If not, this document serves as a record of what was possible and what we chose not to do.

The window is narrow. But it's open. What happens next depends entirely on whether Oregon acupuncturists decide this future is worth organizing for.

About the Author

Dr. Rebecca Groebner, DAc, LAc, is an acupuncturist licensed and practicing in Oregon and also licensed in Washington State. She is a graduate of the National University of Natural Medicine and the Pacific College of Health Sciences, a former faculty member at both NUNM and the Oregon College of Oriental Medicine, and a past board member of the Oregon Association of Acupuncturists. She currently serves as Clinical Training and Program Manager with the Acupuncture Relief Project in Nepal, where acupuncture is used within an integrated primary-care model in a low-resource health system.

Dr. Groebner has worked in private practice, community-based settings, and academic institutions. She is also a borrower navigating the federal Borrower Defense process and has supported other graduates seeking relief. This document reflects her analysis as a clinician, educator, and participant in the system she examines.