American Alliance for Professional Acupuncture Safety (AAPAS)
1767 12th St, # 248, Hood River Or 97031, United States
www.aapas.org | info@aapas.org
Member Organizations:
American TCM Society (ATCMS) • American Association of Chinese Medicine and Acupuncture (AACMA) • United Alliance of NYS Licensed Acupuncturists (UANYSLA) • California Acupuncturist United Association (CAUA) • Florida Acupuncture Association (FAA) • National Federation of Chinese TCM Organizations (NFCTCMO)
AAPAS Joint Opposition to All Three ACAHM Draft Program Revision Proposals
The American Alliance for Professional Acupuncture Safety (AAPAS) is a national alliance of the following professional organizations representing licensed acupuncturists, Traditional Chinese Medicine practitioners, educators, researchers, and students across the United States:
- American TCM Society (ATCMS)
- American Association of Chinese Medicine and Acupuncture (AACMA)
- United Alliance of NYS Licensed Acupuncturists (UANYSLA)
- Florida Acupuncture Association (FAA)
- National Federation of Chinese TCM Organizations (NFCTCMO)
Speaking as one unified voice, AAPAS respectfully and collectively opposes all three draft proposals published by ACAHM on May 29, 2026.
We recognize that ACAHM is responding to genuine pressures — federal loan policy changes, the AHEAD earnings framework, and real concerns about program affordability and accessibility. These pressures are real, and AAPAS does not dismiss them. However, we believe that all three proposals respond to a short-term financial crisis by making a long-term professional sacrifice — one that the acupuncture and Traditional Chinese Medicine profession will not be able to undo.
— Better fewer and better than many of inferior quality.
This principle guides every position in this statement.
I. Why AAPAS Opposes All Three Proposals
Proposal 1 — Reducing the MAc from 1,905 to 1,590 hours
This proposal cuts biomedical and clinical science education by 30% — from 450 to 315 hours. ACAHM’s own document acknowledges this reduction ‘may be a difficult position to defend without evidence that the reduction does not impair the clinical competencies that support scope-of-practice defense.’ Modern acupuncture is not simply needle insertion at traditional points — it demands the seamless integration of classical theory and contemporary biomedical knowledge. ‘Stomach 36’ is not just a classical point; it is the tibialis anterior muscle, adjacent to the deep peroneal nerve and anterior tibial artery — safe needling requires knowing exactly what lies beneath the skin. A patient presenting with fatigue and joint pain may fit a TCM pattern of Kidney Yang Deficiency, or they may have early lupus requiring immediate referral. Explaining that acupuncture ‘moves Qi’ does not communicate with a cardiologist or insurance medical director — explaining that it modulates the autonomic nervous system and activates endogenous opioid pathways does. Biomedical literacy is not a translation exercise; it is what makes acupuncturists safe, credible, and competitive in modern integrated healthcare settings.
At a time when acupuncturists are actively defending their scope of practice against dry needling practitioners who claim superior anatomical training, cutting our biomedical hours hands them that argument on a silver platter. The affordability problem this proposal seeks to address does not require reducing educational content — it requires reforming delivery models, reducing administrative overhead, and developing articulation agreements so that students who completed anatomy and physiology at the undergraduate level are not required to repeat it in graduate school. Better training, not less training, is what earns acupuncture its rightful place in the modern healthcare system. AAPAS firmly opposes Proposal 1.
Proposal 2 — A Bachelor of Science in Acupuncture as an independent entry-level program
This is the most concerning of the three proposals. ACAHM’s own document frankly acknowledges the central threat: there are no independent, portal-of-entry healthcare professions in the American healthcare system that require only bachelor’s-level education for professional licensure. Creating one for acupuncture does not make our profession more competitive — it makes acupuncture the outlier. It invites payers, hospitals, and policymakers to reclassify licensed acupuncturists as auxiliary personnel rather than independent clinicians. ACAHM’s own document further acknowledges that Medicare generally does not recognize standalone bachelor’s-level clinicians as independent billing providers. AAPAS cannot support a proposal that ACAHM itself identifies as potentially jeopardizing independent provider status, hospital integration, and reimbursement parity.
Proposal 3 — An applied bachelor’s plus a shortened master’s
This is the most carefully constructed of the three proposals, and AAPAS understands its intent. However, AAPAS remains opposed. A one-year master’s program built on only 735 hours of instruction — of which only 45 hours are biomedical and clinical sciences — does not constitute meaningful graduate-level clinical education. It is a credentialing mechanism, not a training program. The graduate degree label would be preserved while the graduate-level educational substance would not. Over time, this will erode rather than protect the professional standing of acupuncture and Traditional Chinese Medicine in the United States.
II. The Direction Must Be Forward, Not Backward
Every healthcare profession that has achieved Medicare recognition, hospital integration, and insurance reimbursement parity has done so by raising educational standards over time, not by lowering them:
- Physical Therapy: Bachelor’s → Master’s → Doctor of Physical Therapy (DPT)
- Pharmacy: Bachelor’s → Doctor of Pharmacy (PharmD)
- Audiology: Master’s → Doctor of Audiology (AuD)
- Nursing: RN → MSN → Doctor of Nursing Practice (DNP)
Acupuncture and Traditional Chinese Medicine has already developed the Doctor of Acupuncture (DAc), the Doctor of Acupuncture and Oriental Medicine (DAOM), and the Doctor of Acupuncture and Chinese Herbal Medicine (DAcCHM). These programs exist. They demonstrate that our profession has the educational infrastructure and the clinical depth to train at the doctoral level.
AAPAS’s position is that doctoral-level education must be the profession’s trajectory — not an option for the few, but the recognized standard for the future of acupuncture and Traditional Chinese Medicine in America. The current financial crisis must not become the moment that permanently redirects the profession away from that trajectory.
III. What AAPAS Proposes Instead
AAPAS does not oppose reform. We oppose reform that diminishes professional standing. The following alternatives address affordability and accessibility without lowering the educational floor:
Pursue doctoral-level CMS and Medicare recognition.
The strongest long-term response to the AHEAD earnings benchmark is not to reduce training hours — it is to increase practitioner earnings by securing full Medicare provider recognition for licensed acupuncturists at the doctoral level. AAPAS member organizations are prepared to support and participate in that national advocacy effort.
Develop competency-based articulation pathways.
Allow students who complete relevant undergraduate coursework in anatomy, physiology, biology, chemistry, and psychology to apply those credits toward ACAHM program requirements — reducing program length and cost without reducing educational depth or professional standards.
Reform program delivery models.
Hybrid, online, and accelerated delivery formats can reduce the cost and time of graduate-level education without reducing its content. ACAHM should set standards for delivery innovation rather than standards for content reduction.
Advocate jointly for targeted federal relief.
The AHEAD framework’s earnings benchmark was not designed with independent-practice licensed healthcare professions in mind. ACAHM and AAPAS member organizations should jointly petition the Department of Education for a benchmark adjustment for licensed independent healthcare practitioners — the same argument being advanced by naturopathic, chiropractic, and other professions facing identical pressures.
Explore a supervised Licensed Acupuncture Assistant (LAcA) tier.
If the goal is expanding the acupuncture workforce in underserved communities, AAPAS supports exploring a supervised practice credential for applied bachelor’s graduates, modeled on the Physical Therapist Assistant and Physician Assistant frameworks. A LAcA would practice under a supervising LAc and would not hold independent licensure. This expands workforce access without redefining the independent licensure standard our profession has built over five decades.
IV. AAPAS Requests
AAPAS respectfully encourages ACAHM to consider the following steps:
- Decline to advance any of the three draft proposals to formal public comment in their current form.
- Commission an independent analysis of the Medicare recognition, malpractice insurability, interstate licensure portability, and long-term earnings implications of each proposed credential change before any proposal moves forward.
- Convene a broadly representative stakeholder working group — including AAPAS and its member organizations — focused specifically on doctoral-level advancement as the profession’s long-term strategic response.
- Engage directly with the Department of Education, CMS, and Congressional health committees on targeted relief for independent-practice licensed healthcare professions disproportionately affected by the AHEAD earnings benchmark.
- Open a formal dialogue with AAPAS and its member organizations before any proposal affecting the professional degree standard is advanced.
V. Closing
The acupuncture and Traditional Chinese Medicine profession stands at a defining inflection point. The decisions made in the next twelve months — by ACAHM, by state licensing boards, and by national professional organizations — will shape what our profession is in the American healthcare system for the next fifty years.
AAPAS believes that future must be built on higher standards, deeper training, stronger healthcare integration, and doctoral-level recognition. Not on a response to financial pressure that permanently narrows what acupuncture and Traditional Chinese Medicine can become in America.
Better fewer and better. The professional integrity of acupuncture and TCM is not a cost that can be cut.
Respectfully Submitted on Behalf of AAPAS and Its Member Organizations
Bin Cai, PhD, RN, FNP, L.Ac.
President
American Alliance for Professional Acupuncture Safety (AAPAS)
Shaobai Wang, Ph.D. L.Ac
President
American TCM Society (ATCMS)
Ying Li L.Ac
President
American Association of Chinese Medicine and Acupuncture (AACMA)
Gang Shi L.Ac
President
United Alliance of NYS Licensed Acupuncturists (UANYSLA)
Chunyan Wang Ph.D. L.Ac
President
Florida Acupuncture Association (FAA)
Yuyan Wang L.Ac
President
National Federation of Chinese TCM Organizations (NFCTCMO)
