May 8, 2025
Linda E. McMahon, Secretary
U.S. Department of Education
Via regulations.gov
RE: Docket ID No. ED-2025-OPE-0016
Dear Secretary McMahon:
On behalf of the Acupuncture and Herbal Medicine Coalition, a collaborative alliance of major national acupuncture organizations including the Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM), the American Society of Acupuncturists (ASA), the Council of Colleges of Acupuncture and Herbal Medicine (CCAHM), and the National Certification Commission of Acupuncture and Oriental Medicine (NCCAOM), we appreciate the opportunity to provide feedback on the Department’s negotiated rulemaking process addressing Title IV regulations.
Our organizations oversee the accreditation, certification, and professional development of thousands of licensed acupuncturists and herbal medicine practitioners, as well as a majority of the institutions that educate them. Many of these institutions participate in Title IV federal student aid programs and serve students who rely on Public Service Loan Forgiveness (PSLF) and income-driven repayment (IDR) plans, including Pay As You Earn (PAYE) and Income-Contingent Repayment (ICR), to make their education affordable.