AIMC Closure: Part 2

This is a continuation of writing about the AIMC closure. Nothing I say on this Substack is ever legal or financial advice. ;-)

What can we do as a community to to help reduce the harm to the students who will become the future of this profession? As I wrote about earlier this year, debt incurred from student loans has been proven to have negative effects on cardiovascular health and increases the likelihood of mood disorders. Because a private loan doesn’t allow access to the relief available with federal loans, the stresses of the debt are riskier. It’s ironic that so many schools for healers have gotten to place where they are this bad for our health.

Despite my own harrowing debt, I love being an acupuncturist and I know that for many of you, this feels like your life’s purpose. I know it can feel urgent. Even so, try to learn from those of us who are in such a bad position. Take a deep breath and a step back. Remember that your path will unfold as it is meant to unfold. Have some faith that if this is the work you are meant to do, it will happen. The path is not always linear and a winding route may mean less financial (and physical and emotional) harm for your future self. I wouldn’t wish my debt on any of you. Please don’t do this to yourself.

Let’s start brainstorming some options for students here? This is by no means a complete list of everything you can do. Feel free to post in comments if you’re seeing more options for folks or if I’ve gotten something wrong here. As students you’re on the ground and that perspective is really important.

Inside the One Big Beautiful Bill (OBBB), if a student had a Direct Unsubsidized Loan or Grad PLUS loan disbursed before July 1, 2026, for their current program, they should be able to keep borrowing under the old rules (no annual cap, full cost of attendance via Grad PLUS) for up to 3 more academic years, or until the end of the program, whichever comes first.

BUT to do this, the student must stay continuously enrolled in the same program at the same institution.

The general rule regarding transferring seems to be pretty strict: transferring institutions appears to break the provision, even under a formal teach-out. As more acupuncture schools close we will get more clear on this…but we are in uncharted territory right now.

Megan Walter of the National Association of Student Financial Aid Administrators notes that, “Even if you stay in the same program, you lose your legacy exemption if you change institutions,” and “Withdrawals or unapproved leaves of absence can also result in forfeiture of legacy status.”

As far as what’s in the“Reimagining and Improving Student Education Federal Student Loan Program Final Regulations” (RISE) Rule itself:

• “Transferring Between Schools Within Same Program of Study” if a student transfers to a different institution (even within the same program of study) that counts as a new program of study, and the student is not eligible for the interim exception (legacy Grad PLUS/loan-limit protection).

• The seems to be one exception: There’s a separate provision, “Campus Reaffiliation Interruption,” covering mergers, ownership changes, or campus reaffiliations. In that scenario, if a student’s institution changes hands but the student stays enrolled at that same institution, they keep legacy eligibility. (I don’t see how AIMC transferring students to VUIM, Oikos, ACCHS, Five Branches, Yo San, or East-West would qualify here because those are separate institutions with their own Office of Postsecondary Education Identification (OPEID) numbers, so it’s not AIMC restructuring under new ownership.)

While the DOE could evaluate this situation and make its own determination, we are in a time crunch here and so let’s try and avoid magical thinking and take this rule and Megan Walter at their word. If a student switches institutions, they fall out of legacy status and into the new rules: capped Direct Unsubsidized Loans ($20,500/yr, $100K aggregate), no Grad PLUS.

As you know, these new borrowing limits won’t work for the mainstream, status quo, (aka “normie accredited”) expensive educational structure that ACAHM/NCBAHM have setup for modern US acupuncture education. If you’re not already in deep, think about getting out while you still can and wait until some better solutions come around. (A few creative schools have already shown that they can provide an educational model outside of the mainstream box). If you are in deep…well, most of the mainstream schools are recommending private loans to finish, and we know those are going to suck. But if you have some way of making those payments immediately upon graduation without the need for IBR, this might work for you. Maybe you are one of the few people who can access a W2 job right after graduation or you have a previous career that you can fall back on to pay off the loans while slowly building a practice?

VUIM has a signed teach-out. If you’re in the later years of your training, it’s the clearest path forward in terms of ease of transferring because AIMC and VUIM already set that up. But, it’s not Cali Acu Board (CAB) approved and you’re probably going to have to take out private loans to make it work. If you are going to use private loans you may as well consider all your options here and pick the school that works best for you, not for AIMC/VUIM.

If you’re early on, consider taking the closed school discharge and pivoting to an adjacent license type (see below).

This is the best option. Finish the term, graduate, and you can retain aid eligibility (if AIMC gets their extension) since it’s the same institution. Get in, get out and get ‘er done.

Here are some options:

This is a one of the better options in this bad situation. Eventually, debt from AIMC is wiped, but it takes a long time to process (I watched this slow painful process for folks after OCOM closed and AIMC won’t officially be closed till 2027.), You’d be starting over if you return to the field later since credits can’t be used once discharged. BUT, it does offer the blessing of having debt wiped and you can take some time to breathe and figure out next steps, AND…

If you take the discharge, you could pivot to training for an adjacent license like NP, PA, PT, OT, MSW, MPH, RDN or mental health counseling. None of these require the MCAT, they build on what you already know, have stronger income stability and job availability, and there’s a real chance acupuncture add-on certifications become more available as this field sorts itself out. Or you can go to acupuncture school later and pay as you go because you have a decent paying job in healthcare to support yourself. You can use what you already learned to offer more holistic care for folks than they might otherwise receive, you can make a decent living to pay off the debt, AND/BUT…

Keep an eye out for loan caps around these provider types, who is being added to the “professional list,” and make sure to check the salary and don’t borrow over what you can reasonably make in one year.

You would definitely lose the legacy provision with a non-teach out transfer (which seems unlikely anyway) but still have access to standard federal Direct Unsubsidized Loans, (capped at $20,500/year and $100,000 lifetime) until the AHEAD earnings premium metric kicks in after a few years (and most acupuncture schools are likely to lose all access to Title IV because of low graduate income). If you’re going to graduate by 2028 or maybe 2029 and the school has enough money to keep going you might be ok. If you need to go to school after 2028, I would think long and hard about a career change or look at a modular program where you can pay as you go.

If you decide on a transfer with the use of loans, the amounts you’ll receive under the new caps won’t be enough to cover the program so you’ll have to work enough or borrow private loans.

Please do your research here because several other ACAHM schools have low Federal Responsibility Composite (FRC) scores and/or are currently on heightened cash monitoring, which makes them more likely to fail/close. Avoid schools with recent (2024, 2025) FRC scores lower than 1.5.

• Check the independent audits for the school on Propublica for recent FRC scores. What is listed on the studentaid.gov site only goes to 2023!

• Check the Flourish database for pass/fail projections on AHEAD earnings metric

• Search clema.ai for aggregated data for educational institutions

From the data we are seeing, it’s hard to imagine an acupuncture school continuing access to Title IV money once two AHEAD earning premium metrics tests go through, unless it’s a new program that doesn’t have four years of graduate data accumulated yet.

Ask these schools what their teach-out plans are.

This seems like the sketchiest option of all. This school isn’t even accredited, though it has CAB approval, so maybe that makes it more likely. The accreditor, ACAHM, is up for review by the government soon though, so they are likely to be extra discerning about accreditation at this moment.

There are no federal loans at all here (Oikos doesn’t participate in Title IV), meaning no income-driven repayment option and no public service loan forgiveness. Yet, for some reason, they are magically offering students half off tuition and they’ll finance a loan with the terms set by Oikos, not by a regulated lender. (I hope you’re seeing all the red flags here and I don’t have the explicitly point everything out?)

Alright, what have I missed? I am hearing AIMC will know more next week…so maybe some of this will change.

Until then, I’m one person with my own opinions here, doing this without pay and mostly reacting to a situation that keeps shifting. Please don’t treat anything here as the final word. Lean on your own advisors, and give yourself real space to think this through without panic driving the decision. If this work is truly yours to do, there will be a way to get there, even if the path isn’t the one you first imagined.

I feel for you all. This situation sucks in the biggest way.

Have some faith in yourself and in the larger Universe. Ask the ancestors. Take your time. If you’re feeling rushed into something, try and find a way to step back, breathe and listen to your heart. It won’t steer you wrong, but it does need your patience and often needs us to set the ego aside so that we can truly hear our purpose clearly as it beats.

Sending you love, bex