Oregon State
The Structural Constraint
Oregon’s current rule requires ACAHM accreditation through two mechanisms: naming it directly in OAR 847-070-0016(1)(a)(A), and requiring the NCBAHM examination, which itself requires ACAHM graduation for eligibility. The AWA and Oregon Association of Acupuncture supports retaining this pathway. The proposal does not eliminate it.
However, relying on ACAHM as the sole pathway carries institutional risk. IRS Form 990 data shows ACAHM posted operating deficits in 6 of the last 10 years, with net assets down 11% since 2015 and a cash collapse in 2024. Each school closure costs ACAHM tens of thousands of dollars in annualized revenue while the AHEAD framework is projected to trigger multiple closures simultaneously. CNME, the naturopathic accreditor, received a 12-0 denial recommendation from NACIQI in March 2026 under strikingly similar conditions. A parallel, Board-approved pathway is not a vote of no confidence in ACAHM. It is a prudent insurance policy.
The Proposed Solution
ORS 677.785(3) gives the Acupuncture Advisory Committee (AAC) authority to recommend standards of didactic and clinical education but the AAC has never independently defined these. ORS 677.785(4) requires an NCCA-accredited examination, not NCBAHM specifically. The proposed revision to OAR 847-070-0016 uses both of these existing statutory authorities to create a parallel, Board-approved pathway to licensure: preserving the existing ACAHM → NCBAHM → licensure route entirely while also enabling innovation.
Under the proposed parallel pathway, a program may achieve Board approval through institutional accreditation from any U.S. Department of Education-recognized accrediting body, or through direct Board approval based on the competency standards established in our proposed companion rule OAR 847-070-[XXXX]. This direct Board approval option creates a meaningful possibility for small, community-based programs, like the existing Oregon College of Community Acupuncture, to seek Board approval directly, redirecting those financial resources toward OMB approval of program quality. How programs structure their curricula, credentials, and financing to meet the competency floor is left to institutional innovation.
Why Now?
The enforcement of the RISE rule begins in 2026. The AHEAD Framework earning premium test begins in summer 2027 with Title IV loss projected by 2028. NUNM enrollment is already declining. The window to establish an alternative pathway before the pipeline fails is narrow and rulemaking takes time. Acupuncture is a Medicaid-covered, evidence-supported primary care tool Oregon will need more of as it moves toward universal coverage. The Board has the statutory authority to act. This proposal asks it to use that authority.