Future of Massage Schools and Title IV funding.

AMTA Federal Funding for Massage Schools at Risk Across the U.S.
“The new rule would eliminate the 150% rule, requiring all clock-hour programs to teach only the state-mandated minimum hours. For states where the minimum is under 600 hours, massage therapy schools and programs would be classified as “short-term programs”, making them only eligible for direct loans instead of Title IV Federal Financial Aid.”

ABMP Massage School Programs at Risk Across the Country
11/13/2023

“As of July 1, 2024, for a massage program to remain Title IV-eligible, program length must be exactly what the state requires. Schools cannot deviate from this number, or the entire program becomes ineligible for Title IV funding. In essence, the new rule amends the 150% rule to 100%.”

What Are My School’s Options?
Schools have multiple options:

If your state currently requires fewer than 600 education hours, encourage your state legislators and regulators to increase the required hours for licensure to the Entry Level Analysis Project (ELAP) recommendation of “approximately 625 hours” necessary to prepare students for entry into the profession. (While “approximately” has not been further defined, certainly somewhere in the range of 600 to 650 hours would qualify.) Currently, 23 states require fewer than 600 hours for licensure. We can work together to advocate for reasonable, defensible increases to meet the ELAP recommendations across the country. In doing so, massage programs will be able to maintain quality curriculum offerings, while states will align with massage profession standards.
You can begin the process to adjust your school’s program hours, so you are fully compliant by July 1, 2024. If you take this route, we recommend starting very soon because July 2024 is only eight months away. This is not a lot of time to complete the various steps needed to adjust program lengths. If your current program consists of more than 650 education hours, another downside is that your future graduates will have a less robust massage education.
You can decide not to make changes and pull your massage program out of Title IV funding.

ABMP 150%” Rule Advocacy Template 11/13/2023

ABMP Increasing Education Hours: A Trend on the Rise 03/26/2024 “

But ABMP and the states are trying to help students. Below are proposed and final changes from this legislative session across the country so far:

Tennessee introduced House Bill 1610 and Senate Bill 1588, which would increase education hours from 500 to 650.

Louisiana introduced Senate Bill 353, which would increase education hours from 500 to 625.

The Florida Board of Massage Therapy approved an increase of education hours from 500 to 650 at its March 20 board meeting.

The Nevada State Board of Massage Therapy proposed rule changes to increase education hours from 550 to 625.

AMTA Call to Action: Support H.R. 7810 Bill to Safeguard the Future of Massage Therapy Students

AFMTE provided the following emails:

Earlier today, the US Department of Education released updated guidance for clock hour programs and pending changes related to state minimum hours and Title IV eligibility, commonly referred to at the “150% Clock Hour Rule Change.” Here is a link to the updated guidance:

Updates on New Regulatory Provisions Related to Certification Procedures and Ability-to-Benefit | Knowledge Center

Although the Department is not delaying implementation of the new rules set to go into effect July 1, 2024, it is now providing an additional six months until January 1, 2025 where it will provide additional discretion against taking enforcement actions on schools. Per the new guidance:

“An institution can raise as a defense to an enforcement action that it faced challenges in meeting compliance due to reasons that are unique, time-specific, and outside the control of the institution. Some examples may include:

The inability to obtain approvals from States and/or accrediting agencies for changes in program length in order to comply with requirements under 34 CFR 668.14(b)(26);

The inability to obtain approvals for academic program changes to comply with the requirements related to licensure/certification under 34 CFR 668.14(b)(32);

The inability to obtain sufficient clarity from State licensing and certification entities about licensure and certification requirements;

The inability to access and use the Department’s systems.

The Department will seriously consider such challenges, in particular prior to January 1, 2025, when determining whether to seek enforcement of these provisions. The Department retains the discretion to base its determination on the totality of the circumstances and the specific facts of each case.

In accordance with the Department’s general practice, the Department encourages institutions to document, prior to July 1, 2024, the circumstances that prevent their compliance with any requirement by the regulations’ effective date. The Department will review such documentation prior to taking any enforcement action related to these provisions.

Email 2

This email is going to anybody who was registered for our webinar last month on the “150% Clock Hour Rule Change.”

One of the open questions we raised on the webinar that US Department of Education had not yet answered at the time, was finally answered today through a communication the Department sent US Congressman Lloyd Smucker (PA). Below is the question asked of the Department, and their response in red below.

Question to the US Department of Education

Currently if a school starts a new short-term program (under 600 hours), the program must run for one year without any financial aid and prove it can achieve a 70% graduation rate and 70% job placement rate.  Our question: We asked the department how programs that will now be forced under 600 hours due to their new rule will be treated.  Will those programs have to run for a year without financial aid until they prove 70/70?

Answer back from the US Department of Education

“This will be explained in a forthcoming Dear Colleague Letter, but the answer is “no,” programs that must be reduced to under 600 hours as a result of these regulations will not be required to provide completion and placement rates in order to remain Title IV-eligible for the 2024-25 award year.

The school will be expected to provide those rates as they normally would for all subsequent years.”

Thanks,

Aaron Shenck

Executive Director – MAACS

www.maacs.us