Our View on DOE Regulations

The following statement was submitted to the United States Department of Education and sent to all massage and bodywork schools in the U.S. this week.

ABMP Perspective on Proposed U.S. Department of Education

Vocational Education Rule Changes

Integrity. Acting ethically. Honestly describing the services we provide. Value. Motivated, talented staff focused on delivering ABMP’s expectmore mission statement translates to improved quality and breadth of member services each year. The ultimate goals are member success in their chosen form of professional practice, client satisfaction, and contributions that move the profession forward. Common sense. Focus on defining and achieving core objectives. Eschew protocol and unthinking habit. Substitute thoughtful behavioral guidelines and encouragement to “use one’s bean” for unproductive bureaucratic instincts and requirements. Fairness. Objectively consider each person’s and institution’s situation uniquely. Avoid type casting. These core values and behaviors guide ABMP’s relationships with our members, staff colleagues, and appreciated additional work partners. We believe similar values appropriately should inform the conduct and performance of massage therapy schools. While the graduate of any training program must marshal initiative and persistence to find specific gainful employment, such an individual has a right to expect that such training, successfully completed, should well prepare him or her to perform as a professional in that chosen field. Schools that advertise, “Enroll in our program, complete the curriculum, and then secure a job as a professional ______ earning over $_____ a year,” have an ethical obligation to assure that result actually occurs with great frequency. We have no empathy for training institutions that steer students to accept loans for training in professions those institutions know full well do not generally pay well enough for the student to have any realistic chance to cover basic living expenses and repay student loans. We encourage reputable massage schools (and there are hundreds that meet this test) to speak up in support of these fundamental viewpoints. The integrity and value perspectives above are relevant to school behaviors. On these basic philosophical matters, Secretary of Education Arne Duncan and Senator Tom Harkin are correct. Rotten apples in the education barrel? Unfortunately, there are more than a few. The stories that have made headlines in recent months have not specifically focused on massage therapy schools, but rather for-profit vocational educators in general. However, there are massage programs in that rotten apple barrel as well. Too many of the 40,000+ massage graduates this year will not receive good value for their massage education. Too many schools seem more interested in signing people up than in honestly assessing a prospective enrollee’s likelihood of being successful, first by graduating, and second by securing enough massage work to support herself or himself and meet financial obligations. We encourage each massage school owner, proprietor, and director to look in the ethical mirror. Do you feel comfortable about what you promise, what you deliver, and whether that deliverable prepares a student to secure gainful employment? If the answer is “No,” then we challenge you to alter what you promise, what you teach, or what you charge to make the equation work. If your answer is “Yes,” then speak up, individually or through your school association or accrediting agency affiliations to put pressure on lackluster institutions to change their behaviors and claims. If we don’t collectively take responsibility for keeping our profession clean, then we shouldn’t be surprised when the government proposes to clean up abuses, particularly at a time when federal loans and loan guarantees finance an increasingly larger share of massage education. Every massage school has a stake in ensuring that all massage schools behave ethically. We’ve all heard the phrase, “He who pays (or guarantees) the bills sets the rules.” Government has a valid desire that federal vocational student loans finance productive training activities, but solutions must not go overboard. Tightening of requirements must not extend beyond what common sense or fairness dictate. ABMP appreciates that responsible massage school owners understandably are apprehensive about the specifics of prospective new federal student loan regulations. Perhaps most worrisome is the fact that schools cannot control whether graduates pursue a driven, income-maximizing approach to massage therapy practice or elect a more avocational path, yet those choices by graduates could dictate whether a school remains eligible for Title IV funding for future students. To be effective in voicing specific regulatory concerns, rather than just stating blanket opposition to any alterations of current requirements, massage school owners would be wise to embrace the fundamental premise that vocational training should meet a market relevance/value test. Our advice is to concentrate on shaping regulatory specifics to massage therapy practice realities instead of railing against “government interference” generally. The element of the proposed Department of Education regulations garnering the most attention is the proposed definition of “gainful employment” (in reality: a) debt repayment rates, and b) the ratio of a graduate’s debt service to their post-graduate income) that would be used as one criterion for program Title IV eligibility. The underlying concept—forestalling students taking on huge levels of debt for training in a vocation that realistically won’t permit earning enough to be able to repay that debt—has merit, but the proposed metrics seem ill-fitting for a profession like massage therapy in which most choose to work part-time and a significant proportion of graduates choose self-employment. ABMP’s most recent comprehensive member survey revealed a median of 10 hours of hands-on work weekly. Electing to build a private practice, while ultimately satisfying along several dimensions, can be a long road to success. Annual earnings in the $5,000–$15,000 range are far from uncommon in the first year or two along this route. Partly this has to do with the inherent challenges of building a professional practice one client at a time, partly to the fact that 45% of massage therapists report holding a second part-time job. Many like the combination of limited hours of physically demanding massage work as a counterweight to another job calling instead for more traditional “desk” work. If numerous graduates select private practice rather than performing massage for an employer, those collective choices could make it extremely difficult for a massage school to meet proposed required ratios of debt service to income. In the case of “gainful employment” analysis for massage practitioners, it is vital that final regulations consider income from all sources for massage school graduates rather than just comparing massage school debts to subsequent massage earnings. Among other elements of the proposed rules that have caught the attention of massage therapy educators, one in particular rises to the fore—the proposed regulation (§§ 600.2) that would establish for the first time a standard formula to convert clock hours to credit hours. The net effect of this proposal could be to reduce the number of credit hours for which massage therapy classroom hours typically count. Many massage therapy instructional hours involve hands-on engagement, by contrast to predominant passive listening to a lecturer in some other professions’ vocational training. This massage training difference deserves consideration as conversion formulas are adopted. This hour definition proposal merits further study and monitoring; arbitrarily reducing the generally accepted current number of clock hours in the conversion ratio could serve to increase the number of actual hours a program encompasses. Such a result would work against the Department of Education’s goal of bringing program costs more in line with graduates’ potential earnings. The cost of a typical education in massage and bodywork has increased more than 60% in the past dozen years; during that same period of time, the typical earnings of a massage therapist have changed little. A massage career should not be measured solely by a tax return; however, the economic equation outlining “investment in training” in relationship to “prospective enhanced earnings potential” must be such that a student’s time spent learning the profession promises a potential return that justifies the time and monetary commitment. In certain respects, the highly detailed formulas in the proposed regulations suggest that a group of government analysts were locked into a windowless room for months with instructions to come up with a metric that would tighten the screws, blithely unaware that the U.S. economy was headed for a persistently high rate of unemployment and under-employment. Even graduates of some of the most prestigious private colleges find themselves straining to secure a job—any job. Client hours for existing massage therapists on average appear to be down 15% from a couple years ago. It will hardly prove surprising that many new massage school graduates likely will struggle to build a practice in 2011 and 2012. It would be a shame to see student loans dry up for large segments of massage training institutions and for students from disadvantaged backgrounds because of general economic malaise. At a minimum, a more gradual phase-in of regulations may be in order. The massage education community comes in many different sizes and shapes. ABMP values its relationships with massage schools, and has a long history of serving many different types of schools. It is not in our general nature to criticize those schools. For example, five years ago we observed a diminution in the average experience and skill level of massage teachers. It wasn’t that top-notch veteran teachers suddenly lost their mojo, rather that the extraordinary enrollment growth created a need to hire many new teachers. Instead of criticizing, ABMP set about on an aggressive course of creating new resource materials and providing instructor training—most of those at no charge to schools or instructors. We desire a vibrant massage education community in which healthy competition spurs all schools to strive for continuous improvement in the quality of their offerings. The foundation of such commerce should be a “fair trade” ethic, one in which prospective students can make informed career and education choices based upon presented information that is accurate and comprehensive. We welcome feedback to these views. Les Sweeney, President Bob Benson, Chairman Associated Bodywork & Massage Professionals


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