11/13/2023
ABMP has created an advocacy template you can use to send to your state senators and representatives. Although the US Department of Education’s (ED) decision to amend the 150% rule is final, hearing from as many school owners, operators, and instructors may make them reconsider the changes. Please use this template as a guideline—add your opinions and experiences to make your letter more personal and impactful.
To Senator(s) [Name(s)] and Representative(s) [Name(s)],
I am a [massage therapist/school owner/operator/instructor] in [city/state]. My massage therapy school, [school name], has been in operation for [number of years]. [School name], its students, curriculum, and graduates will be severely impacted by the final US Department of Education (ED) rules that amend the “150% rule” for Title IV funding. I ask that you support the “Smucker Amendment” in the Labor, Health and Human Services, and Education Appropriations Bill for the following reasons.
Graduates
The path to earning a state massage license begins with graduating from a state-approved massage therapy program followed by demonstrating knowledge and competence by passing the Massage & Bodywork Licensing Exam (MBLEx). MBLEx pass rates show the optimal number of massage therapy educational hours taken to pass that exam is between 600–650 hours. Twenty-three of the 47 licensed states currently require fewer than 600 education hours. Forcing schools to teach the bare minimum will jeopardize a student’s likelihood of passing the MBLEx and then achieving future success as a massage therapist.
Public Safety
Most states’ current minimum-education-hour requirements started as a recommendation from lawmakers. Likely this number was a product of diverse individual opinions—though little actual research —at the time regulations were adopted. By contrast, the Entry Level Analysis Project (ELAP)—a two-year (2012–2013) thorough research project embraced by all seven national massage organizations—identified the knowledge and skills a massage therapy student should have to work safely and competently with clients.
The ELAP report determined that approximately 625 hours are necessary to prepare students for entry into the profession. As mentioned above, 23 states currently require fewer than 600 instructional hours. The question is obvious: Will these minimum state requirements ensure sufficient education to equip massage therapists with the requisite knowledge and clinical practice to provide services safely and competently to clients? The consensus among massage schools is “No.” That is why the average core massage program length is approximately 700 hours. Eliminating the 150% rule jeopardizes public safety and lessens the odds of a student’s success post-graduation.
Schools and Curriculum
In addition to lower tuition rates for reduced hours, there is a possibility we will see enrollment rates go down, and this will directly correlate to financial strain to keep school doors open and massage therapy programs available. The new rule will allow schools a paltry eight months to restructure curriculum to comply with a state’s minimum educational standards. This is an extraordinarily short timeline to reduce and reframe educational hours, not to mention transition instructors from the old to the new curriculum so they have a level of comfort.
Many schools must obtain reauthorization to reduce their education program hours, which is a costly process on its own and takes longer than eight months to complete. This short fuse will force some schools to close. Program-hour changes require separate, sequential approvals from state-authorizing agencies, accreditors, and the ED. Each of these steps typically takes several months and each step must be completed in a specified order. In addition, if several thousand programs in the country (embracing all professions covered by this regulation), must institute this process simultaneously, the approval entities will be backlogged, and the approval process will take longer than normal.
Student Enrollment
Students who enter career training programs are making an investment in their future. They are also taking a bit of a gamble. Spending money on a post-secondary education is a large financial commitment, one that often involves going into debt. Absent the 150% standard, student enrollment will drop significantly because students will have challenges trying to secure their own funding. Amending the 150% rule and forcing schools to teach only the state minimum-hour requirement will set many students up for failure—they will not receive the education they need to succeed in the profession. This may impact a potential student’s decision in the enrollment process.
It is imperative that the amendment of the 150% rule be reversed or rendered unenforceable. If not, no victor will emerge July 1, 2024. Students, instructors, schools, and the public will suffer. The entire massage therapy profession will experience disorder. Eliminating funding for programs and causing barriers to entry is the antithesis of the ED’s mission. Forcing states to lower educational hours will not “promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access.” Please consider the unintended consequences this rule will have on the massage profession as a whole by supporting the “Smucker Amendment” in the Labor, Health and Human Services, and Education Appropriations Bill.
Sincerely,
[Your name
Title
Contact information]