Massage Education and the Gainful Employment Rule

Discover the shift about to hit massage schools nationwide as we unpack the consequences of the new federal gainful employment rule with Lance Hostetter, Director of Government Relations for ABMP. In July 2024, a federal program to protect students from predatory education practices could have major consequences for massage therapy schools. We explore the fine line between consumer safety and the integrity of massage therapy education. The conversation takes a turn as we probe into the controversial shift from the 150% rule to a mere 100%, bringing up concerns about the potential dilution of massage training quality.

ABMP: Massage School Programs at Risk Across the Country
NASFAA: 2023 Gainful Employment

Chapters

• 2:29 What is Gainful Employment?
• 4:12 The 150% Rule
• 6:06 ELAP
• 12:38 ABMP on Gainful Employment

Transcript

Lance Hostetter: 0:35

So the impact will be great and it's something. I think it's around 350 school programs that could be impacted by this nationwide.

Corey Rivera: 0:46

And how many schools do we have total?

Lance Hostetter: 0:48

Somewhere in the ballpark of 1,000. So we're talking over a third of programs will be impacted by this policy.

Corey Rivera: 0:56

That's a lot.

Lance Hostetter: 0:57

That is a lot.

Corey Rivera: 0:58

It's an outrageous number. Yeah, a quick note before we get going. Abmp is a sponsor of this podcast and we're aware of what it might look like to have them featured on this show. You should know that never, not once, has ABMP suggested content or tried to censor our work at Healwell. We reached out to them about this topic because it's so important and we wanted to hear what they had to say. If anyone from any member of the Coalition of National Massage Organizations would like to speak with us on or off this show, we would be happy to talk with you. Please send us an email at podcastheowellorg.

Corey Rivera: 1:40

Welcome to the Rub, a podcast about massage therapy. We say the quiet things loud, have a hunger for change and a desire to connect the dots. I'm your host, Corey Rivera, and today we're talking about the US federal law that has been put into place to protect students but threatens the future of massage schools and the massage profession itself. Schools that teach massage take many forms. They can be part of a large, established franchise, but most of them are privately owned and operated by people who love massage so much or are willing to take on the immense amount of work required to run a school this summer, in July of 2024, a new federal rule, known as gainful employment, will take effect and it might shut down a third of existing massage schools. Let's back up a second.

Corey Rivera: 2:31

In September of 2023, the federal government finalized the gainful employment rule. It's 700 pages of regulation designed to protect students from predatory education practices. The rule affects all for-profit colleges and all public and private non-degree granting programs, more commonly known as trade schools. The US Secretary of Education, miguel Cardona, said we are fixing a broken system and making sure that students know before they take out loans, when college programs have a history of leaving graduates with high debts, low earnings and poor career prospects. The gainful employment program estimates it will protect 700,000 students every year who would have enrolled in programs that didn't live up to their promises.

Corey Rivera: 3:14

The rule has two big requirements. The first is called the debt to earnings ratio. It says that after graduations, students must make enough money to pay off their student loans. The second requirement is that at least half of the graduates must make more money than the average person in their state, who only has a high school diploma. If programs fail these requirements, they will lose the ability to accept federal loans, also known as Title IV funding Programs who lose Title IV funding can still take private loans, but anyone who's ever dealt with a private loan company knows that they aren't much better than your local loan shark. The cement shoes of a private company might be financial instead of physical, but they'll sink you to the bottom of the river just as quickly, because even I don't want to read 700 pages of government documents. I talked to associated bodywork and massage professionals' government relations representative.

Lance Hostetter: 4:04

Hi, I'm Lance Hostetter, director of government relations with associated bodywork and massage professionals, ABMP.

Corey Rivera: 4:11

Lance says that in addition to the big requirements, there's another part of gainful employment that causes a unique problem for massage therapy schools. It's known as the 150% rule. It says that schools can teach up to 150% of the minimum number of hours required by law. In July, 150% will be reduced to 100%.

Lance Hostetter: 4:33

Fear in a state that requires 500 hours, you, a massage program, can provide up to 750 hours in the program or require that for graduation.

Lance Hostetter: 4:45

In changing 150%, that 150% rule down to 100, the Department of Education is essentially saying schools cannot require graduates to do anything more than the bare minimum for state licensure.

Lance Hostetter: 5:01

And we think this is a problem because our idea of licensure and what the state's responsibility is public safety. What do you need to do your job safely? Not what do you need to do your job well? It's the school's job to ensure that students are doing both safety and doing it well. So in moving it down to 100%, the Department of Education is really doing a disservice to this industry in particular by saying we don't really care about quality and we're going to regulate quality out of massage programs and not allow you to do anything more in order to receive Title IV funding is essentially what it is. So a school can still have a program of 750 hours in 500 state, but students would not be eligible to receive financial aid to go to that school. So the idea is the same as that. It's a consumer protection item, but it really impacts schools and we think, students in workforce negatively down the road.

Corey Rivera: 6:05

You might be wondering where a number like 625 comes from. Massage has seven different national associations, which is a topic for a whole other episode. This group calls itself the Coalition for National Massage Therapy Organizations and possibly the only thing they've ever accomplished as a group is called the Entry-Level Analysis Project, or ELAP. This project hired experts in the massage industry to figure out what should be included in an entry-level massage program in order to create safe and competent massage therapists. In 2013, they published a document called the Core Entry-Level Analysis Project Report and Blueprint, which outlines the topics and added up to a 625-hour curriculum.

Corey Rivera: 6:44

I would like to stress that this 625 hours was considered the bare minimum necessary for competency, not excellence. Remember when Lance said 500 hours was too low? Well, massage therapy is licensed individually by state. That state decides the minimum number of entry-level hours the therapist needs to qualify. Currently, there are four states that don't have licensing Minnesota, wyoming, kansas and Vermont looking at you and 30 of the states that do have licensing do not require their programs to be 625 hours in length. It has been 10 years since the Entry-Level Analysis Project was completed and the average reaction to that recommendation of those experts has been a shrug. If you thought that the 150% thing was massage's biggest hurdle. It's not. It's simply the most immediate problem. There's another one Almost no massage therapist works a 40-hour work week and that is the standard when it comes to measuring income. This means that any reports concerning massage therapy income levels are very, very misleading.

Lance Hostetter: 7:50

Students need to, upon graduation, earn X amount of dollars to pay down their debt incurred from school. This is based on the assumption of full-time employment, and now, as you know, corey, and as many of you that are listening know, massage therapists sometimes aren't full-time employed. Sometimes this is a second gig, sometimes this is a series of jobs that you may have, or maybe it's a hobby, and so this really doesn't serve the industry well, and we took fall with that particular issue.

Corey Rivera: 8:31

Like you said, massage therapy is kind of weird in how we clock our hours and how we get paid and how many hours you can do. Most people who are listening are probably massage therapists and they know that performing 40 hours of hands on massage a week is not a thing that you can really do and stay healthy and stay in the game the profession. It's too hard on your body. I would argue that it's too hard on your mind, because focusing on a single human being for an hour is a lot of mental energy as well as physical energy.

Lance Hostetter: 9:05

Most of most massage therapists are not full time. Most of them will never be full time. Most of them still choose to do the profession because they love it. They it's not just something, that it's not just a job, it's something that they love, it's a lifestyle, it's all those things and perhaps that they they're working in a different job and earning that income that would then pay back the, the loans that they incurred by going to massage school. Those are all anecdotal things that don't go into public policy, into the sausage making, if you will.

Lance Hostetter: 9:39

The deadlines July 1st of 2024 to comply with this regulatory change. I'll say that a BMP is working in coalition with other partners in the field to try to get the Department of Education, at a minimum, to extend that deadline, ideally to like January 1st of 2025. There's no promises there and I can't even share any significant updates on that. I'm just saying that's a, that's a strategy that we are hoping to deploy so we can at least give a longer runway for folks to to get up to speed on this. So that's number one schools will have to change their pro. If you're in a, if you're in a state that is a 500 hour program or below 600 hours. You'll have to comply with this new rule at some point, we're assuming so. You'll need to transform your program and I think that'll look differently for for every school and you probably need somebody that's not a public policy expert and more of a curriculum expert to come on and talk to you about what that could look like. But we imagine it will take a significant chunk of time and dedication from schools to do that.

Lance Hostetter: 10:49

Outside of that there's other advocacy actions that that schools and states can take. Number one there is a amendment on the table at the federal level. Senator or representative excuse me, smucker is trying to carry an amendment that would essentially block the the amendment to the 150% rule from going to 100 and maintain it at that 150% level. I think that's something that all schools should write in and support and encourage their state's federal legislators to support that amendment. And this this rule change is is kind of a catch 22. If, if your state requires 500 hours and you offer a 500 hour program, you're technically in compliance with it. The issue is in federal statute. It says that no clock hour programs below 600 hours can be eligible for force federal funding for Title four funding.

Corey Rivera: 11:55

I heard many massage schools choose not to offer federal funding to their students because they don't want to comply with a federal rule of at least 600 hours or the massage expert rule of 625 hours.

Lance Hostetter: 12:09

So it doesn't matter if you move from 500 and 550. If your state's 550, you are not eligible until you get to that 600 threshold. So you really do need to encourage your state to move to that 600 threshold just to be eligible for funding outside of the 150% rule. But because of this new, this new change, I think it behooves everybody to think about what it means to be a 600 hour program.

Corey Rivera: 12:37

How does APMP feel about all these changes?

Lance Hostetter: 12:40

I think ABMP I don't think I know ABMP actually applauds this effort and stands by a lot of this work.

Lance Hostetter: 12:48

Our issue is not related to the consumer protection of students. In fact we believe in that. We think the majority of the regulatory changes in this 700 page packet are really sound public policy. We take issue again with the change from 150% of education hours to 100% hours based on your state, based on what your state requires, and to the debt to income ratio calculation for Industries like ours who have part time employees or or not full time employment. I should say, outside of that, this is really sound public policy because it's protecting. It's protecting students and it's protecting future employees and is, in my mind, a a not just about education but it's about economy. Unfortunately, the 150% rule change, I think, negatively impacts at least the massage economy and a time when more and more people are seeking out services from massage therapists, and I think this, this rule change, could really hinder how many, how schools operate, how many students are able to go to these schools and thereby what the workforce looks like and the massage industry.

Corey Rivera: 14:11

That's 1 of the things I wanted to talk about that this Is an issue that affects massage schools, but it is not a massage school issue, it's an all of us issue. It's a entire massage profession issue, because if the schools go down and we don't have a workforce anymore and we already lost a chunk of people from COVID, people retired, or I mean it was a lot, it was a lot of pressure and a lot of fear and a lot of not not good working conditions, so we lost a lot of people. There will lose more people, so we won't be able to replace the people we lost. And I personally and heal well for sure believes that we're moving into a place now where we might Really start being effective in places like healthcare. But if we don't have people that are trained To be there or to do the job, it's not going to matter if the system's ready, because we won't be ready.

Lance Hostetter: 15:02

It's interesting if you look at larger labor statistics, you'll notice that across multiple industries Including, you know, four year or master's degree or doctorate degree, path, job paths Hiring is part, which means there's a workforce flow issue, and that's not unique to massage, that's not unique to any specific industry. That is a societal issue that we're facing right now, which begs the question why are we making it harder for people who want to be in a pathway to be in that pathway, ie why are we making it harder for massage schools to operate and serve students and people who want to perform and be a part of a profession that is growing and that public demand is growing? For I think that's one of the huge unintended consequences of this rule changes that we will likely see. If unchanged, we will likely see a decrease in workforce development for massage therapy, which thereby makes it harder to hire, which makes it harder to provide services, which creates a huge inverse in supply and demand.

Corey Rivera: 16:23

In the next episode, my co-host, cal Cates, and I will have a more say. The quiet things, loud conversation about gainful employment and how the massage profession, the whole profession, needs to step up. If you don't want to wait an entire two weeks to hear that episode, it is available for everyone right now on our Patreon at patreoncom. If you'd like what you hear, you can support the show by helping us combat the not-safe-for-work content the Apple algorithm has recommended, which we have no control over, by leaving us a review on Apple Podcasts. Thank you for listening.