Facing Major Challenges Under Proposed Federal “Do No Harm” Regulation

With review from the Association of Accredited Naturopathic Medical Colleges, Association of Colleges of Chiropractic, and the Accreditation Commission for Acupuncture and Herbal Medicine.

Natural medicine professions face one of the most severe federal regulatory threats in recent history. In fact, the professions are currently battling two simultaneous existential threats regarding student financial aid. A new draft accountability framework from the U.S. Department of Education, commonly referred to as the “Do No Harm” or AHEAD regulation, places academic programs at risk of losing access to federal student loans.

Compounding this “Do No Harm” framework is the recently finalized RISE rule, which arbitrarily narrows the definition of “professional degree” and caps federal student loans for naturopathic and acupuncture professions (as well as nursing, PT, OT and dozens of others) to a lifetime aggregate of $100,000—drastically below the actual cost of completing these programs. These regulatory actions threaten to permanently reshape the future of naturopathic, acupuncture and chiropractic education across the United States if adopted and allowed to be implemented.

Central to the “Do No Harm” proposed rule is a new “earnings premium” accountability test enacted as part of the 2025 One Big Beautiful Bill Act. This mandate ties the continued eligibility of higher education programs for Title IV student funding directly to the median graduate earnings of graduates reported exactly four years post-graduation. Programs failing to demonstrate IRS-reported earnings that exceed a federally determined benchmark two times within a three-year period will become completely ineligible for federal student loans as early as July 2028.

For graduate programs in natural medicine, this federally determined benchmark relies on the median earnings of individuals aged 25 to 34 who hold only an undergraduate degree in a broadly related field. Past accountability tests utilized comprehensive inputs like debt-to-earnings ratios or cohort default rates. This new framework ignores tuition costs, licensing examination pass rates, graduation rates, and actual loan repayment success entirely.

Inappropriate Framework

Preliminary federal modeling released earlier this year revealed that this “one-size-fits-all” framework could lead to approximately 98 percent of naturopathic, acupuncture and Chinese medicine programs failing this skewed metric. Additionally, as published in Dynamic Chiropractic, initial draft data identified 13 chiropractic programs in the federal data set, and among those with complete information, approximately 62 percent would fail the proposed earnings test and potentially lose access to federal student loan eligibility.1 Any program failing the benchmark twice in a three-year period would completely lose federal student loan eligibility. It should go without saying that any exam or framework that leads to such catastrophic failure rates, across multiple professions, is not scientifically or statistically valid. It is a model incorrectly applied to what it is attempting to measure.

A Coordinated Defense Against Flawed Metrics

Organizations representing all three affected professions mobilized rapidly in response to this existential threat. The American Association of Naturopathic Physicians, the Association of Accredited Naturopathic Medical Colleges, the Accreditation Commission for Acupuncture and Herbal Medicine, the Council of Colleges of Acupuncture and Herbal Medicine, and the Association of Chiropractic Colleges all submitted extensive formal comments exposing the deep methodological flaws of the proposed rule. An analysis of these technical comments reveals a striking consensus. The federal framework fundamentally misunderstands the economic realities of licensure-based, entrepreneurial health care professions.

An overview of the comments submitted by these professional associations representing natural medicine reveals consensus on four major structural failures within the proposed regulation:

1. A Penalty on Small Business Ownership

Unlike many salaried health care workers, naturopathic doctors, licensed acupuncturists and chiropractors primarily operate through self-employed, small-business models. These newly graduated professionals launch independent practices, manage overhead expenses and invest heavily in local community marketing. Sound business management dictates reinvesting early revenues into clinic infrastructure, diagnostic equipment and staffing. During these crucial early years, practice owners intentionally minimize their personal taxable income to strengthen the long-term viability of their clinics.

One critical question relates to how earnings are measured. It is unclear which sections or lines of IRS tax filings are being evaluated, and whether the self-employment income reported to the IRS accurately reflects actual economic stability or wealth creation, for both these practitioners and their communities. For naturopathic doctors, acupuncturists and chiropractors who operate independent practices, taxable income may not capture the value of business ownership, equity development, community employment generation, or future earnings potential.

There is also concern that the model penalizes professions which offer career flexibility by including the data from graduates pursuing part-time practice models, integrative health collaborations, rural practice development or delayed careers. This rigid window is particularly punitive for the heavily female workforce across these fields, capturing practitioners precisely during life stages when many balance early career growth with maternal and familial responsibilities. Without adjusting for flexible or part-time scheduling, the framework effectively transforms a known societal wage gap into a punitive institutional failure.

2. A Grossly Premature Measurement Window

A four-year post-graduation measurement period does not adequately capture the career trajectory of health care professionals whose practice models require substantial time to develop. Many naturopathic doctors complete postgraduate residencies before entering independent practice, and all of these professions often spend several years establishing referral networks, growing patient panels, and building viable businesses. Consequently, earnings data collected within four years of graduation may disproportionately reflect the early stages of professional development rather than the long-term earning capacity and workforce value of these practitioners.

Earnings data proves that income in these professions grows significantly over time. Chiropractic earnings roughly double over the course of a career,2 highlighting the absurdity of judging a multi-decade profession on a single, early-career snapshot. The four-year window ignores the reality of practice development and fails to capture the true long-term value of a natural medicine degree.

3. Mismatched and Asymmetric Data Sources

Federal regulators plan to determine pass or fail status by comparing two entirely incompatible data sets. The threshold benchmark of people who have completed a bachelor’s degree relies on the American Community Survey, a voluntary instrument where respondents estimate their gross household earnings without any legal obligation or verification. The Department proposes comparing that data to graduate earnings pulled from strictly enforced IRS tax data reflecting net income. Comparing self-reported gross survey estimates against post-deduction tax records introduces a severe structural bias against small-business owners.

Furthermore, the benchmark aggregates individuals using broad two-digit Classification of Instructional Program (CIP) codes. Specialized, doctoral-level practitioners like NDs and DCs would find themselves compared against a massive pool of bachelor’s degree holders in generalized health sciences or allied health roles. This mixes fundamentally distinct labor market dynamics, matching independent clinical practice owners in their early careers against mid-career salaried employees in vastly different fields.

4. Ignoring Proven Financial Stability

Perhaps the most glaring omission in the proposed rule is the complete disregard for actual student loan repayment success. Cohort default rates provide a direct, comprehensive measurement of a program’s value and true borrower affordability. Graduates across all three of our professions demonstrate a high level of financial responsibility based on the Department’s published data.

Naturopathic institutions consistently have default rates hovering between 0 and 2 percent. Acupuncture institutions had default rates of 0.01 in both 2022 and 2021, the most recent reporting years.3 Chiropractic institutions similarly trend well below national averages. While high student loans is unequivocally a challenge in these professions that needs to be addressed, this data demonstrates that our graduates secure the financial stability necessary to service their debt obligations. Stripping federal aid from programs that produce successful, responsible borrowers contradicts the very purpose of an educational accountability framework.

Impact on Patients and Allied Businesses

Loss of Title IV eligibility would eventually eliminate access to federal student loans for affected natural medicine programs. Decreased enrollment will inevitably shrink the future workforce of NDs, LAcs and DCs. This regulatory oversight endangers far more than just academic institutions. The entire ecosystem of natural health relies heavily on a robust pipeline of highly trained clinical practitioners. Graduates from these natural medicine programs are intricately woven into the fabric of integrative medicine, from product development to education, research and patient care. This threatens to dismantle the foundation of an entire industry in one administrative brushstroke.

More importantly, restricting access to natural medicine education undermines national public health priorities. More than 100 million adults currently utilize complementary health care services, primarily seeking safe, non-pharmacological pain management. Federal agencies project massive upcoming physician shortages. At a time when our health care system desperately needs providers dedicated to chronic disease prevention and whole-person care, punishing community-based clinics through flawed administrative metrics represents a catastrophic policy failure.

Advocacy, Action and the Path Forward

Higher education leaders and legal experts widely agree that the rule proposed by the Department of Education is heavily flawed. The unified resistance from our professions is escalating rapidly.

In addition to comprehensive technical comments submitted during the rulemaking process for the “Do No Harm” regulation, powerful congressional and legal counter-offensives are actively underway to combat the RISE rule. The Department of Education recently finalized the RISE rule, narrowing the definition of “professional degree” to only 11 professions for student loan purposes, excluding nursing, NDs, LAcs, OTs, PTs, PAs and dozens of other health professions. Lawmakers recently introduced a Congressional Review Act resolution seeking to officially repeal the RISE rule, with its restrictive student loan definitions. A coalition of 25 states has sued the Department of Education, seeking permanent injunctions to block implementation of related loan restrictions. Two lawsuits have been filed on behalf of various health care professions seeking immediate injunctions before the rule’s implementation date of July 1, 2026, with more lawsuits anticipated. While these specific actions target the parallel RISE rule, they demonstrate the aggressive legal strategies our professions are prepared to deploy to protect student access to financial aid.

We fully support transparent, statistically valid accountability measures that protect students and taxpayers. We cannot accept a framework that evaluates health care education using simplistic, short-term tax metrics while ignoring patient outcomes, public health benefits, and successful loan repayment. Our professions are committed to exploring every possible legislative and potentially legal pathway available.

The stakes for our colleges, students, industry partners and patients could not be higher. We must ensure federal policymakers understand that natural medicine education delivers profound economic and societal value. Professional survival requires collective vigilance and action. Stay informed and join our coordinated advocacy efforts to defend the future of natural medicine.

Sign up for AANP policy updates at https://naturopathic.org/page/AdvUpdates.

References:

1 Dynamic Chiropractic, “Confronting the Threat to Chiropractic Education,” accessed June 8, 2026.

2 Association of Chiropractic Colleges, “Comments on the Notice of Proposed Rulemaking, Docket ID ED-2026-OPE-0100,” submitted to the U.S. Department of Education, May 20, 2026, page 13. Regulations.gov Document ID: ED-2026-OPE-0100.

3 The Accreditation Commission for Acupuncture and Herbal Medicine (ACAHM), “Comments on Accountability in Higher Education and Access Through Demand-Driven Workforce Pell: Student Tuition and Transparency System (STATS) and Earnings Accountability, 91 Fed. Reg. 21,088 (Apr. 20, 2026),” submitted to the U.S. Department of Education, May 20, 2026, page 7. Docket ID: ED-2026-OPE-0100.

Laura Culberson Farr is the executive director of the Association of Naturopathic Physicians (AANP), leading efforts to advance recognition and access to licensed naturopathic medicine in the U.S. With nearly 30 years of advocacy experience, she has served as executive director of the AANP since 2017, where her leadership has helped achieve licensure in several states and supported ongoing initiatives nationwide. Previously, she led the Oregon Association of Naturopathic Medicine, expanding prescribing authority and Medicaid access for naturopathic doctors. Before her work in naturopathic medicine, Farr was a lobbyist and government affairs consultant in Oregon, managing successful campaigns for Vote by Mail, smokefree workplace laws, and tobacco control. Her expertise in health care reform and collaboration among providers and insurers has been instrumental in integrating naturopathic medicine into primary care.