Proposed Rule Could Limit Student Financial Aid and Close Massage Therapy Schools

 

While the intent is to ensure students are not financially worse off after completing their education, the rule’s execution is deeply flawed and raises serious concerns about regulatory overreach. Originally designed for degree-granting institutions, the rule has been extended to career training programs, like massage therapy, without accounting for how these professions actually operate. The current earnings metrics fail to reflect key realities of the massage profession, including part-time work, tip-based income, self-employment, and flexible career paths. As a result, many programs could lose access to federal funding by July 2028!

 

We strongly encourage all school leaders, educators, students, graduates, employers, and practicing massage therapists to submit comments on the proposed “Do No Harm” rule.

 

• Harm to Student Access, Equity, and Workforce Development: By tying federal financial aid to these flawed measures, the rule will severely limit access to massage therapy education and cause many schools to close. This would have the biggest impact on lower-income students, women, and underrepresented groups, and could significantly reduce the number of new massage therapists entering the profession.
   
• Regulatory Overreach and Misalignment: The proposed rule takes standards that were originally created for colleges and universities that offer degrees and applies them to career training programs like massage therapy. This approach does not reflect how massage therapy education works or how therapists build their careers, making it a poor fit for our profession.
   
• Flawed and Incomplete Earnings Metrics: The way the rule measures earnings is based on comparisons that are often inaccurate or misleading. It uses faulty “high school only” income data, does not account for differences in pay depending on where someone lives, and compares just a few years of massage therapy earnings to many years of earnings from other workers. It also ignores important parts of the profession, like part-time work, tips, self-employment, and income that may not always be fully reported.
   
• Failure to Capture Long-Term Career Value of Massage Therapists: The rule looks only at income in the first few years after graduation, which doesn’t reflect how massage therapy careers typically grow. Many therapists increase their earnings over time by gaining experience, building a loyal client base, specializing in techniques, or starting their own businesses, none of which are captured in this short-term view.
   
• A Better Measure: Graduates’ Ability to Repay Loans: Accountability measures should focus on graduates’ ability to successfully manage and repay their student loans over time, rather than solely relying on raw earnings data. A repayment-based approach provides a more accurate and equitable picture of student success while recognizing the diverse career paths, work schedules, and income models common in the massage therapy profession.

Submit Your Comments by May 20

How to Submit Your Comments in 5 Easy Steps

1. Visit the U.S. Department of Education's website.
   
   
2. Enter your comments directly or upload a document (PDF preferred). If uploading, type “see attached file” in the comment box.
   
   
3. Select the category that best describes you.
   
   
4. Provide your email address and indicate whether you’re submitting as an individual, organization, or anonymously.
   
   
5. Confirm you are not a robot and click “Submit Comment.”
   

Thank you for taking the time to show your support! Let’s stand together to protect access to massage therapy education and ensure our profession is fairly represented.