Debt by Natural Causes

This Week in College Viability Interview

Ryan Hofer — Tue, 25 Aug 2026 23:36:50 GMT

I had the pleasure of participating in an interview alongside Dr. Bex Groebner, hosted by Gary Stocker on This Week in College Viability! If you’re interested in higher education data and finances, follow Gary’s channel for a weekly podcast and the College Financial Health Show. Also, subscribe to Needling to Get to the Point, Bex’s Substack, if you haven’t already!

Enrollment Trends at NUNM

Ryan Hofer — Tue, 25 Aug 2026 08:10:43 GMT

Since Fall term starts soon, let’s take a look at the enrollment at my alma mater, NUNM. To its credit, the university posts total and program enrollment numbers on its website:

Natural Practitioner “Response to Threats” Article

Ryan Hofer — Mon, 24 Aug 2026 08:01:59 GMT

An article by the Executive Director of the American Association of Naturopathic Physicians (AANP) titled “Confronting the Threat to Natural Medicine Education” was published in Natural Practitioner magazine on July 1, 2026. Since it’s a good distillation of talking points, I’ll break it down and provide my analysis.

Show Me The Data!

Ryan Hofer — Wed, 19 Aug 2026 21:10:40 GMT

The Department of Education (ED) has publicized a lack of required data submissions by schools. It turns out, 42% of schools haven’t submitted at least one set of required data.

Just over 1,900 colleges are missing or underreported any number of data files while 578 colleges didn’t properly submit all seven data files.

This is the type of school data that will be used to match students with earnings for the July 2027 Earning Test. I don’t think ED will look kindly upon schools that don’t submit the files needed for the first Earnings Test.

That first batch of data was initially due July 31, 2024, and would include stats from 2022–23 and 2023–24. But the Education Department repeatedly pushed the deadline back until Sept. 30, 2025. Data from the 2024–25 academic year was due Oct. 1, 2025. In two months, on Oct. 1, 2026, institutions will have to submit data from 2025–26.
ED plans to use the data to compare the earnings of a program’s average graduate with those of a high school diploma holder in the same state. Programs that fail the test in two out of three consecutive years could temporarily lose access to federal loans.

Inside Higher Ed created a searchable table, so we can all see which schools haven’t yet submitted the required data yet. Let’s check on some ND and Acu schools:

Good job Five Branches, Alhambra, Northwestern, and Won Institute! Many others have some overdue homework.

Photo by Annie Spratt on Unsplash

Taking Stock

Ryan Hofer — Sun, 16 Aug 2026 08:02:29 GMT

This Substack newsletter continues to grow steadily, and will become more relevant over the coming year. Thank you subscribers, free and paid! Your engagement and interest helps socialize the call for systems change in Naturopathic and Acupuncture Education.

Where do we go from here?

Over the next year we will continue to witness the decline of the educa…

Interview on By The Roots Podcast

Ryan Hofer — Thu, 13 Aug 2026 21:29:51 GMT

I had the pleasure of joining Dr. Christie Wyld for a deep dive into the state of Naturopathic Medical Education on By The Roots. I hope you’ll take a listen, even if you’re not a Naturopathic Doctor, and please share this with anyone you know who is considering attending an ND program!

Here's a link to the episode on Spotify.

Episode Description
In the US…

AANMC Lawsuit and Effects of the Loan Caps

Ryan Hofer — Mon, 10 Aug 2026 00:12:19 GMT

As I wrote about previously, the AANMC, AANP, and NMSA have filed a lawsuit to get the 50K loan cap for ND programs. I’ve also written and spoken about how the 20.5K cap is an existential crisis because ND programs can’t actually survive under that constraint. ND tuition alone is about 40K and the annual cost of attendance is about 70K. ND programs desperately need the 50K cap to bring their educational product into the realm of possibility. I don’t think 50K is enough, but the 20.5K cap is the immediate fire that must be put out. I was able to locate the federal court complaint filing, and it’s very illuminating to read about how the 20.5K cap is affecting AANMC and its member institutions. Let’s take look at what’s going on backstage.

CNME Decision Letter [part 2]

Ryan Hofer — Sun, 09 Aug 2026 08:01:31 GMT

I previously wrote about student achievement issues cited in the Department of Education’s Final Decision Letter that placed CNME on a 12 month monitoring cycle. In this post I will review the compliance issues related to recruiting and admissions. Here’s the Final Decision Letter again for reference:

Council On Naturopathic Medical Education Sdo Decision Letter 2026 6 23

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Let’s start on page six with the second area of noncompliance:

34 C.F.R. § 602.16(a)(1)(vii)
Department staff finding: The agency is not in compliance with this section. The agency has not demonstrated that it has established effective standards, as required by 34 C.F.R. § 602.32(f), for the review of recruiting and admissions practices and publications and advertising that include student achievement outcomes. NACIQI concurred with this finding in its motion (p. 6).

ND Loan Caps Lawsuit

Ryan Hofer — Fri, 07 Aug 2026 08:15:34 GMT

The AANP, AANMC, and NMSA have filed a lawsuit in order for ND programs to gain access to the higher student loan limit of 50K for Professional Degrees, as defined by the Department of Education. Lawsuits by professional organizations representing Nurses and Physician Associates have resulted in temporary injunctions and an expanded list of Professional Degrees, but neither ND nor Acupuncture graduate degrees were included. In an attempt to avoid a collapse of the funding keeping ND programs alive, the ND professional organizations are now seeking an injunction.

Mixed Messages and Accreditation Renewals

Ryan Hofer — Sun, 02 Aug 2026 08:01:06 GMT

We’ve seen a clear trend of sudden closures at ACAHM schools: OCOM, East West College of Natural Medicine, PIHMA, and AIMC. Acupuncture graduate degrees were already a declining subsection of declining higher education sector before the loan caps and the earnings test even began. Over the next two years, I think we will see an acceleration of this decli…

SIEAM FY 2025

Ryan Hofer — Thu, 30 Jul 2026 19:47:53 GMT

The most recent publicly available audit for the Seattle Institute of East Asian Medicine shows the school once again received a Financial Responsibility Composite Score below 1.0.

A school with a score less than 1.0 is considered not financially responsible. However, a school with a score less than 1.0 may continue to participate in the Title IV programs under provisional certification. In addition, this lower score typically requires that the school be subject to cash monitoring requirements and post a letter of credit (equal to a minimum of 10% of the Title IV aid it received in the institution’s most recent fiscal year).

No Fall Term at AIMC

Ryan Hofer — Wed, 29 Jul 2026 19:46:00 GMT

The Acupuncture and Integrative Medicine College (AIMC) community has received an email from the President explaining that a fall trimester, scheduled to begin on August 31, is no longer a viable option. The announcement from the President contains the following information:

Last night the AIMC Board of Directors met and considered my recommendation date…

On Meltdowns

Ryan Hofer — Tue, 28 Jul 2026 19:21:54 GMT

One aspect of the ND/Acu meltdown I could never understand was an attitude I eventually named “too special to fail.” This is the perspective that ND/Acu schools won’t close because the mission is very unique and some people care about their particular program. This generally went along with inflated administrator salaries, often justified through compar…

Everyone Knows, Right?

Ryan Hofer — Wed, 22 Jul 2026 20:05:05 GMT

As we travel steadily towards July 2027, I’m not expecting the ND/Acu spin machine to slow down or get reflective. It’s important to understand, the schools will continually emphasize positives while continually omitting serious negatives. This is why its essential for students and the public to understand the group dynamics in ND/Acu world, and to unde…

Into the HyperReal

Ryan Hofer — Mon, 20 Jul 2026 18:13:35 GMT

We live in a society filled with parties broadcasting out their messages, and this Substack newsletter is one example. However, I see a big difference between messengers paid to hype for the status quo, and messengers who independently share their perspective on quantifiable data. In this newsletter, I write continually about the loan caps and the earni…

ASAOM Review at AZPPSE

Ryan Hofer — Thu, 16 Jul 2026 02:26:45 GMT

The Finance Committee of the Arizona Board of Private Postsecondary Education reviewed the Arizona School of Acupuncture and Oriental Medicine on June 18th, 2026. As you may recall, ASAOM was the only acupuncture school left in Arizona after PIHMA closed, but it was also having financial issues and is on a quarterly review. The June 18th meeting was the…

CNME Chooses New Executive Director

Ryan Hofer — Wed, 15 Jul 2026 19:16:36 GMT

The CNME Board has appointed Jan W. Friis, Jr., J.D. as its new Executive Director. Mr Friis was Senior Vice President for Government Affairs at the Council for Higher Education Accreditation (CHEA) for more than 20 years. I see this as a positive step out of insularity and towards accessing external expertise to improve the quality of Naturopathic education. With its new Executive Director, CNME will now attempt to come into compliance with multiple federal regulations within a 12-month monitoring period.

Cnme Pressrelease Cnme Hires New Ed July 2026

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Fractional Loan Limits

Ryan Hofer — Mon, 13 Jul 2026 02:53:32 GMT

Under the new rules for federal student loans, annual loan limits are calculated “fractionally,” meaning a student will only be eligible for the full amount if they are a full-time student, as defined by the program. This change applies to all students, including legacy GradPLUS students. The Student Financial Services office at Columbia University expl…

CNME Placed on 12-Month Monitoring

Ryan Hofer — Wed, 08 Jul 2026 21:10:55 GMT

The Department of Education has released the CNME decision letter from the Senior Department Official (SDO). It’s posted under the 3/24/2026 meeting documents at the NACIQI archive website.

Council On Naturopathic Medical Education Sdo Decision Letter 2026 6 23

416KB ∙ PDF file

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The end result is that CNME is on a 12-month monitoring plan during which time it needs to come into compliance with the requirements in the decision letter. The Code of Federal Regulations (CFR), Sections 602.16 through 602.21, explains standards for federal recognition of accreditation agencies by the Department of Education. The author of the decision letter, Under Secretary Nicholas Kent, organized the letter using these standards. The decision letter is 26 pages so I’m going to break my review up into several posts.

Non-Compliance Regarding Student Achievement

34 C.F.R. § 602.16(a)(1)(i): Accreditation agencies must set forth clear expectations for “(i)Success with respect to student achievement in relation to the institution’s mission, which may include different standards for different institutions or programs, as established by the institution, including, as appropriate, consideration of State licensing examinations, course completion, and job placement rates”

From the CNME Decision Letter: “Department staff finding: The agency is not in compliance with this section. The agency has not demonstrated that its student achievement standards are sufficiently rigorous to ensure that the agency is a reliable authority regarding the quality of the education or training provided by the programs it accredits. NACIQI concurred with this finding in its motion” (page 2).

ND Education Regulations and Changes Discussion

Ryan Hofer — Sun, 05 Jul 2026 22:30:08 GMT

Katherine, Stevie, and I had a great conversation about what’s going in ND world, how we got here, and what’s possible. I hope you’ll enjoy the open discussion about issues that are challenging the sustainability of the ND ecosystem.