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| 13 president of the Midwest College of Oriental Medicine.
14 We are a multi-state approved accredited program 15 offering a Master's Degree in Oriental Medicine. We are 16 a for-profit college. 17 There are a few points I would like the 18 Department to consider when revisiting the Gainful 19 Employment rules as it applies to colleges of 20 acupuncture and Chinese medicine, a very narrow concept. 21 The education of ACM students is 22 substantially different in career choices and education 23 than other goals of other graduates, programs and 24 students of other student accredited programs. The 25 theme for me today is: Hold me accountable for what I 
1 can control; don't hold me accountable for what I can't 2 control. And one of the things about ACM students is 3 that many of them, not like other industries, are not 4 choosing to be employed, or not choosing to be employed 5 full-time. In fact, one of our graduates whose husband 6 is a cardiologist chose to receive financial aid and is 7 practicing at a local tennis club part-time, may not 8 even be charging people. 9 I have a graduate who recently moved to 10 Florida whose husband is a prominent internist. She 11 decided to go to school, obtain her master's degree, 12 pass the national boards, obtain licensure, with the 13 expectation that she would have a number of children 14 before practicing after they were 18. 15 I have a senior retired Korean graduate who 16 chose to do the education for the sole purpose of 17 treating patients in his community church in the 18 basement for free. 19 Another graduate, a student, who, during 20 the application process, indicated that the sole purpose 21 of her education was the life-long treatment of her 22 autistic child. She felt that the acupuncture helped 23 the autism but couldn't afford the life-long treatment 24 so she felt it would be better to receive the education 25 and never intended on practicing.
1 Some graduates choose to volunteer at 2 low-cost clinics. There's a practice called Community 3 Acupuncture where there's a sliding scale between $5 and 4 $20 a treatment, and, subsequently, our graduates adjust 5 their lifestyle and adjust their choosing to earn less 6 money. 7 I mentioned this to a friend and he said, 8 Well, how can that be? How can you be held responsible 9 for your graduates' choices?" And I can't. 10 Our graduates are 80 percent women. The 11 average student is between 38 and 42 years old. Many 12 women students wait until having children and they were 13 independent before returning to acupuncture in Chinese 14 medicine. Some graduates choose to rely on the support 15 of their spouses and to operate how-they-like practices. 16 So the idea that there's immediate 17 employment is nonexistent. We do have graduates in 18 hospitals and medical centers across Illinois and 19 Wisconsin, but most graduates choose independent 20 practice. They choose to be entrepreneurs, and, as you 21 know, it takes a number of years before we can break 22 even. 23 My second point is that there are 60 24 colleges, approximately, teaching Chinese medicine and 25 acupuncture in America. 50 percent are for-profit.
1 50 percent are not-for-profit. We all teach, basically, 2 the same curriculum, we have similarly qualified 3 faculty, we have very similar fixed costs for 4 operations, yet 50 percent of the schools are not 5 required to comply with these regulations. The 6 not-for-profits are totally not evaluated for any of 7 these criteria, which we think is very unfair. We need 8 an equal opportunity for protection under the 9 regulations, both for not-for-profit and for-profit. 10 Again, getting back to: Hold each college 11 accountable for the measurements. Are the colleges 12 charging more-than-available financial aid? It's real 13 simple. We don't. We operate very much like a 14 not-for-profit. We establish a budget, determine what 15 number of students to make the budget, and that's what 16 we charge in tuition. So if a college is charging less 17 than the financial aid available, publish it. Come out 18 there and say, we're taking 40 percent of your available 19 financial aid. We're taking 110 percent of your 20 financial aid. That gives a consumer an indication of 21 what it costs and how responsible the college is. 22 I believe in consumer protection 23 100 percent, and I believe the Department needs to do 24 more in terms of disclosures, other than the Gainful 25 Employment little web page that may be hidden on the
1 websites. We need a Carfax-like disclosure. We need 2 multiple factors that are presented to prospective 3 students at the time of their application or the time of 4 their tour, the time of the interview. 5 Let's talk about faculty qualifications. 6 Let's talk about the fact that I have 87 percent of my 7 last four years' graduates in practice. They're in 8 practice because we enabled them to pass the Boards. If 9 you can't pass -- first of all, we have an 85 percent 10 completion rate. If you can't pass the Boards, you 11 can't get a license, which means you can't choose not to 12 work full-time. So licensure in professions is 13 important. Passing the boards and completion rate is 14 important. These should be disclosed -- 15 MR. MARTIN: Time. 16 MR. MANNING: You have 20 seconds. 17 MR. DUNBAR: Finally, there is a big 18 difference between -- there is a gray area between 19 not-for-profit and for-profit, and I suggest the 20 Department consider eleemosynary for-profits. These are 21 for-profits that don't issue dividends or issue very 22 little dividends. These are colleges that the primary 23 stockholders, myself and my partner, are stockholders. 24 We are both full-time employees, and we are making wages 25 commensurate with not-for-profit positions in our same
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