The mission of the Independent Massage School Association of California is to promote the interests of the owners, staff, faculty, students and graduates of independent massage schools in California. Membership is open only to schools that have massage and bodywork as their primary focus.
55000 Highway One
Big Sur, CA 93920
27820 Dorris Drive
Carmel, CA 93923
P.O. Box 2110
San Anselmo, CA 94979
9833 Fair Oaks Blvd., Suite C-1
Fair Oaks, CA 95628
6708 Foothill Blvd., Tower 2
Tujunga, CA 91042
739 12th St.
Fortuna, CA 95540-2346
424 F St. #B
2940 Webster St.
Oakland, CA 94609
CAMTC # SCH0007
BPPE # 0101661
18424 Harbin Springs Rd.
Middletown, CA 95461
108 N. Main St. #5
Sebastopol, CA 95472
699 Peters Ave.
401 – 32nd Ave.
San Francisco, CA
CAMTC – Board of Directors
In response to a letter received today from Joe Bob Smith at CAMTC, I am writing on behalf of IMSAC (Independent Massage School Association of California) to request that the Board consider how it handles applicants who have hours from schools that have closed and were in good standing when they closed.
According to AB-1147 (Sec 4615), the CAMTC Board of Directors has the responsibility to determine sufficient education and to develop policies and procedures to approve schools, but the board is not instructed by the law to retroactively disapprove schools that have closed in good standing prior to the School Approval Process now implemented by the CAMTC. The law is in fact silent on the handling of such schools except that Sec. 4606 mentions appointment of Custodians of Record, a strong implication that the legislature anticipated that such records would remain of value.
I request that, at the Board Meeting on the 25th, to the Board amend the approval process to add language that does not retroactively disapprove all former education for those students who attended BPPE-approved schools and/or schools that were not unapproved by the CAMTC at any time. These hours were lawfully acquired by thousands of students who were encouraged to and did put their trust in the state vocational school approval process.
If the language in the letter attached is maintained, thousands of students who have graduated from schools that are now closed will not be able to use their education hours – hours paid for and taken in good faith at a state-approved school — to apply for CAMTC Certification after June 30th, 2016.
In addition, the adoption of this policy would place an extraordinary and undue burden on approved schools. Approved schools would be solely responsible for explaining the sudden policy shift – and they would surely bear the brunt of the anger and grief this would provoke.
Existing policy is that education from schools that were in good standing with the BPPE and/or the CAMTC at their time of closure would be honored by CAMTC. It was not stipulated that graduates would have to apply by June 30th, 2016, nor was it stated that schools would bear any responsibility to ‘spread the word’ of policy changes. Again, the provision for establishing Custodians of Record – prior to any CAMTC approval process – speaks to the perceived validity of educational hours completed at state-approved (BPPE) institutions in good standing.
If it is not possible to continue to accept hours from non-CAMTC-approved schools in the future, we request that the process of moving toward that end be modified to increase fairness and to reduce anger toward and lack of credibility of all state sanctioned school approval agencies, including BPPE and CAMTC.
Examples and suggested modifications:
1. McKinnon BTC is the Custodian of Records for Body Therapy Center and Acupressure Institute. Both BTC and AI are closed, and we regularly have returning and current students use hours from these schools as portions of their 500 hours for application for CAMTC Certification. McKinnon BTC has applied to be an Approved CAMTC school. Will the records we maintain from these closed schools – both approved and in good standing at the time of their closure — still be accepted?
Suggestion: Amend language to allow hours from schools closed in good standing (that were acquired by merger or sale and are now held by approved schools acting as Custodians of Record) to count toward CAMTC-required application totals.
2. A school closes in good standing with the BPPE. The school has NOT been put on the ‘unapproved’ list by CAMTC. The school may or may not be able to reach out to all previous students to notify them that the validity of their previously accrued hours is now time-limited — or the school may not be able to reach all students before the end of June.
Suggestion: CAMTC permits students to open applications and submit education hours from state-approved schools in good standing prior to the June 30 deadline. These hours could then be added to additional hours from approved schools as they are earned and documented. CAMTC could determine a timeframe for how long applicants would have to complete and document required hours, pass the MBLEx, and submit other application requirements. In this way, the goal of not accepting non-CAMTC-approved school hours after June 30 could be met, and students would at least have some ability to use previously accrued (and paid for) hours from state-approved schools.
In addition, CAMTC supports school efforts toward communicating with former students by placing announcements with professional membership organizations, creating press releases, and communicating immediately with all known schools.
3. A school that was in good standing with the BPPE was sold and, subsequently, after sale, listed as unapproved by CAMTC. A student attended the school during the time the school was in good standing.
Suggestion: As stated above, allow students more time to submit hours accrued from all educational institutions in good standing prior to June 30. Additionally, support communication and notification efforts and establish reasonable application completion timelines for certification applicants.
The invalidation of education obtained from state-approved institutions is an extraordinary step. An increase in educational standards and monitoring need not entirely discriminate against or disadvantage members of the public who have paid for and earned educational hours in good faith at state-approved schools. By establishing a reasonable time for students to be notified and to submit their previously accrued, state-approved hours, the twin goals of fairness to students who have acted in good faith and increased educational standards and monitoring can be achieved.
To: Business and Professions Committee
Re: Statement of Information in regard to the Elimination of the CAMTC 250 Hour Tier
I am writing as the spokesperson for the Independent Massage School Association of California (IMSAC). We are represented on the California Massage Therapy Council (CAMTC) by Keith Grant.
Who we are
IMSAC (Independent Massage School Association of California):
Consists of 20 of the 80 independent massage schools in California (all 20 have been in operation between 15 and 40 years.)
Employs over 350 teachers and staff
Serves over 1000 graduates annually
Is part of California’s unique character: no other state boasts the number of schools offering massage education and the diversity of education provided.
Supports CAMTC and its mission to improve standards for massage education in California; but not at the cost of jobs and businesses throughout the state.
Recent action and concerns: On September 18th, the CAMTC Board voted for advancing elimination of the 250-hour, entry-level tier for Certified Massage Practitioners (CMP) to December 31, 2014, one year earlier than the compromise stipulated by SB 731 when it was passed into law. This limits entry to certified practice to the 500 hour CMT certification. A separate CAMTC vote already advocated placing passage of a psychometrically valid exam in front of both tiers. Because the majority of IMSAC schools operate on a pay-as-you-go basis, IMSAC is concerned about:
Loss of viability for its member businesses
Associated job loss for the many employees of independent massage schools in California
Reduced “affordable and accessible” career options for un- or under-employed workers, youth, homemakers returning to the workforce, and veterans in need of retraining, among others
By filing this Statement of Information, IMSAC wants to bring focus to the negative economic impacts of early elimination of the 250-hour (CMP) tier. At this time, schools are already barely recovering from the economic downturn of the last five years. IMSAC schools support many CAMTC efforts and are in favor of progress for our field, but we do not want to be dismissed as arbitrary collateral damage of that progress.
Relevant points of information:
1. The recent CAMTC Board vote on the CMP tier was not explicitly on the meeting agenda but buried within a 95 page board packet under “Sunset Actions”. IMSAC ended up with little time in which to canvas member schools for opinions or in which to communicate concerns.
2. Eliminating the 250-hour Certified Massage Practitioner tier will have a negative impact on both employment and growth of the massage therapy profession in California—particularly in northern California where many local requirements have been and are less than 500 hours.
Schools have already created work plans, budgets, and calendars around the expiration of the 250-hour tier at the end of 2015 rather than 2014.
It is already challenging to find qualified teachers, an identified problem throughout the profession and a matter to which IMSAC is committed.
If the 250-hour tier is terminated (either early or at the end of 2015), most independent schools will be forced to close from elimination of their business model and lack of resources and time to double their curriculum.
Even for schools that manage to remain open beyond the elimination of the 250-hour, entry-level tier (CMP), initial student tuition costs will rise suddenly by about $4000.
Many of the students normally served by these long-standing and reputable schools will no longer have educational options allowing them to enter a career in massage therapy.
Elimination of the CMP tier creates an unnecessary incentive to oppose adoption of CAMTC-only regulation by northern California cities and counties.
3. If students are required to initially commit to – and pay for – programs of 500 hours or more, then:
Students will have no choice but to take out third-party loans to finance their education.
While the CMT tier is for 500 hours, access to federal financial aid currently requires accreditation and a minimum program of 600 hours (34 CFR 668.8). To be considered a full-time program, 900 hours must be provided in an academic year (34 CFR 668.3). There is already concern for loan default rates from private post-secondary schools and no evidence for 500 hours being a financially viable program length.
4. Passing an exam helps to independently verify a student’s or applicant’s learning, an important factor when all submitted school transcripts may not be valid (despite CAMTC’s best efforts). The arbitrary number of 500 hours of education, however, has never been correlated with achievement of professional competence on a well-specified set of core tasks. To date, there has been no consistent and widely accepted standard for required core competencies and job tasks within the massage profession.
To remedy this situation, a national, industry-wide initiative called the Entry Level Analysis Project (ELAP), supported by all major stakeholders, was undertaken. Results from ELAP (a 750-page document detailing recommendations and findings) are due out this December. The results of ELAP will re-shape all massage therapy programs nationally, and those in California will be no exception. If the CAMTC and legislature wait until the ELAP results are released and considered by the massage profession before potentially reshaping certification policy, all schools in California can not only participate but also lead the way in supporting consistent national standards for education. It will be possible to compare programs and hours in terms of actual competencies. If CAMTC certifications are changed prematurely, all schools will face another change in requirements in a very short time.
5. CAMTC has certified over 40,000 massage professionals. Of those, roughly 10% have been certified at the 250-hour level (Certified Massage Practitioner). According to the CAMTC’s own data, a smaller percentage of CMPs (250 hours) compared to CMTs (500 hours) are suspected of participating in adult entertainment or sex work. There is no data-driven indication that the CMP tier presents an increased physical or ethical risk to the public.
6. Proposed solutions:
To avoid business closures and job loss by maintaining the 250-hour, entry-level, massage practitioner tier (CMP) as a CONDITIONAL option valid for a limited time (3 years?) after which the certificate holder would have to have achieved CMT status by completing an additional 250 hours of Education. This combined with an entry exam raises professional standards while preserving flexibility in entry to the field and supporting California’s small businesses and jobs. At the very minimum, retain the current CMP certification through the end of 2015, though this only delays the loss of jobs and businesses.
In the longer term, determine what curricula meet California’s needs based on the ELAP analysis of tasks, competencies, and estimated hours to teach them. Continue to allow those entering the field to have adequate time to attain classroom hours by retaining a limited-time-validity conditional entry-level certification. This allows California to support real standards for education, gives the CAMTC flexibility to shape certification policy to support portability to other states, supports entry to the field, and supports continued relevance and viability for independent schools.
In summary, the solutions we propose:
Support meaningful heightening of standards for professional practice of massage therapy in California while offering more program flexibility.
Support the CAMTC in its effort to bring California into parity with other states to increase portability and state-to-state recognition for California Massage Therapists
Preserve California small businesses and jobs
Preserve access to new career opportunities for homemakers, veterans, youth, downsized-workers, and other Californians
We sincerely request the support of the Business and Professions Committee in helping to preserve businesses, jobs, and professional opportunities in California.
Thank you for your time and attention,
IMSAC MEETING MONDAY APRIL 29th, 2013
Hosted by McKinnon BTC in Oakland, CA
In BOLD are action items, if you are able to help with this task, please let me know asap.
As people were arriving, Selena opened the floor for questions to ask on our 11am scheduled call to the BPPE.
Selena mentioned many schools have asked her about the ability to benefit exam, financial ratio required for school approval, and site visits.
Joseph shared his experience of his site visit and dealings with the BPPE on the issue of enrollment and accepting college credits for ‘high school diploma or equivalent’
The BPPE had told him it was ok.
Julie Reynolds expressed concern with unannounced site visits since she is not onsite unless teaching and student records are not on site. She would need notice to bring them to a site visit.
Patricia Cramer had an unannounced site visit.
Laura gave a general explanation of the BPPE structure and two year process of gaining full staffing and providing training for various divisions.
She shared statistics on how many applications have been accepted and processed. They have a large back log still, particularly for reapprovals. These may take up to two years for review. They are admittedly still experiencing a steep learning curve with regard to applications and site visit compliance. they have reconfigured organizational structure to alleviate this.
Main issues they are looking for are falsified information and quality education happening.
Most common complaint is lack of quality education. 19 cases are being reviewed by attorney generals office.
They will be revising regulations in bill 2296 to be reviewed this fall and implemented by next summer. This will be a process we should be involved with. This will include the metrics required by the SPFS and revise what is meant by gainful employment.
Joyce facilitated the conversation and asked about the Ability to Benefit Exam and whether it would be valuable/worth while for IMSAC to draft their own to try to get approved. Laura did not seem to think was worthwhile. However, primarily because they are so back logged, it would not be something they would be able to participate in in any way.SHe reminded us that the test has to be administered by a third party and needs to be done currently and by an approved test. Many people expressed the irrelevance of a standardized ABE to massage education. We were reminded that it does not matter to the BPPE.
Joyce then asked about the financial ratio needed to maintain BPPE approval of 1 to 1.25 Assests to Liabilities. This is set in stone and she was clear that if a school did not meet that criteria, they would discuss teach out options for school closure. Laura did add that we may turn in updated financials to prove things had improved. Financials are required by the BPPE at the renewals and anytime they deem necessary.
Keith began his comments as our representative from CAMTC with the reminder that the first 250 hour tier can be achieved with education from more than one school. This was effective Jan 1, 2013.
There was some discussion around National Certification and how the requirements and functions have changed. People can still take the exams they offer, but it no longer is offering Certification at the 500 hour level. This is very important to be telling students and informing staff so they can be giving people accurate information.
CAMTC will sunset at the end of 2014. Keith and Beverly May are beginning the sunset application soon and will keep us posted on how that process goes. It is very important to remember that the future of CAMTC relies on its success. They will be providing metrics to the state regarding the CAMTC and providing rational that it should stay intact. IMSAC will be drafting a letter to Bill Gage indicating our preference that the CAMTC remain intact and continue providing the 250/500 hour tiers.
We will also draft a letter to CAMTC to make the language on the website clear for students, grads, schools and everyone else that we do not know what will happen after 2014. As it reads now, many people are understanding the website to say it will undoubtedly moving to 500 hours. This is extremely misleading since schools are recreating programs based on this and students are unclear as to what will be required.
Keith mentioned that with the renewal of the CAMTC, should the 250 hour tier be dropped, there will likely be a similar ‘grandfathering’ clause as we saw when CAMTC originated. This would give people time to move to 500 hours and not be drastic. He added that it will be likely to see Certification require an exam (MBLEx or one of the NCBTMB exams http://www.ncbtmb.org/
sites/default/files/files/ 2013_Licensing_Clarification. pdf)
If the renewal is accepted, there will be no gap in the certification process. If it is renewed, it will be for 5 years.CAMTC is “fighting for its life” and will need to make compromises. IMSAC needs to decide what we are willing to stand behind, and what we would oppose.We have a new website! Please visit imsac.org and send revised contact info and a logo. Also, if there is anything else you would like to see on there, let me know.If you can please link it to your website, do so. If anyone would like to create a logo that would be great. Deidrea and Doug from Healing Arts Institute have graciously agreed to make website updates. THANKS!!!!!!!!!!!!!!!We finished with a discussion around IMSAC’s mission and goals. We are looking to develop shared documents for schools to give students including SPFS, enrollment agreements, FAQ’s on accurate information for tests, certification, etc..We are looking to hear from those who were not there about what you would like from IMSAC membership.We are also looking to develop a Code of Ethics that all schools abide by and will demonstrate our commitment to offering quality education as our main objective.We gained an Officer – Joseph Carter of the Acupressure Institute.Our next meeting will be this fall in October.Thanks everyone for participating in IMSAC! If you see anything missing – please let me know!!!SelenaPOST MEETING UPDATE FROM KEITH:(Doug & Diedrea, can you add this a news item on the website – interesting since I learned this after we spoke this afternoon)I happened to be searching on the ACCET (accreditation agency) website and came across these “final” regulations from the Department of Education on Ability to Benefit. Interesting, in that they do seem to have the 6 semester hour qualification. If the intent of the state law was to follow the federal regs, that that’s a done deal.(might be something to forward to Laura)…Keith
Ability-to-Benefit (ATB) Examination
California Education Code (CEC) §94811 defines an ability-to-benefit (ATB) student as a student who does not have a certificate of graduation from a school providing secondary education, or a recognized equivalent of that certificate. Under CEC §94904 (a), an institution is required, prior to executing an enrollment agreement with an ATB student, to have the student take and pass an independently administered examination from the list of examinations prescribed by the United States Department of Education (USDE).
Alternative to the ATB Examination
CEC §94904(b) authorizes the Bureau to approve an alternative examination if the USDE does not have an approved examination relative to the intended occupational training provided by the institution. An institution seeking Bureau approval of an alternative to the ATB-test should submit, in writing, the proposed alternative test, evidence that the USDE-approved examinations are not relative to the intended occupational training, and evidence of the relation of the proposed test to the occupational training program.
Please send the request to:
Bureau for Private Postsecondary Education
Attn: Ability-to-Benefit Alternative Review
P.O. Box 980818
West Sacramento, CA 95798-0818
In BOLD are action items, if you are able to help with this task, please let me know asap.
IMSAC is the curator of a way of teaching……….. join & enjoy!
IMSAC Meeting Minutes – Oct. 18, 2012
McKinnon Body Therapy Center, Oakland, CA
Chair – Selena Lee, McKinnon BTC
Minutes – Doug Blanc, McKinnon BTC
Action Items are in Bold Italics.
Present: Madonna Polley – Fair Oaks Massage Institute, Keersha Winds – Jupiter Hollow School, Patricia Oberg – Sebastopol Massage Center, Keith Grant – CAMTC, Cole Cormer – World School, Joyce Reim and Willy Harbour – School of Shiatsu and Massage, Kenneth Grisales – Monterey Institute of Touch, Jeanette Forester – Hendrickson Method Institute, Selena Lee, Carl Johns and Doug Blanc – McKinnon Body Therapy Center
Board Check-in by Selena Lee:
– James Mally, Kate Alves and Tobin Rangdrol are no longer on the Board. Selena Lee is the only person still on the Board – fulfilling all roles. By-laws allow for adding three more members to Board without a vote.
– No membership dues will be charged in 2012. Dues may be charged in 2013.
– New membership applications were distributed.
Check-in by attendees:
• Joyce Reim and Willy Harbour – School of Shiatsu and Massage at Harbin Hot Springs
Cleared their BPPE re-approval this year.
They have down-sized staff and classes to respond to smaller enrollment since 2009.
CE enrollments are up.
• Cole Cormer – World School of Massage
Have locations in San Francisco and Pleasanton and are in the process of opening more branches, including Chinese-speaking branches.
Are in process of audit by BPPE since May – first time they have been audited. They are awaiting site visit as part of audit.
They are noticing a slow down in turnaround time for CAMTC approval for their students.
• Patricia Oberg – Sebastopol Massage Center
Completed BPPE re-approval in March 2012.
Also noticing slow down in CAMTC turnaround time.
Now offer a 250- and 500-hour program in response to CAMTC.
• Julie – Massage Therapy Institute, Davis
No recent changes to programs.
Moved back to smaller facility to reduce overhead.
They have applied for BPPE re-approval and completed initial site visit.
They are finding that CAMTC misplaces transcripts.
• Keersha Winds – Jupiter Hollow School for Massage
They completed their BPPE re-approval in August 2012. They found BPPE to be picky, but helpful.
They need to stay on top of CAMTC to accept training hours.
They are hoping to add more info for students on their website to cut down on how much time they need to spend informing each prospective student.
• Madonna Polley and David – Fair Oaks Massage Institute
They have completed their re-approval and audit.
They have down-sized and moved to a smaller facility.
• Kenneth Grisales – Monterey Institute of Touch
Kenneth took over ownership in 2008.
He has seen an increase in enrollment for Advanced Program
They are in the process of re-approval; they received some corrections from BPPE.
• Jeanette Forester – Hendrickson Method Institute
Struggling to meet BPPE requirements. Their program is 200 hours.
Considering getting an exemption – their students often are already CAMTC certified and don’t need hours from approved school.
They are still approved as an NCBTMB provider.
• Selena Lee – McKinnon Body Therapy Center
McKinnon is up for re-approval in Spring 2013.
Keersha and Selena reported that more students are looking for 250 hours. Many students come in mis-informed as to what they need for CAMTC certification or even what CAMTC is. Schools are finding they need to speak to individual students for 45 minutes to one hour. Selena said that McKinnon’s monthly Orientation Evenings helps inform prospective students.
More students are getting their 250 hours initially and then taking their time to get to 500.
Selena reminded members that IMSAC is dedicated to preserving the choice that a diversity of programs offers students. Joyce asked if schools with Title IV funding are seeing a shift in their enrollment. Selena noted that there are no schools with Title IV funding thus far in IMSAC. Doug observed that NHI has seen a decline in enrollment since 2010 when CAMTC certification at 250 and 500 hours went into effect.
Kenneth reported that he had applied to be a VA approved provider and he was shocked at the additional paperwork and tracking required. Joyce found that being re-approved as a VA provider was simple since not much had changed since previous approval. Selena reported that McKinnon had applied and was denied, and that perhaps it is not worth the extra paperwork.
CAMTC Update by Keith Grant, IMSAC Representative to the Policy Board:
Keith led reminding members that CAMTC is a non-profit organization that issues voluntary certification. Certification exempts CMPs and CMTs from local regulation. And exempts establishments from discriminatory local regulation. CAMTC is a title act – meaning that it is illegal in California to use the title “Certified Massage Practitioner/Therapist” without CAMTC approval.
To date, CAMTC has completed 46,000 applications. Simple applications are processed in Sacramento. Applications that are flagged by Live-scan are sent to the LA office for investigation. Applications that are denied can be appealed by the applicant. Professional Services Review currently has around 800 applications under review for denial.
38,000 certificates have been issued – around 35,000 are current at this time.
CAMTC would like to keep the organization with few minor changes in order to improve chances of being approved for re-authorization after sunset in 2014. It is important CAMTC remain voluntary. If CAMTC is made mandatory, it will have to include Scope of Practice which would invite attack from Physical Therapists and Chiropractors who could kill CAMTC altogether.
Some changes to CAMTC:
SB 1193 has passed. It requires that all massage therapists or establishments not certified by CAMTC post an 8.5 x 11 anti-human trafficking placard at their place of business. Effective 4/1/13.
SB 1238 – strikes the word “single” school from the requirement of where school hours must be completed. 250 hours can now be completed at any combination of schools. 100 of those hours still need to be Anatomy, Physiology, Pathology, Ethics and Contraindications. Also the CAMTC can suspend a certificate if a CMP or CMT is arrested. Therapists have 30 days to appeal suspension.
Portal G has been amended to allow an applicant to become a CMT if they have 250 hours of training and completed an approved exam such as MBLEx.
There are four school representatives on CAMTC: Keith is one of them. Ben Drilling (CAMSA) is another. Information on changes to CAMTC comes down to schools through these four reps. CAMTC does not actively disseminate information on changes to schools. * In order to maintain Keith as IMSAC rep. on Policy Board, IMSAC members have to report a total of 1000 graduates among them for each of the last three years – 2009, 2010, and 2011. We currently have about 300 reported for each year.
CAMTC will sunset at the end of 2014. The 250-hour Certified Massage Practitioner tier is scheduled to sunset at the end of 2015. We have the opportunity to maintain the 250-hour tier beyond sunset if we are organized and active.
There is currently no talk of requiring CEUs to maintain CMP or CMT. In fact, very likely it will not be added.
CAMTC leadership is working with the League of Cities to address their concerns about certified therapists operating in their jurisdictions as prostitutes. Beverly May has been important in this effort. CAMTC needs the League to support re-authorization.
Ahmos Netanel will continue as CEO through sunset.
The next CAMTC Policy Board meeting will be in November.
Selena informed members that CAMBS had a list of 280 independent schools in California. That number in 2012 is 84. She reminded us that it is important for IMSAC to recruit more member schools to ensure that our voice is heard. Only we can represent small schools’ interests. IMSAC’s main concern right now is to maintain the 250-hour training tier.
Transcripts for CAMTC Approval by Bekah Hopkins:
Bekah reported that when sending student transcripts to CAMTC, schools must include a breakdown of hours for each class completed when students are applying for 250-hour Certified Massage Practitioner. Breakdown must include how many hours are Anatomy, Physiology, Pathology, Ethics, and Contraindications. CAMTC will not inform schools nor student if a transcript is incomplete. The onus is on the school to check the status of transcripts.
There was discussion of the issue that different employers have different requirements: Google requires the NCE, different Massage Envy locations have varying requirements – some CMP, some CMT. Many larger employers require 500 hours in order to narrow the field or to satisfy their insurers or reduce applicant numbers.
Selena raised the question: Should IMSAC be pushing for a sole 500-hour tier?
Kenneth thought it would be easier administratively to keep the two-tier system.
Madonna thought it was more difficult to keep two-tiers.
Joyce suggested that if all students were required to get 500 hours, all schools would be in the same position.
Keersha said her school only has a 251-hour program. She would have to change everything.
Some suggested it would be ideal to keep the 250-hour tier but add a CE requirement.
The consensus was IMSAC should continue to advocate for the two-tier system.
There was some discussion of the NCBTMB’s decision to increase requirements to 750 hours of training and to switch to the term “Board Certification” and phase out “National Certification”. Remains to be seen what the change will to do their membership. Not much change for California.
BPPE Update by Selena Lee:
The Advisory Committee met on 10/15/12. The Bureau is now fully funded and fully staffed. A draft of the 2012- 2015 Strategic Plan is available on the BPPE website.
The Advisory Committee will recommend to the Bureau to approve a reduction of STRF fees from $2.50 per $1000 of tuition to $.50 per $1000. The Bureau is expected to approve and go into effect 1/1/13
AB 2296 is due to go into effect and is undergoing clarification of language. The bill will require more detailed reporting of 4 disclosures to students, including: accreditation status, cohort default rate data, job placement success in the field, and salaries for graduates.
Keersha reported that it is very difficult to get graduates to report what they are earning. Joyce added that it is difficult to produce accurate reports from such a small sample size. Kenneth said many schools just report 0 rather than try to chase down grads to get stats. Selena proposed that IMSAC come up with a standard Student Fact Sheet to comply with requirements of AB 2296. Schools could then just input information. The members agreed.
BPPE reported that many schools are being cited for not having proof of HS Diploma, GED or proper Ability to Benefit tests on file for their students. Ability to Benefit tests cannot be conducted in-house, but must be administered by a third party such as Wunderlich for a substantial fee. Selena proposed that IMSAC develop a massage-specific ATB test approved by ABMP. Joanne Wenzel has indicated that BPPE will probably accept a standard test approved by a third party. The members agreed.
Selena called for volunteers to join the Board:
Madonna said she is willing to offer help with the ATB or the website but not commit to a position on the Board.
Next IMSAC meeting will be in March or April (after the CAMTC meeting in February).
Keith will report a list of cities that require CAMTC to practice and a list of cities we are struggling with to accept CAMTC.
Treasurer Report – IMSAC currently has just over $2000 in the bank.
Dear School Members,
I recently learned some disturbing news. I heard through the owner of a hypnotherapy school that audited financial statements are required with our annual reports!This is in addition to having to submit audited financial statements every five years with our re-approval applications. This will cost schools $10,000 – $15,000 per year! I called the Bureau for Private Postsecondary Education and spoke with Diane McKernon and she confirmed this news.
Diane also said that Joanne Wenzel had received my letter regarding audits, and that there has been a lot of concern expressed about the audited financial statements. In that letter I asked if the regulations could be changed to allow schools making under $750,000 per year to submit financial statements done in accordance with GAAP (Generally Accepted Accounting Principles). Regulations from the previous bureau allowed that.
Diane said that new regulations will be published shortly, and that there will be a chance to comment on them. She implied that we may need to work with the legislature to get changes, as she was unsure if the Bureau could make separate rules for schools making less than $750,000 per year.
I also asked Diane if I had to have our re-approval application submitted 3 months prior to the expiration of our approval. She said that they had several calls about that, and that it is fine to send in the application just before the approval expires. There are even provisions for late applications, but that includes additional fees. Once the application is submitted approval is extended until they can review the application. At least that gives us a little more time.
I spoke with an accountant on Friday who quoted $14,000 to $15,000 to prepare audited financial statements. He said that the size of the school being audited wouldn’t make much difference to his quote, because the main costs have to do with the requirements of the audit. I thought that I could amortize the cost of an audited financial statement over the five years in between re-approval applications, but I am not prepared to pay that amount every year.
Career schools have to do regular audits, so this is not a big deal to them. The career schools have several seats on the advisory board to the Bureau, and it is in their interest to keep the requirement for audits, as it will put the smaller schools out of business.
What can we do?
1) Share this email with other school owners.
2) Contact owners of other small schools – hypnotherapy, cosmetology, bartending, flight schools, whatever. The more schools from different fields that are involved, the better it will be for us.
3) Contact your state assemblyperson and state senator. Here is a link for finding your representatives: http://tinyurl.com/3bsbxs You can also write Assembly Member Anthony Portantino who was the author of AB-48 that formed the Bureau. Try to meet with your representative if possible, and let them know the consequences of the bureau’s actions.
4) Send letters to the editor of your local newspaper and to anyone else who may have some influence.
Below is a sample letter you can use. Please feel free to change the wording.
James Mally, N.D.
Independent Massage School Association of California
New regulations in California are threatening the closure of many small vocational schools, impacting numerous industries from flight training, to massage therapy. The most pressing issue is that the newly formed Bureau for Private Postsecondary Education is now stalling on a critical decision that would require schools to submit audited financial statements every year to prove they are financially viable.
An audit of this caliber will cost schools over $10,000. This is far more than many small schools can afford, and will put them out of business. In the past, smaller schools making under $750,000 were allowed to submit financial statements that were done in accordance with generally accepted accounting principles. This costs schools around $500.
Numerous school owners have presented this issue to the Bureau, but so far the Bureau has failed to act. The Bureau has an advisory committee to help them with the new regulations, but the advisory committee consists of representatives of the career colleges. Is it possible they are stalling so that their competition will be put out of business?
The closures of these schools will not only affect the school’s employees and teachers, but will also limit the educational opportunities for thousands of Californians who seek career training at these schools. In the midst of the worst economy in many years and record high unemployment, can the state of California afford to put people out of work and take away affordable career training opportunities?
To get involved or learn more contact the
Bureau for Private Postsecondary Education
P.O. Box 980818
West Sacramento, CA 95798-0818
Also please contact your state assemblyperson and senator, and the author of the bill (AB-48) that formed the Bureau:
Assembly Member Anthony Portantino
P.O. Box 942849
Sacramento, CA 94249-0044
Tel: (916) 319-2044
Fax: (916) 319-2144
Board of Directors Meeting.
Approved minutes from 29 Oct with minor corrections (typos, …)
Further letters are being sent to Irvine, San Ramon, and Newport Beach. A letter was sent to the Mayor of Irvine from Gloria Negrete McLeod, Chair of the Senate B&P Committee, informing Irvine that the view of the legislature is that even charter cities must comply with the state preemption and that this was in accord with a verbal opinion by legislative counsel.\
CAMTC is considering hiring a law firm in Orange County (not yet determined) to provide a written legal opinion on preemption. Although the board is making every effort to work with cities and to discuss their concerns, seeking a legal declarative order from the courts is a possibility. Should any third party take-on a non-complying city via the courts, it is also likely that CAMTC would file an amicus brief.
There are now 15 staff persons processing applications, an addition of 9 temporary staff persons. They are now entering applications received on 20 October or later. As of 16 Nov, about 8350 applications had been received; of which 90% have been for the upper tier, 10% for the lower tier. This likely reflects an early bias toward south state applications, but I don’t have any actual data on that at this point. Current application processing starts are averaging about 50-60 per day, about 2-3 days of applications per calendar day. Staff expects to catch up in about 2-3 weeks. An application received now with everything looking valid and complete should take about 2-3 weeks to process. After catching up, such an application will take about one week. Flagged applications will take longer, depending on the reason for flagging. An applicant can check the status of their application on the CAMTC website. They will be emailed a login ID and password when their application is opened.
The board created a Review and Disciplinary Committee chaired by Rick McElroy, the BOD member representing the League of Calif Cities, and co-chaired by Beverly May. Then can add up to 5 other members. The committee will both review red-flagged applications and future disciplinary actions.
Portal G requirements (Massage Therapist by Exam and work experience) have required proof of experience by having the IRS directly send tax returns to CAMTC. This turns out to be both an expensive ($144) and length process. There is a shorter, faster (3 weeks) and free form, 4506-T that results in the IRS sending summary return information to CAMTC. The board voted to accept the 4506-T form in conjunction with a full return sent to CAMTC by the applicant. [It would be good to push this into also allowing W-2 forms and a statement of confirmation from an employer, but now wasn’t the time to enter what would be a lengthy issue].
The next meeting will be in person, at the Courtyard Marriott in Sherman Oaks on 10 Dec, 10am-4pm.
The 12 November Public Policy Committee was mainly devoted to answering concerns from cities and describing the policies for red-flagging applications by staff and re-routing them for more detailed cross-checking and processing. I’ve attached documents related to red-flagging and basis for denial that have been developed by CAMTC. These were from Committee chair, Beverly May, subsequent to the meeting. May mentioned during this meeting that an agency has been contracted to investigate schools flagged by local agencies as potential diploma mills. On the suggestion of one city, CAMTC will also check county court records on applicants. This are public records, generally available online. This check is motivated that cases involving prostitution charges are of plea-bargained into another category and don’t show up on DOJ records.
The CAMTC meeting on 29 October started with approving 3 past minutes. Minor typos and corrections. Board chair, Ahmos Netanel, at the previous phone-based meeting had expressed some frustration that the board had not been getting minutes for approval.
The board then moved on to the IMSAC application. That was interesting but we got seated. Mason Myers asked about the definition of “graduate”. Roberta Rolnick and Jill England (staff attorney) both noted that the implication was graduate from a program that had been approved by the BPPVE. Paul Swinghammer jumped on that, whether that had been verified for the claimed graduates, whether there was a privileged relationship between Bob Benson and myself (since I had been invited to the FSMTB organizational meetings), and whether IMSAC was a “real” organization. Jill England and others noted that verification of graduates at that level hadn’t been previously done. Jill noted that there was a signed application and that IMSAC had been filed with the state which was, from the legal standpoint, sufficient verification of organization. Roberta asked me about the purpose of IMSAC (unified voice, coordination of problems and solutions, pooling resources and knowledge in a changing academic environment, …). Mason Myer’s said that this was dragging on too much, and he was ready to move to place me on the board. I was voted on with no dissents and Swinghammer abstaining.
Ahmos Netanel brought up 5 problems facing CAMTC: CA Chiefs of Police (some hostility just from change), defiant cities (in particular Irvine, Newport Beach and San Ramon), customers still waiting, potential legislation from cities, management needs.
There was follow-up discussion on potential need for an executive director, either from AMG or directly hired. AMG has been swamped both with many more applications than expected and a large number of phone calls in which people had to be led through the web page (same people who otherwise would be processing applications). We (at that point) authorized a higher payment to AMG through Dec to enable them to catch up. They’ve had about 6000 applications in the first two months (August/September) versus a pre-estimate of about 2500.
The meeting had several guests from nearby cities (police depts).
The meeting went into closed session. Mainly on the basis and legal issues on denying certification and handling of suspicion of fraudulent transcripts.
Closing minutes, with spectators back in, were on approving immediate AMG
proposal for catching up and on starting definition of exec director.
Harbin School of Healing Arts
Membership in IMSAC is $100 annually and is open only to BPPE and CAMTC Approved Schools in California, and that have massage as their primary focus. Applications from schools on the CAMTC Pending list will be reviewed by BOD. If interested please feel free to download a membership application.
2940 Webster St Oakland, CA 94609