Something seemed very wrong at the American Academy of Acupuncture and Oriental Medicine.

There was a locked closet with student files the registrar could not access.

There were students arriving for a Chinese-language-only massage therapy program, siloed off from the rest of the classes at the Roseville campus. Students who were sent off to "internships" at local massage parlors where some of their supervisors were unlicensed, some had prostitution arrests on their record, and few bothered to fill out all the paperwork the students needed for legitimate degrees, according to the Minnesota Office of Higher Education.

When state office investigators took a closer look in 2019, they found that seven of nine recent graduates of the Chinese Tuina Massage program had already had their massage therapist licenses revoked or deactivated for "ties to prostitution/trafficking." The other two were working for an employer that advertised on RubMaps, an unsavory site where patrons post explicit reviews of sexual encounters they claim to have had at massage parlors.

At least one internship supervisor was arrested for prostitution while investigators from the Office of Higher Education (OHE) were still finalizing their blistering 25-page report.

A national study of sex trafficking in higher education, released this month by the Seldin/Haring-Smith Foundation, found 18 schools, authorized by five different states, that appeared to bestow meaningless degrees on women being funneled into the sex trade — allowing those businesses to operate with a veneer of legitimacy.

Minnesota was the only state in the study that shut down one of these operations.

"OHE determined there is a theme of prostitution and/or human trafficking related to AAAOM students and/or internship sites," Betsy Talbot, manager institutional registration and licensing, concluded in the state's February 2020 report.

The school has a new name and a new location and a new owner now.

The renamed American Academy of Health and Wellness no longer offers massage classes. Its students continue to work toward advanced degrees in acupuncture and traditional Chinese medicine. None of the other degree programs at the school tripped any red flags for state regulators.

The Office of Higher Education report can't tell us what happened to the women who came here for an education and left with criminal records. It can't tell us if what happened to those women was negligence, criminality, cruelty or coincidence.

"Our jurisdiction is not human trafficking," Talbot said. Human trafficking is the jurisdiction of the Minnesota Bureau of Criminal Apprehension, which can neither confirm nor deny the existence of a criminal investigation into the school.

So Talbot's three-person office focused on the problems that were within its jurisdiction. Such as the institutional failures that could allow vulnerable people to be exploited under the guise of education.

In June 2020, the Office of Higher Education gave the academy's owner, Dr. Changzhen Gong, a choice: Sell the school or shut it down. Gong could not be reached for comment.

"Institutions are operated by people; people are not infallible; they make bad life choices, and that's when a regulator will end up stepping in to help correct it," Talbot said. "What's happened to your institution that it could be exploited for this purpose?"

Every other student at the school was on file in the registrar's office. Their transcripts, their class schedules, their tuition payments and student loans, AND the meticulous logs of their properly supervised clinical field work.

The records of the Chinese-language massage students — once state officials tracked them down to the locked closet in Gong's office — looked very different.

Incomplete applications, missing Social Security numbers, haphazard tuition payments and overpayments. Inconsistent record-keeping of grades and coursework and little evidence that anyone properly supervised their off-site internships. In one case, the training logs claimed a student worked nine hours straight without so much as a bathroom break. Supervisors are supposed to note meals and breaks, so students earn credit only for the hours they spend working toward their degree.

"It was in the shadows of the rest of the institution," Talbot said. "Why they made that choice, I'm not here to make that determination. But it was run outside the administrative controls you would expect from an [accredited] institution."

Under state supervision, AAAOM was sold to Dr. Xiping Zhou, a longtime practitioner of acupuncture and Chinese medicine who operates two schools in Wisconsin.

"One of the most important reasons why my wife and I decided to purchase the school is because we do not want to see AAAOM permanently closed, thus current students not being able to finish their degree and education," Zhou said last week.

Zhou is working to win back community trust by organizing open houses and offering discount clinics to anyone willing to experience an acupuncture session from a student intern.

The Office of Higher Education, meanwhile, is back at work, looking out for all the students enrolled in more than 200 accredited degree-granting institutions in Minnesota.

"I am not so naive to think that just because we have ended this pipeline that a new pipeline will not occur," Talbot said. "These students need credentials to get licensed in municipalities. Where are they going to get that credential next?"

In response to the Seldin/Haring-Smith Foundation report, the U.S. House Subcommittee on Economic and Consumer Policy asked the Department of Education to investigate just how many of the nation's vocational schools might be acting as illegal fronts for sex trafficking. To read the full report, visit:

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