All schools wind up being rough for OOS applicants. Basically, w/ a 28, it's really important to apply broadly; no one school that he applies to will be particularly high yield or likely to let him in, but you're more likely to hit a dart board if you throw 30 darts rather than 15. (Yes, 30 might be pushing it... but really, apply at just about anywhere you could reasonably see yourself wanting to go to. This of course assumes that the costs of the secondary apps are not important to you; if cost is an issue, then you may have to be more careful about where to send.)
Also, while you probably have a shot at a few MD programs, it never hurts to add a DO program or two "just in case" if you don't care about the letters that go behind your name on the white coat.