Who Speaks for You?

ACAOM’s letter to the Department of Education regarding the proposed gainful employment rules begins —

On behalf of the Commissioners of the Accreditation Commission for Acupuncture & Oriental Medicine (ACAOM), and in partnership with the Council of Colleges of Acupuncture & Oriental Medicine (CCAOM), the National Certification Commission for Acupuncture & Oriental Medicine (NCCAOM) and the American Association of Acupuncture & Oriental Medicine (AAAOM), we write to offer comments…. Collectively, we represent over 33,000 students and graduate acupuncturists in the United States, and 56 colleges of Acupuncture & Oriental Medicine.

Are there 33,000 students and graduate acupuncturists? Where did they get that number? Do they represent me? Reading the rest of the ACAOM gainful employment letter confirmed it – their letter doesn’t reflect my position on the proposed rules, or on the state of the profession.

ACAOM‘s existence depends on the schools and a steady flow of students, CCAOM represents the schools, and the NCCAOM‘s income depends primarily upon new graduates taking credentialing exams.  Once these groups get their money the future of acupuncture school grads is of little consequence to them.

Of course they would make the case for maintaining the status quo, but they should not be telling the DOE that they represent me.

I’ve just sent this email to the ED of ACAOM (mark.mckenzie@acaom.org) with CC’s to the leaders of NCCAOM, CCAOM, and AAAOM (kwardcook@thenccaom.org; executivedirector@ccaom.comcastbiz.net; DonLeelac@gmail.com), and to ashley.higgins@ed.gov (of the DOE) and bduran@mpamedia.com (of Acupuncture Today) —

 

ACAOM’s May 23rd letter to the DOE regarding the proposed gainful employment rules includes this phrase —

“Collectively, we represent over 33,000 students and graduate acupuncturists in the United States.”

Neither ACAOM nor any of the other organizations mentioned represents me.

The only organization listed that even pretends to serve graduate acupuncturists is the AAAOM. Their professional and student membership is a thousand or so, optimistically, and they were not in partnership with you for this letter.

I am not surprised that organizations that profit off students and new graduates would write a self-serving letter avoiding responsibility for the number of acupuncturists struggling to pay off huge educational debt.

I am not even surprised that you would claim to represent me. But I am angry that you did so.

Unless you can provide documentation that you do represent 33,000 students and graduate acupuncturists please retract your statement to the Department of Education and make clear that you are speaking on behalf of your organization, which depends on schools and a steady flow of students to survive.

Speaking for myself,

Elaine Wolf Komarow, LAc

In coming weeks I’ll explore more of the distortions and spin in the ACAOM letter. But for now I hope you agree that standing by while these organizations claim to speak for us is a mistake.

Borrow my text or use your own, but, let ACAOM and the other alphabets know they don’t represent you — and make sure the Department of Education knows that too.

Acupuncture Careers

ACAOM gainful employment — This deserves its own post.  I don’t have the head-space to write such a post at the moment.  I don’t even have the time to fully read and digest this document.  The little bit I can digest is making me sick to my stomach. I’m betting some of my readers would like to dig into this. I’d love to hear what you think.

NCCAOM/Dry Needling/A Young Profession

A survey about the possibility of a new NCCAOM certificate in Facial Rejuvenation showed up a few days ago. The online conversations were a reminder that many of us are confused about the NCCAOM — what their role is, what we want their role to be , what their role “should” be.  The topic deserves its own post, but, in short, the NCCAOM is a credentialing agency. They design, administer, and maintain the process by which most of us are able to be licensed.  There are loads of consequences of their power within our profession, especially because we have not had, for some time, a truly effective or well-functioning national professional association.

There were many complaints that the NCCAOM hadn’t done more to “stop dry needling.” That, combined with yesterday’s urgent petition regarding legislation on the Governor’s desk in Delaware, made we think I’ve got to try, one more time, to explain where we are with the issue and why what we’ve been doing won’t work. My post to my alumni group is out of context, but I hope still worth sharing (somewhat edited for clarity) —

Since Dry Needling is the issue that keeps coming up as a major focus for the profession, I wanted to give a little more info about the “court rulings” in our favor.

The one that received the most notice and attention was the case in Oregon regarding Chiropractors and Dry Needling.  The outcome of the case was widely misrepresented within the acupuncture community. Various stories indicated that the courts said that dry needling was acupuncture or that it had been determined that the training programs were insufficient.  This was not the case.  You can read a fuller explanation of the outcome of the case here – http://theacupunctureobserver.com/a-practical-next-step/. The gist of the ruling is that dry needling does not meet the implied definition of physiotherapy within the Oregon code.

Other states have also had rulings (usually informal) from the Attorneys General stating that dry needling is not within PT scope.  These rulings have typically been much celebrated within the acupuncture community, but we haven’t been hearing what happens next.  For instance, some time ago Utah was celebrating such a ruling.  Since that time, legislation added dry needling to the scope of physical therapists.  Similar legislation passed in Arizona.  When the AG recently ruled that dry needling was not within PT scope in Tennessee, the ruling included phrasing that basically said, PT’s will need to address this legislatively, as was done in Utah.  (You can get the link to the ruling here — http://theacupunctureobserver.com/late-july-acupuncture-news/).  Illinois is another state where the AG’s latest opinion agreed with the argument that dry needling was not within PT scope, but where the PT groups are already preparing legislation for the next session.

There will probably be states where the acupuncture community is large enough and well-connected enough (and Maryland might well be one) where similar legislation would not be successful, but if you look at the numbers in most states, the PT’s (who also often have business connections with the medical establishment) are likely to prevail.

Today I received a notice of a petition regarding DE HB 359, adding dry needling to the scope of PT’s in Delaware.  HB 359 passed by overwhelming majorities in the House and Senate and needs only the Governor’s signature.  Among the “gems” in the petition – “Accordingly, HB 359 will potentially place the general public in significant danger of injury and harm due to unsafe and unqualified needle practices.”  There are about 800 PT’s in DE, and even more PT Assistants.  There are 45 LAcs.  The odds of the Governor exercising his veto are slim, the odds of pissing off 800 PT’s?  Pretty good, considering we’ve just stated they are putting the public in significant danger.  Interestingly, one of the authors of this petition is the same person who pushed for the requirement of the NCCAOM OM credential in DE, putting practice off limits to about 70% of US acupuncturists.  Isn’t it ironic that the profession’s self-imposed restrictions on licensure in Delaware have left the LAcs scrambling to block action by an overwhelmingly larger group?

Had LAcs been more willing to work with the PT’s from the start, I suspect that in many jurisdictions we’d have come out ahead.  We’d have built relationships and understanding and had some influence, perhaps, on how this modality is practiced.  By sending PT’s to the legislative fix (that’s what “we” said right from the beginning – if they want to do this they should do it legislatively) we’ve taken ourselves out of the process.  As they succeed with changing the law we’ve lost any influence on the procedure.

Of course, trying to work together might not have changed anything.  Professions (including our own) are universally unhappy about outsiders coming in to tell them what they should do and how they should do it.

I will add three things in response to the previous post.  1) While I appreciate the frustration felt by LAcs when dry needling and acupuncture are spoken about as being equivalent, hasn’t it been our insistence that dry needling IS acupuncture that led to this? Wouldn’t we be better served by clarifying the distinction between the two? (Of course, that would undermine our argument that we have a right to regulate the procedure.)  2) There are many cases of patients not wanting to report harm suffered at the hands of providers.  This happens among acupuncture patients too. Even LAcs can cause a pneumothorax.  3) The cease and desist orders can’t help but remind me of the stories from decades ago of acupuncturists being threatened with arrest for practicing medicine without a license.

It hasn’t taken long for us to go from being the scrappy upstarts just wanting to help people with a simple technique, and frustrated by the establishment that was trying to shut us down, to acting like the establishment.  We’ve got our ever-increasing credentials, and maybe specialties soon, and are increasingly able to participate in the bureaucratic system of figuring out which set of codes gets us a reimbursement we can live with. Now, in Maryland, LAcs can interfere with a citizen’s ability to choose what treatments they get from which providers, and can throw their weight around in the provider community.

PT’s will outnumber us for a long time to come.  It’s a shame we’ve pissed in that particular well.

 

Late July Acupuncture News

CCAOM has released two new position papers regarding Clean Needle Technique. (No mention on the AAAOM or CCAOM sites about this important news.)  We practitioners are responsible for knowing the latest standards for safe practice, so here are the new position papers on the use of gloves and skin preparation for your convenience.

 

NCCAOM has finally released the report on 2013 Demographics from the JTA survey. 52K as the median pre-tax income is not good news, especially since most of us get no benefits (no paid sick leave, no paid vacation, no disability or health insurance, no retirement savings plan). (Then again, many of us seem to be working part-time, often by choice. So maybe the figure isn’t so crazy?)  Math lovers among my readers — feel free to share what additional number-crunching reveals. I’m not a numbers person, but I’m pretty certain that the average income will be below the median income figure.

67% of respondents hold only the NCCAOM AC credential.  If this accurately reflects the overall credential distribution within the profession the states requiring the OM credentials are off-limits to 2/3 of practitioners. That can’t be a good thing. (I’m still waiting for someone to explain the public health issues that led to the upcoming change in FL. And I sure wish FSOMA and the Florida Board would do a better job of spreading word of that change.)  Do those with the OM credential have a higher median income to offset the additional education and credentialing costs? The NCCAOM should collect that data next time.

The NCCAOM survey is designed to gather information from acupuncture practitioners so there is no data on how many acupuncture school grads have left the profession. I hope the CCAOM will soon require schools to track those numbers.

 

The California Board came in for some media scrutiny recently.  If the extra attention helps eliminate some of the extra hoops (which equal extra costs) necessary to practice in California, it will be a silver lining. I hear there might be some trouble on the New Mexico board as well (no details, though). Have independent boards been a winner for the profession?

 

It wouldn’t be an update without a little Dry Needling talk. The vocal segment of our community obsessed with the practice hasn’t been crowing about the Tennessee AG Dry Needling ruling that IMT/TPDN is not within the current scope of Physical Therapy. (Thanks National Policy Group for keeping us informed!) No doubt the concluding paragraphs referring to a legislative fix, as happened in Utah, tempers the celebration. And while I’m on the subject, here is a legal analysis of the faulty argument that the use of acupuncture needles by non-acupuncturists is illegal.  Can we please stop saying that now?

I suppose this is enough to keep everyone busy for a while….

Acupuncture and Insurance

I keep hearing questions and complaints about insurance billing and acupuncture.  I don’t have an original post ready. This is adapted from an email exchange with some colleagues and thought it might be a good starting point for a conversation, despite the odd lack of context. But if you’ve been around for a while you can probably imagine what preceded it! (Then again, we should probably be out enjoying a holiday weekend rather than pondering our profession’s future.) —

“I am absolutely fine with practitioners pursuing all of the various business models that are available to us.  I want anyone who wants acupuncture to find a way to access it. Depending on both the practitioner and the patient, there may be certain models that are more appropriate or appealing than others.  Private room treatments at varying levels of cost with the money coming directly from the patient or indirectly via an insurance company, sliding scale models, in group or private settings, treatments as part of other medical care, I’m good with all of it.  I don’t believe that a patient’s willingness to make life changes is related to what they are paying for treatment. I don’t believe that lots of talk and time is necessary for people to benefit from treatment, though I believe it can have benefits.

“I do believe that lots of graduates come out of acupuncture programs with very little information about how to choose which model might be best for them or for the community in which they wish to work. I believe they often come out having been told some version of “if you build it they will come.” It makes me sad and angry when folks who invested so much in their education don’t have the business skills to make a go of it, especially when there are so many areas so underserved by LAcs.

“I don’t believe that fraud is necessary to make a living from an insurance based practice, and, I have seen many conversations about insurance billing for acupuncture that revolve around questionable practices. I certainly don’t think all practitioners engage in these practices, but some do. I also see practices that are by the book, but are still likely to have unconsidered consequences.  How many acupuncture treatments that are not billed to insurance involve three distinct sets of needle insertions, compared to those that are billed.  Does it take more sessions to treat back pain with acupuncture when the treatments are covered by insurance?  (Does the billing provider think of the treatments as being preventative once the back pain is in remission while the non-billing provider might not be thinking about back pain at all and instead pondering the client’s inability to relax even when on vacation?)  How do the answers to these questions impact data on the cost effectiveness of acupuncture?  As purchasers of health insurance, how do we feel if we think an MD is doing a more complicated procedure, with a higher reimbursement rate, than another, cheaper procedure that is equally effective?

“I did not mean to give the impression that offering a higher level of service when warranted will get a provider kicked out of a plan. However, if a provider’s patients consistently need a higher level of service that will get noticed by an insurance company. It may well be audited. And, it will be taken into account when the insurance company is deciding whether to continue to contract with a particular provider.  When you refer to this as an urban myth is it your position that insurance companies do not care whether a provider consistently bills for more services than other providers serving a similar population?”

Thoughts?

Talking about our Education

“We have over (2000 hours, 4000 hours, 3 years, 4 years) of education and they want to do acupuncture with (a weekend, less than ten, 200 hours) of training!The public is in danger.”

“The (PT’s, Chiropractors, MD’s) doing acupuncture are significantly undertrained! If they want to do acupuncture they need to go to acupuncture school, or at least take (400, 500,1000) hours of training.”

It’s a no brainer, right? But ….

1) We are comparing our total professional education to additional post-professional-degree hours.

An MSAOM curriculum includes: Biochemistry, Introduction to Organic Chemistry, Anatomy and Physiology, Microbiology, Introduction to Western Pathology, and a Survey of Western Clinic Sciences (3 semesters). M.D.’s have already covered these classes in their education.

2) Does the aspect of “our” medicine they want to use require a full TCM education?

Is Tai Qi, Qi Gong, Introduction to Botany, 40 credits of herbal medicine, a semester of auricular acupuncture and 3 semesters of point location needed for a PT to safely use a needle to release a trigger point? (If you insist they learn all of that, won’t they then argue that they can also do auricular acupuncture and distal points?)

3) How well-educated are most acupuncture school graduates? How worthwhile was most of their time spent in school?

ACAOM standards were based on the programs that existed at the time credentials were being established. They were not based on a careful analysis of what was needed to train safe, effective, successful practitioners. Acupuncture related Facebook groups include posts asking about using moxa to turn breech babies, how to treat TMJ (no pulse, tongue, or presentation information provided), and recommendations for treating people undergoing chemotherapy. With our thousands of hours of training, shouldn’t we know the answers to these questions? (Or have a better source than Facebook for answers?)

4) Is there a correlation between the length of a program and the quality of the graduates? Were the early U.S. practitioners (many of whom had less than 1300 hours of training) harming the public?

It is an article of faith in the acupuncture community — our training of X hours is necessary for safety, and anything less is an affront and a danger. Yet a colleague recently wrote “I am at a medical acupuncture conference. Exceeding my expectation. The presenters know their stuff. Lots of depth…. I am going to find out about their training. Maybe they are a special group….what i am seeing here meets any high standards TCM conference…. Very surprised.”

The more (as defined by us) = better has done us no favors. The numbers we fight for are arbitrary. The argument is easily refuted by other providers. Adopting it within our profession has increased the business strangling debt-burden new grads carry. And created internal divisions which only further harm our growth. (How long before a state (or the NCCAOM) demands the FPD to become an LAc?)

Please, let’s let the knee-jerk “less is dangerous, more is better” argument go.

Acupuncture in Louisiana

If a resolution is passed and no one is listening, does it still impact the profession?  Sadly, in this case, yes.

I wasn’t planning to write today, but then I came across Louisiana SCR 22 which has been moving through the legislature. It may have passed already (I’m trying to find out), though according to the information here it is still in a House Committee. (5/21, verified, this is not YET a done deal, there are still two opportunities for the resolution to be amended!) You may know that in Louisiana only MDs and DOs can be Acupuncturists.  An individual who has gone to acupuncture school or passed the NCCAOM exam can apply to be an “Acupuncture Assistant” and work under the supervision of an MD. This resolution would establish The Practice and Regulation of Acupuncture and Oriental Medicine Review Committee, and could have been a terrific opportunity to make the practice environment in LA more amenable to LAcs.  It gets off to a great start –.

WHEREAS, the practice of acupuncture and oriental medicine provides important health benefits to the residents of this state; and

WHEREAS, the practice of acupuncture and oriental medicine has become a well established, widely-used, viable modality across the United States; and

WHEREAS, when practiced as a whole medicine, by a fully trained practitioner, the practice of acupuncture and oriental medicine satisfies a missing niche that includes a prophylactic approach that allows the patient or a referring medical director a proactive avenue towards health when neither symptoms nor severity of disease warrants other forms of treatment; and

WHEREAS, oriental medicine often becomes a valuable way to identify those in need of a referral to a western medical provider.

THEREFORE, BE IT RESOLVED that the Legislature of Louisiana does hereby direct the Department of Health and Hospitals to create the Practice and Regulation of Acupuncture and Oriental Medicine Review Committee

But, look at the language for the committee membership  —

(1) The secretary of the Department of Health and Hospitals or his designee.
(2) The Senate president or his designee.
(3) The speaker of the House of Representatives or his designee.
(4) The executive director of the National Certification Commission for
Acupuncture and Oriental Medicine or his designee.
(5) The executive director of the American Association of Acupuncture and Oriental Medicine or his designee.
(6) The executive director of the Louisiana State Board of Medical Examiners or his designee.
(7) The executive director of the Louisiana State Medical Society or his designee.
(8)A chiropractor designated by the Chiropractic Association of Louisiana who is certified as a diplomat of the American Board of Chiropractic Acupuncturists or has completed equivalent training in acupuncture.
(9) A physical therapist designated by the Louisiana Physical Therapy Association.

 

So, eight members, including a DC and a PT, but no fully-trained acupuncturist. The AAAOM doesn’t even have an Executive Director at this point, and probably doesn’t have the funds to hire one, and in any case represents only a tiny portion of the profession.  The NCCAOM should be on our side, but their input in Delaware, for example, wasn’t positive for the majority of LAcs.  Once upon a time we might have looked to the PTs as allies, but our speech and actions regarding dry needling destroyed that.

I did send this Letter to Senator Mills today (which you can borrow from), but if the resolution is engrossed it is too late. The best we can do then is advocate for acupuncture friendly designees, make sure to stay in touch with the eventual appointees, and hope we can show them that the public would be served by allowing those trained as acupuncturists to be acupuncturists.  I’m sorry that this one got by me (I’ve got a practice to maintain), and sad that we don’t have a national organization to track and act on such things. AAAOM, where were you? I have high hopes for the CSA, but, without a state organization, Louisiana probably wasn’t on their radar. This was a missed opportunity.

Licensure News

Finally! At the May 6th Delaware Board of Medicine meeting two experienced and NCCAOM-credentialed acupuncturists were granted Delaware licenses, bringing the number of the LAcs in the state to just under forty. This is good news for the people of Delaware. It is also good news for the profession as whole. And hopeful news for the practitioners who are now commuting to Maryland, or not practicing, because they were unable to obtain a Delaware license.

Why did it take action from the MD’s on the BOM to get these practitioners licensed?

These LAcs had appeared before the Acupuncture Advisory Board four times since applying for licensure in late 2012/early 2013. At several of these appearances the Acupuncture Advisory Board members acknowledged the applicants’ excellent qualifications but refused to grant licenses despite having the authority to do so.

For decades one of our “sacred cows” has been that we need our own boards. Then we’ll have the power to control our destiny. Sadly, when given the chance, some of us prefer to control our destiny right down the tubes.

Consider the history of the independent California Acupuncture Board, with its unique accreditation and exam process, and its ongoing problems. Or Nevada, with an independent board, 53 LAcs, a $1000 application fee and $700 per year renewal fee.  If Delaware had an independent board my colleagues would have had to go to the courts to present the argument (made by a public member of the Board of Medicine) that requiring an herbal education and exam for individuals who do not want to use herbs in their practice, in a state in which anyone can sell and recommend herbs, is restraint of trade.

It isn’t the M.D.’s and “the system” that is limiting the growth of our profession these days. It is other acupuncturists. I’ve asked and asked, but I have yet to find anyone who can explain why the Florida (independent) Acupuncture board is increasing the education and testing requirements for licensure. Have patients been harmed? If a change is needed are there options that would be less burdensome for the profession?

I’ll be interested to see the full minutes of the May 6th DE BOM meeting. In a classic conjunction of issues, a practitioner instrumental in drafting the restrictive Delaware law, and a current Acupuncture Board member who had voted against granting licenses to the two qualified acupuncturists, appeared before the BOM to ask them to do something to stop PT’s from doing dry needling.

Did either of these practitioners consider that their previous actions that limit the number of LAcs in Delaware increase the odds that citizens will seek treatment from non-LAcs? Or that our political power is limited by our small numbers? Did the BOM wonder what’s up with this profession — they don’t want anyone to use a needle, even other LAcs?  (FWIW, the BOM doesn’t regulate PT’s.)

You’d think that our own self-interest would prevent the credential and educational creep that costs us so much. But it hasn’t. The AMA Code of Medical Ethics states “A physician shall respect the law and also recognize a responsibility to seek changes in those requirements which are contrary to the best interests of the patient.” Restrictive laws and rules that limit access to qualified acupuncturists are contrary to the best interests of patients. Let’s work for change – for the people who need acupuncture and the qualified individuals who want to provide acupuncture. Credential creep hurts us all.

Five Important Dry Needling Developments

Yes, more on dry needling.  More about education will have to wait.

Five things to know —

  1. The Oregon Ruling did not (despite the Acupuncture Today headline) determine that “Dry Needling is Acupuncture.”  For a full exploration of the case, read this post. In summary, the ruling of the court was that Dry Needling is not physiotherapy.
  2. On April 1st Utah Governor Gary Herbert signed HB 367, legislatively adding Dry Needling to the scope of Physical Therapists.
  3. On April 24th Arizona Governor Jan Brewer signed SB 1154, legislatively adding Dry Needling to the scope of Physical Therapists.*
  4. On March 25th Massachusetts HB 3972 advanced. This redraft of acupuncture bills HB 2051 and SB 1107 was necessary because the bill could not advance with the language that “dry needling is acupuncture.”
  5. At the end of April the Illinois Department of Professional Regulation issued an informal ruling that dry needling was not within the scope of practice for Physical Therapists “as the acts are currently written.”  That last phrase is important. From what I can tell there are about 550 LAcs in IL and over 9,000 PT’s.  The PT’s aren’t ready to call it quits. Time will tell if the victory for the LAcs is a lasting one. The PT’s could well look to Arizona and Utah and work for a legislative change.

(A colleague practicing in Delaware recently told me of the urgent phone calls and emails she’s been receiving — she must get involved in the fight against PT Dry Needling! Delaware is a state in which a few LAcs on the Advisory Board refuse to grant licenses to qualified acupuncturists. There are so few LAcs (less than 40) that they can’t maintain an association and citizens are far more likely to get acupuncture from a DC or an MD than an LAc. Now the profession wants to take on the PT’s? If there’s an urgent need for action from the LAcs of DE, perhaps it should be action to bring LAcs to the state?)

For those who insist we must do something about this serious risk to our profession, here are some suggestions. They would do far more to benefit our profession than this ongoing battle with the PT’s.

* One of the acupuncture profession’s strategies from the start of the Dry Needling issue was to argue, as the AAAOM wrote in their 2013 position paper,– “the addition of TPDN to physical therapy practice is being determined by physical therapy regulatory boards, deleteriously circumventing transparency and public health safety protections provided by standard legislative process.”  This was a mistake. Given the relative political strength of the PT profession and their MD supporters legislative victories are likely. Had we been willing to work with our health-care colleagues in the regulatory arena we might well have had input and influence in the use of this procedure.

A Call to Action

We have an opportunity to help Californians, and all acupuncturists, but we need to act now. As I’ve written before, states setting their own super-special requirements for acupuncturists seeking licensure is expensive and limiting for practitioners and the profession. I’ve never seen evidence that the public benefits from such requirements.

California has been one of the worst offenders. An exploration of the unique educational requirements can wait for another day, but we now have an opportunity to do something about the exam.  (Please note – much of what follows is based on my best understanding of the situation from respected colleagues in California.  I have not been personally able to fully research the California situation.)

The California exam has had problems for years, among the lowlights — a California Acupuncture Board (CAB) chair sent to prison for selling the exam; a point location exam shown to be so subjective that the State mandated that the CAB cease using it; incidents of extremely high failure rates and serious scoring errors; and CAB’s refusal to compare two exams for possible unfair scoring.

A recent Sunset Committee is turning up the heat on the CAB. Senator Lieu, the Sunset Committee chair, may support a bill that will allow potential licensees to take the NCCAOM exam rather than the California state licensing exam. It is time to let the Senator know that this change would benefit the people of California and all acupuncturists.

Please send emails this week to:

marty.block@Sen.ca.gov, ted.lieu@sen.ca.gov, tom.berryhill@sen.ca.gov,
ellen.corbett@sen.ca.gov, cathleen.galgiani@sen.ca.gov, ed.hernandez@sen.ca.gov,
jerry.hill@sen.ca.gov, alex.padilla@sen.ca.gov, lark.park@gov.ca.gov, Anna.Caballero@scsa.ca.gov, Denise.Brown@dca.ca.gov, Tracy.Rhine@dca.ca.gov, Sonja.Merold@dca.ca.gov, LeOndra.Clark@sen.ca.gov, kimberleywoo@sbcglobal.net, bluelotushealth@gmail.com, blueheartacu@gmail.com, crystal.clk@gmail.com, Spencer.Walker@dca.ca.gov

Some possible language —

I formally request that the Sunset Review Committee mandate that the CAB and staff use the national certification exam (NCCAOM) as the main exam for California Acupuncture licensure.

The NCCAOM exam is widely known to be a fair and comprehensive exam. It is relied upon in almost every state except California. Those practitioners who are credentialed by the NCCAOM have an excellent safety record. To require a unique exam for California, especially one shown to have ongoing problems, increases expenses for all California practitioners, costs which are ultimately borne by the public.

I urge you to require the use of the NCCAOM exams as the main exam for CAB licensure.

Thank you for your consideration.

We will all be better off when meeting one set of standards allows us to practice anywhere in the country. Changing the situation in California would be a wonderful step in the right direction.