Tag Archives: nccaom

Middle of the End

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The opinions in this post are mine alone, and do not represent any organizations or associations with which I am affiliated.

The profession is in trouble. And as of the October 26 NCCAOM/ASA Town Hall even our leaders admit it. That last bit is new. But what isn’t new — as far as those leaders are concerned, there is only one way to save the profession. It’s their way. And it depends upon working LAcs to shut up about our concerns, and do what they tell us to do.

My experience with the ASA in the Spring 2020 was yet another reminder of the profession’s dysfunctional patterns. I believed (despite previous experience) that a mainstream Acupuncture organization was willing to transparently explore the risks and the benefits of a proposed course of action – in this case, of becoming Medicare providers – with the thought that in so doing we could prepare to mitigate the risks, increase the likelihood of benefits, and build consensus on a course of action.

Instead, at the 11th hour, after 100’s of volunteer hours from a group of individuals invited to participate, almost every mention of “cons” disappeared. A slanted pro-inclusion document was released, followed by a poll designed to tilt pro-Medicare. Still, support for the fight was, and continues to be, tepid. And rather than address or acknowledge the legitimate concerns of working practitioners, what we get from the leadership is exhortation and pressure.

This is a repeated pattern.The organizations choose a direction: increase hours of training, add credentials, become doctors, increase insurance coverage, fight other professions. It’s our only hope. Practitioners who raise concerns are ignored, sidelined, or attacked. When the success we were promised doesn’t arrive, it’s our fault. The organizations may change, but the song remains the same.

A year ago I was privileged to have lunch with Mina Larsen and I made the following request —

The ASA and NCCAOM have decided that becoming Medicare Providers is the only way forward. I keep being told that I have nothing to worry about, that I’ll be able to opt out and continue to practice the way I do now. As a way to show working professionals that you have our backs, let’s pretend the language passes tomorrow, boom. Can the ASA and NCCAOM prepare a document, “So, We Won, What Next?” Lay it out for us. What, specifically, do we need to do to Opt Out? Is it a one time thing? Can I change my mind? How does opting out impact my patients? If I want to be a provider, how do I sign up? Do I need to make changes to my record keeping? Are there any accessibility issues regarding my office? If I make errors in billing am I in any greater legal risk? What are the profession’s plans for lobbying on an ongoing basis? Won’t we need to prepare to fight rate cuts? What’s the budget for that?

(I’ve been asking these questions for a decade!)

So far, crickets. There hasn’t been any effort to help us prepare for what happens on the other side of “success.” Just as we’ve been left to fight with the insurance companies and devote more time and money to training.

Other thoughts while listening on the 26th —

– Has anyone explored how many LAcs are likely to choose to participate in Medicare? What percentage of the 50 million Medicare beneficiaries Mr. Taromina mentioned will LAcs end up serving? If other professionals provide more of the acupuncture treatments, could it speed our demise as a relevant profession?

– Why hasn’t increased insurance coverage increased LAc satisfaction and practice success? Is it true that increased insurance coverage hasn’t impacted non-participating providers at all? (It isn’t true, but that’s what we were told at the time, and now we’re being told the same about Medicare.)

– Is there evidence showing that treatments from LAcs are more efficacious than acupuncture treatments provided by others?

– The presenters raved about a future in which, in a pediatric oncology setting (a weird example for a discussion about Medicare), LAcs would treat not just physical pain, but also the emotions and spirit of patients and their families. Are third party payers reimbursing for treatment of emotions and spirit? Do practitioners feel that the time and visit constraints of third party payers impacts ability to deliver deep, holistic, treatments?

– Mr. Taromina mentioned that the lack of unity in the profession resulted in missed opportunities when it came to Covid, the opioid crisis and the ACA. What’s a specific thing he thinks we could have done differently? (I mean, sure, working together, but for what specifically?)

– Mr. Taromina said that no one has come to the leadership with “better ideas” about helping the profession. Why have suggestions to revamp our educational and credentialing process to create a shorter and cheaper path to entering and remaining in the profession been ignored? (I raised these ideas years ago, and I’m not the only one.)

Was the presentation on the 26th too alarmist? No. It might not be alarmist enough – “the profession” is in trouble, there will be consequences for most of us, and the only “solution” under consideration by those in power won’t help.

It’s critical for regulated professions to have healthy organizations and institutions and I’ve devoted huge amounts of time and energy to supporting these groups. Facing, once again, their lack of learning from the past and their disregard for the actual lived experiences of working professionals is painful as hell.

I have no suggestions about what we do next. For me, it’s time for a healthy boundary. There’s no point in continuing conversation with those who refuse to hear. I’ll save my energy for the treatment room.

Good luck to us all.

Medicare and Acupuncture: End of the Beginning, or Beginning of the End?

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The opinions in this post are mine alone, and do not represent any organizations or associations with which I am affiliated.

 

When I started this post in early June I wrote –

Join your state association. The states will be distributing ASA-developed Educational materials and a survey regarding Medicare inclusion soon.

I was honored to be asked to participate in the ASA Medicare Working Group developing the materials. My goal, as always, is to provide vetted information and analysis so that we can make wise decisions and be prepared for consequences. The ASA Board knows I won’t tolerate anything less. It’s concerning that the NCCAOM made statements that they’re already pursuing Medicare inclusion, but the ASA insists they won’t move ahead without the support of the community.

By mid-June, I was concerned.

There was an inexplicable urgency to complete our work. There had been no attempt to work with outside experts to get definitive answers to issues still up for debate. Academics have studied Medicare’s impact on medical practice and physician satisfaction, and there are lawyers who specialize in Medicare law. Why not give us the time to hear from them about the likelihood of an opt out, or whether we can really expect better reimbursement rates?

I noticed a double-standard as we debated which opportunities and risks to include on our list. But I reminded myself that perception wasn’t reality, and that the ASA doesn’t have a ton of resources. That preparing legislation would take time. I still believed the ASA was committed to an honest process and I told myself that the board would correct any bias when they received the document for review.

I was going to write that the process was challenging, and the document wasn’t perfect. But it was the result of a good-faith effort and everyone should participate in the survey.

By late June, I was distressed.

The slight pro-inclusion tinge had been amplified by the Board’s edits. Several changes were so extreme that two of us (given only a few hours to express our concerns) asked that our names not appear on the ASA-Medicare-Educational-Brief (in the end it was signed “The Medicare Working Group”).

I was going write about where the document fell short, and where it was wrong. I’d share my growing sense that the ASA BOD wanted the survey results to give them a particular answer.

I’d encourage everyone to watch the recording of the June 24th ASA/NCCAOM Town Hall, because all of the scrambling to sell Medicare inclusion didn’t completely obscure hard realities. (Sure you’ll lose a little money on every treatment, but you’ll make up for it in volume!)

By the first days of July, I was dismayed.

Perhaps the ASA BOD doubted they’d get their hoped for outcome? Suddenly, the most controversial issues were no longer a concern. We’d definitely get opt out, reimbursement rates would be better. The ASA Revised Medicare Educational Brief was rushed out, which shows only two potential risks of Medicare inclusion. The old survey and any responses were killed and a new survey was distributed. There was a new Town Hall, and now we were told that we had nothing to worry about. The ASA newsletter asked “Are L.Ac.’s ready to take their rightful place in the federal medical system and reap the benefits of being a recognized part of mainstream medicine?” Look, Ma, NO Risks!

Had they finally consulted with experts and gotten better information? No, the sources were the lobbyists – those who make a living from convincing others that what the lobbyist advocates for is a good thing. Incorrect information about settled issues (such as the proper use of Advanced Beneficiary Notification) continues to be circulated.

(Will the lobbyists accept a contract based on Medicare reimbursement rates?)

I surrender.

The NCCAOM has resources and the ASA has the power to speak for the profession. It seems clear that, at some point, they will pursue legislation to add LAcs to the list of Medicare Providers. If this survey doesn’t turn out the way they want, there will be another.

The more we become enmeshed in the mainstream medical system, the more we’ll need the money of the NCCAOM (our money) to protect us, the more we’ll need to support the ASA so that they can look out for us. The lobbyists will have job security. I’m not so sure about us.

My upset isn’t because I believe Medicare inclusion will be bad for practitioners and the profession, though I do. It’s because our leadership is selling us a fairy tale rather than preparing us for the challenges that await.

I was recently described by a member of the ASA BOD as a straight shooter with great credibility. Believe me when I say that the ASA Medicare Educational Brief, in its current form, is a slanted document that presents an inaccurate picture of what life will be like for LAcs as Medicare providers. If you answer the survey keep this in mind.

Good luck to us all.

Another NCCAOM Post. Sorry.

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I know, three posts in two weeks is too many posts. I need a break as much as you do.

My post last week was an open letter to the NCCAOM, so I think it’s fair to share the response from the Chair of the NCCAOM Board of Commissioners.

Dear Elaine,

It was nice to meet you at the CCAOM conference.  Thank you for your concern and dedication to our profession.  My apologies on the delayed reply and acknowledgement of your letter to the NCCAOM Board-I did not want to respond with only a cursory acknowledgement given the energy and effort of your letter.  I will share your letter with the rest of the Board of Commissioners.

That said, I do want to address some of the points you made in the letter.  I hope you will not take my comments as a dismissal of your concerns – I would simply like to clear up some misunderstandings. I am not able to address all of them in this moment, but I would like the opportunity to clarify in the future.  A few points:

-The CEO is not responsible for setting up recertification criteria- that process is done by the Recertification committee(again within the parameters of maintaining our certification).   Continuing education is a non-negotiable.  That said, it has been noted and suggested that the process be more streamlined.

-Exam content is driven by a specific process dictated by NCCA standards; it is acknowledged that the end result is an exam that weighs heavily on TCM.  That is a challenge that we continue to attempt to address.  We are always looking for new suggestions – within the parameters that we must maintain to keep our certification.  As was mentioned, there are budgetary considerations to developing additional psychometrically valid exams as well as the challenge of having enough practitioners to determine psychometric validity and objectivity.

-States that have added herbal certification to their licensing act have initiated that either through the professional association or the state regulatory board. We have not initiated this despite some of the rumors.

-With regards to stakeholder input: whenever possible and applicable, we do seek stakeholder input.  There are times where stakeholder input does not weigh in on a decision – i.e. compliance with new requirements from NCCA, exam validity requirements, ; and issues where we actively sought stakeholder input – i.e. the revision of the code of ethics, the herbal safety certificate creation, etc.

Thank you again,

Best regards,

Afua

Afua Bromley, L.Ac., MSOM, Dipl.Ac. NCCAOM

Chair, NCCAOM Board of Commissioners

I fear my frustration at hearing the same old talking points resulted in a brusque response.

Dear Afua,

Thank you so much for taking the time to respond. I appreciate it.

Will you be at the ASA meetings this coming weekend? I’ll be participating. If you will be attending, perhaps we’d have a chance to talk through these issues in person? In the meantime, I’ll share some thoughts.

Perhaps I shouldn’t take it so literally, but I don’t think there are any misunderstandings here. Perhaps my comments at the CCAOM meetings, and in my blog, could not thoroughly illustrate my  knowledge of these issues. I’m well aware of the complexities of the NCCAOM’s situation. We may certainly have some differences of opinion about what is possible, ideal, effective, or desirable, but I don’t think any misunderstanding is the issue.

Specifically, in response to your email –

  • I understand that CEO’s generally defer to committees for policy proposals. And yet it would be unusual if the CEO did not influence, to some degree, the work of the committee and decisions about how to refine, implement, or adopt committee proposals. In any case, I hope my letter, and the input of the profession as a whole, will be considered by the recertification committee. I agree that continuing education is a standard aspect of ongoing certification for health professionals and others. But the degree of involvement the NCCAOM has in approving classes, and the level of reporting it requires of Diplomates, is outside of normal practices. Requiring providers to pay you to have their courses approved raises questions about your motivations. I look forward to seeing how the committee can better align the cost to the profession of your system of approvals and tracking, with the benefit to the profession of such an onerous system.
  • I’ve heard, over the years, several versions of the “We realize the TCM focus of the exam is a problem, we share your concerns, we’d love to hear your proposals, but the NCCA guidelines, and budgetary constraints, mean we aren’t going to be able to do anything about it” response. If your understanding of the NCCA requirements you have been working under leave you seeing no path forward for a non-TCM based exam, wouldn’t it be more honest to acknowledge that? I can imagine several possible solutions – dropping the lineage based portions of the exam completely and leaving it to schools to verify that aspect of a student’s training, just as it currently defers to CCAOM for CNT testing, is one. I understand from those with more expertise than I, that the JTA used by the NCCAOM has significant flaws, so developing a new JTA would be another approach. Perhaps working with a group other than the NCCA would be helpful. I don’t believe there is no solution to this problem, but if those at the NCCAOM who are most familiar with the NCCA requirements don’t see any room for change, acknowledge that. Let’s not waste the time of others by pretending you’ll consider other options.
  • I was tracking the NCCAOM participation in the original DE licensure law in real time, and have media reports [An Example]from the time, showing Mr. Taromina actively pushing for the herbal requirement for all licensees. The professional association reported being persuaded by Mr. Taromina that the herbal requirement would be the best path forward. In Utah [We Have Met the Enemy], any investigation would have shown that the position of the professional association (no longer functional, I believe) was taken in response to one individual’s desire to retaliate against graduates of a particular school. The NCCAOM made no attempt to assess the position of the many Diplomates in the state who were unaffiliated with the professional association. And the NCCAOM has yet to offer any correction of the letter, written by that association and distributed by the NCCAOM, saying that the NCCAOM agreed with the proposed change. Last, but not least, the NCCAOM says it supports all Diplomates. If so, the proper participation of the NCCAOM in response to proposed regulation that would  eliminate licensure for Diplomates of Acupuncture would be a vehement renunciation of such efforts and a statement that it believes that Board Certification in Acupuncture is the only Certification that should be required for licensure.
  • In a recent example, the NCCAOM announcement of changes to testing procedures was met with expression of concern from stakeholders. In response, the NCCAOM made adjustments so that the changes would be less onerous to those about to graduate. Checking in with schools prior to the initial announcement would have meant those changes could have been made proactively, and schools would have been prepared for their student’s concerns. Clearly, there was some room for adjustment. There is not such a bright line between where stakeholder input is possible and applicable, and where it isn’t, as the NCCAOM repeatedly states.

Perhaps you didn’t notice the wish in my letter —  “that when concerns were brought to your attention you didn’t deny or evade or misrepresent what happened.” Your reply here contains all of the denials, evasions and misrepresentations I’ve heard before. As the saying goes, don’t micturate on my leg and tell me it’s raining. Don’t tell me that someone else is making you aim this way, or that budgetary constraints are to blame. It is possible for the NCCAOM to do better. The first step is owning the problem. I’m still waiting for that.

With hopes for a better future,

Elaine Wolf Komarow, LAc, Dipl. Ac.

The good news is that it looks like I will be able to talk with NCCAOM folks this weekend. I hope that gives me some good news to share. The bad news – it means there will be another blog post.

 

NCCAOM Issues – Here’s a Real-Life Example.

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Last week’s post generated lots of feedback – in the comments and elsewhere. Several people reached  out to me with stories about how their professional success was negatively impacted by NCCAOM policies or procedures.

An individual trained to be an acupuncturist wrote:

I graduated from an acupuncture school outside the country in November 2017. The NCCAOM requires that those trained outside the US must have their documents evaluated by a third party in order to apply and sit for the NCCAOM exams. As of November 2017 the NCCAOM only accepts documents evaluated by the International Consultants of Delaware (ICD).

In December 2017 I began my long ordeal with this organization. After 8 months of emails and phone calls going unanswered or minimally responded to with a form letter, I contacted NCCAOM to inform them that the company they were requiring me and others to use had appalling business practices that were preventing me from taking the NCCAOM exams, applying for a state license and starting a job that was being held for me.

Happily, I did get immediate help from the contact at NCCAOM. They intervened on my behalf and took my educational documents for their own review. However, I was then notified that I still needed ICD evaluation as the NCCAOM could not approve a “non-traditional” transcript. They also said they were not familiar with the school.

The school I attended has been graduating American students for over 15 years, and many have returned, successfully sat for the NCCAOM exams, and obtained licensure in the US. However, now it seems that the format of the provided transcripts are unacceptable; nothing has changed from the school’s perspective.  The only suggestions offered by the NCCAOM are not feasible, such as giving them the names and other personal information of past American students in order to compare what would be identical transcripts, my completing a 2 year apprenticeship (not acceptable for licensure in my state), or the school rewriting their program.

It has now been 18 months since I started this process and am no closer to being allowed to even apply for the NCCAOM exams. It seems incredible to me, and many others, that the format of transcripts, paperwork really, is all that is keeping me from fulfilling my dream. The NCCAOM has nothing to lose by allowing me to take the exams only the gain of my $1500. If I fail, then that is on me.

P.K.

 

The LAc who wants to hire P.K. wrote:

Dear NCCAOM,

As a licensed acupuncturist in practice since 1995, I have been saddened to watch the new generation of acupuncturists struggle with ballooning student loan debt and escalating practice requirements. The combination is eating away at our numbers. This acutely affects the public, our clinics, and those of us hoping to retire some day and pass our clinics on.

As an employer, I am immensely frustrated, because your practices are blocking me from hiring.

P. K. has been my clinic’s office manager, front desk staffer and clinical assistant for more than 3 1/2 years.  She is bright, committed, compassionate and skilled.  She excelled in her three years as a student at a well regarded European acupuncture school.  She comes highly recommended by the school’s president. She has been a delight and a pleasure to work with, continually exceeding my expectations, and our patients are very fond of her.

Meanwhile, I am busy, frequently over booked, and have been looking to add to my clinical staff, with no luck, for quite some time. There is a shortage of licensed acupuncturists in my area interested in a high volume, low fee, community style of practice. I offered P. a position as a community acupuncturist in early 2018, contingent on her obtaining a Massachusetts acupuncture license, and she accepted. Since then, I have been waiting, watching as she does what she can to obtain licensure, while the NCCAOM has been a roadblock in that process.

P. has spelled out in her own narrative the details of her efforts to get approved to take your exam.  When I reached out to you on this matter, we were asked to provide information on previous grads of her school who have sat for the NCCAOM exam — information that neither of us has any access to, but which no doubt, resides in your own files.

Consequently, P. has been left in limbo, with no path forward to practice in the US.  My clinic remains understaffed, and I have no ability to hire the person I’ve chosen, who is best prepared to succeed in this position.  Our state is unable to add a skilled acupuncturist to our numbers. It is all very frustrating, and sad.

A final thought — the whole idea of a licensing exam is to evaluate whether or not a graduate is prepared to enter the field.  If you trust your exam’s ability to function as it was designed, blocking graduates from taking the exam makes no sense.

D. D., Lic Acupuncturist

 

I (The Acupuncture Observer) do believe that requiring a combination of education and examination is the best way to increase the odds that a licensee will be a safe and effective practitioner. Folks with good study skills and an ability to memorize can pass exams without being able to apply what they know in practice. The NCCAOM exams can’t test whether a candidate can identify the signs used in diagnosis, for example. And, the schools have an incentive to say all of their students know enough to be practitioners.

I acknowledge that, for better or worse, the NCCAOM currently requires graduation from an ACAOM-accredited school, or an overseas equivalent. And that means they have to have some method of determining equivalence.

And, yet, is there no solution here? Is it really better for the public, or the profession, that a business and a community goes without the help it needs, while a well-educated and well-trained individual who wants to fill that need is sidelined, with an expensive education wasted?

I think the NCCAOM can and should do better. If they can’t, we need to allow another path to licensure.

 

Dear NCCAOM

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Dear Ms. Ward-Cook, NCCAOM Board of Directors, and NCCAOM staff:

The selection of Chief Executive Officer is a critical time for an organization. Continuity might be the primary goal when a business is thriving. When things haven’t been going well, the best choice might be someone with a fresh perspective and a willingness to shake things up.

As you know, the number of people entering the profession has dropped significantly. Without a change, the growing demand for acupuncture will increasingly be met by people who are not Licensed Acupuncturists. The profession we have worked so hard to build is at risk of becoming little more than a footnote, even while acupuncture itself becomes widely accepted. We must face this issue head on. Every decision made by our organizations must consider which choice supports growth of the profession, and which will contribute to our demise.

With such a small profession anything that divides us, or limits opportunities, is problematic. So is anything that inflates the cost of our education or entry to the profession. These all increase the odds that an interested person will choose another profession, or, having entered the profession, will struggle to succeed.

Over the years, the NCCAOM has made a number of decisions that have, in fact, divided us, limited us, and complicated educational choices and entry to the profession.

I hereby request you select a CEO committed to change, so that the NCCAOM can be an organization that unites, and that removes any barriers for entry to the profession that are not necessary for the protection of the public.

Your new Chief Executive Officer should –

  • Understand that it is in our best interest that everyone who passes the NCCAOM exams finds it easy and inexpensive to obtain and maintain their NCBA (Diplomate) status. In the absence of any findings of unsafe practice, active status should renew automatically, and at a minimal cost. With such a small number of practitioners, we can’t afford to exclude any competent and safe practitioners from employment or licensure. As it is, significant numbers of Licensed Acupuncturists are excluded from job opportunities even after passing the NCCAOM exams. The current system of CEU verification is complicated, and has no measurable impact on practitioner quality.
  • Develop exams that test only what is necessary for safe practice, focusing on crucial tasks and red flags. No particular lineage has been shown to be safer or more effective than any other. Testing requiring knowledge of one specific lineage adds to the cost of an education, complicates school choice, divides the profession, and increases NCCAOM expenses, all without benefit to the public. Since knowledge of a particular lineage is not required for competence, a Job Task Analysis focused on knowledge of a lineage is flawed and must be redesigned.
  • Fight any attempt to exclude any Licensed Acupuncturist from practicing to the limits of their knowledge and experience. The NCCAOM should never support efforts to limit, for example, the use of herbs to any subset of acupuncturists. They should be clear – the herb credential is optional, and acupuncturists without that credential should not be disadvantaged compared to all other individuals in a jurisdiction. Using resources gathered from Diplomates to support efforts to limit their practice feeds resentment and division. The addition of requirements for the herbal credential limits opportunities for practitioners, increases barriers to practice, and increases educational costs.
  • Ensure that the NCCAOM changes policies or procedures only after extensive consultation with all potentially affected parties, allowing us to minimize and mitigate harm. Changes that lead to additional costs or stress to students, schools, and licensing boards work against success and growth.
  • Prioritize execution. User friendly and functional portals are important. So is accurate information. Errors (such as incorrectly reporting licensure requirements) can have a huge impact on educational choices and employment decisions. For practitioners who have a choice, a frustrating hour spent fighting with the recredentialing process can be a deciding factor in whether or not they maintain active status.
  • Keep the focus on the core of the NCCAOM’s mission – ensuring the safety of the public through credentialing Acupuncturists. Lobbying costs money. Taking a position on a matter of politics leads to division and disappointment. The NCCAOM needs to minimize expenses for Diplomates, not use our money to fund activities that we may not support.
  • Leave education to the schools. When the NCCAOM develops educational programs, such as content for the CHCS COQ, it increases concern that the NCCAOM could one day move to make this certificate mandatory due to self-interest. Likewise, the approval system for CEU’s adds to the cost of classes and complicates maintaining certification. This system has no discernible benefit to the public, and stands in marked contrast to the practice of many other credentialing bodies.

I’ve held NCCAOM certification for the past 25 years. I have spent decades as a Board member – of my State Association, State Regulatory Advisory Board, and even the AAAOM. I know that many of my colleagues are quick to demand action, resistant to reconsidering their positions on issues, and eager to place blame. I know it’s frustrating to work hard to give people what they want, only to be criticized for your efforts.

I write now as a Licensed Acupuncturist, and do not speak for any other group or organization.

The existence of a national credential was a great help during our efforts to establish licensure in Virginia in the early 90’s. Over the years I have defended the organization countless times. But when I last renewed my board certification I had to grit my teeth.

As it stands, I’m no longer clear that the NCCAOM is a net benefit for the profession. I don’t trust you to look out for my best interests, even though I’ve been a Diplomate for all these years.

I would like to be able to defend you again. I’d like to know that you had my back. That my fees weren’t being used exclude me from practice. That lapsed status wasn’t keeping colleagues out of the profession. That your exam didn’t require people to learn a lot of information they’ll never need to practice safely. That my fees weren’t being used to fund futile turf wars. That the information you provided could be trusted. That your systems worked. And that when concerns were brought to your attention you didn’t deny or evade or misrepresent what happened.

It’s time for a CEO who understands the changing landscape, and understands that without a change in direction there will be no profession left to protect. For the sake of the profession, and the future of all of us associated with it, I hope that you choose wisely.

 

Sincerely,

Elaine Wolf Komarow, LAc, Dipl.Ac. (NCCAOM)

 

 

The NCCAOM Replies

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In early August I received a comment from Mina Larson of the NCCAOM in response to A Feature or a Bug. I approved it, replied, and now, with a bit more time, will give it a closer look.

I always encourage those who disagree with my posts to share their thoughts in the comments. I moderate to limit rudeness, screeds, and ad hominem attacks, not viewpoints. I’ll run guest posts, though I admit I’m more enthusiastic when the guest is a voice that doesn’t already have access to various other megaphones.

As I wrote in About Me,

” I continue to do my best to serve the profession and the public by encouraging a deeper exploration of the professional choices we are making. This blog is an effort to provide a forum for the dialogue necessary for our success.

All of my writing for The Acupuncture Observer reflects my own opinion.  I do not speak for any organization or board and am not representing any group here. I apologize in advance for any mistakes. Please let me know of any errors so that they can be corrected.”

Now, Mina’s comment (in italics), and my responses:

Elaine, it is very disappointing and alarming that you do not share with your group the many times I have communicated with you, informed you and updated you on updates on and rationale for proposed and new policy decisions – even our decision to not move forward proposed policies when we received input from our Diplomates (you were one of them) regarding a PDA and eligibility proposed policies a few years back. You also conveniently forgot to mention the fact that we delayed our linear testing (that we have to do to stay complaint with adaptive testing) and pre-grad elimination (also to stay compliant [sic] for our accreditation) based on stakeholder input. Please see NCCAOM Student Webinar: http://www.nccaom.org/nccaom-webinars-posted/student-webinars/

 

Mina, I have been unclear on whether all of our discussions are “on the record.” In several cases I have not shared our communications as I was unsure what was official NCCAOM policy. I’ll do better in this regard in the future. In many cases our discussions have not changed my assessment of the situation. Some of our talks were a factor in my feeling that the NCCAOM talks out of both sides of their mouth. I did not “forget to mention” to the times the NCCAOM has changed or delayed changes in response to input, I specifically refer to it. I even include a link to the announcement of the delay in linear testing, as well as an additional post (June 5th) reporting on some changes.

You continue to also bring up the NCCAOM testimony in Utah, in which I have provided information about our Chinese Herbology exam and requirements upon request by the Utah Advisory Board of Acupuncture. We testify at state hearings upon request from state regulatory boards and state associations to provide information about our standards and our exams. That is what credentialing organizations do! The herbal exam is one of our requirements for OM Certification and if you listen to the testimony at the Utah hearing, we provided information. We did not “side” with any group during that meeting. I had several meetings with groups opposed to and for the CH exam. We do not “pick and chose” what hearings we should go to – we are there to provide information about our standards and exams and to support our Diplomates in that state. How do you think there are now 47 states that have a practice act for acupuncture? We have been involved with helping a majority of these states to develop a practice act. How convenient you leave this info out.

I included a link to the entire testimony in the post about Utah. In that post, I include a link to a letter (UtahNCCAOMletter), distributed under the NCCAOM’s auspices and letterhead, showing that the NCCAOM supported the position of the state association and regulatory board to require the herbal testing. Although, in discussion, you told me that the letter was a mistake, the NCCAOM has not done anything to correct record. If the profession is confused about the NCCAOM’s position, that is on the NCCAOM. You and I went through that post word for word. In the end, the only place you could quibble with my writing was that my statement that the NCCAOM was unwilling to reconsider the hourly requirements for sitting the test did not include your position that that change was not within the NCCAOM’s purview.

In the interest of space, every post leaves out all sorts of history. Overall, I have often expressed my appreciation for the hard work of the NCCAOM.

Yet some people want to blame the NCCAOM for any problems with the profession. They want to point out that we moved to DC from Florida, but leave out the fact that not one dollar was spent on “moving employees”. Any employee who moved to the DC area from Florida, paid their own expenses. It is very disturbing to see people making false assumptions and publish information that is not validated. We did not invest, lease or buy headquarters, in fact, we are sharing our space with other associations in DC so that we can give those funds back to our Diplomates through our advocacy and PR work for promoting them and our profession.

I can’t be held responsible for what “some people” think. I have often defended the NCCAOM. I have not concerned myself for one second about where you are moving and how much it is costing. It’s an insignificant issue in my book. The NCCAOM has a MONTHLY column in Acupuncture Today, and the ability to mail or email every single Diplomate in the US. If you can’t make your case to “some people” I hardly think I’m responsible.

Now the gossip continues by assumptions that we go out and testify on selected issues, when what we do and have always done is testify and provide support to state associations who need our help or regulatory boards who request our input on NCCAOM standards. How come you do not speak of the many times we have traveled to states to provide information to advance the profession and our work with the Bureau of Labor Statistics and the VA? You and others on this blog choose to ignore the information on our website and focus on assumptions.

I have often reported on the work of the NCCAOM in various states. Your work is widely reported in AT and in your news alerts. There is no need for me to cover it extensively, though I do cover it. I link to the NCCAOM website and publications regularly.

You seem to leave those details out! How come you publish our 990s but forget to reveal that Kory, I and other NCCAOM dedicated employees work around the clock to help our Diplomates? You even have my cell phone number and I have taken your calls weekends, nights, holiday, but you are on a mission to discredit the NCCAOM because there needs to be someone to blame for issues in the profession. Anyone can also take a look at our annual report on our website with our financial statements. In fact, if you were to look at the data from the last couple of years, you will see a deficit as we have invested to give back to the profession. If you want evidence, just contact associations in Kansas, Wyoming and others who received practice acts last year as well as associations like FSOMA whom we have helped over the years, just to name a few.

I don’t leave those details out. I am glad for your hard work, and have said so many times. I appreciate your willingness to communicate. The 990’s and annual report stand for themselves.

In is also interesting that you have also left out the PR and advocacy work that the NCCAOM has accomplished (please go to http://www.nccaom.org for this information) to advance the profession. I have learned in my 15 years of serving this profession, there are some amazing people that make a difference by collaboration, selflessness and hard work and some who will continue to point fingers, have agendas, and cause needless disruption at a time when we need to unify to strengthen our medicine and the profession.

I haven’t left any of this out. I agree that there are many people working hard to strengthen the profession. I too, have worked selflessly on boards, with associations, to increase collaboration and unity. My goal is never “needless disruption” and I am sad that you seem to believe that is what I am doing.

Many of us have worked to build a better profession. And, honestly, much has been done that has not served us well. We have created fault lines, left qualified practitioners with limited options (requiring the herbal exam of all practitioners is one example), and selected winners and losers among the varied lineages behind this medicine. My efforts have always been to help us learn from our past and from the experiences of other professions, so that we protect the public without unnecessarily limiting freedom to practice and without putting additional burdens on professionals who are struggling for success.

It’s too bad that within this medicine, which looks for balance and harmony, we have so much trouble negotiating our differences.

A Feature or a Bug?

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When a trusted business or organization screws up, it’s good to give them the benefit of the doubt. We all make mistakes.

I have trusted the NCCAOM. They were important to our acceptance as a legitimate profession. In 2014 I encouraged people to support a transition to their exams in California, hopeful that one national standard of entry would further the growth of the profession.

But I’ve noticed a pattern – the NCCAOM makes a big announcement and seems unprepared for the response. They scramble to address the upset, explaining why we don’t understand their good intentions or their difficult position.

I used to think it was a bug. They just weren’t as competent as I’d thought. And Acupuncturists mostly don’t understand their role and are quick to react.

But now I think it’s a feature.

We don’t understand their role because they talk out of both sides of their mouth – they say or do contradictory things depending on their immediate desire.

In the “NCCAOM Questions and Clarifications” document (released in draft format), their response to the reaction to the changes in testing policies, the NCCAOM writes:

“There are some policies where we may ask our stakeholders’ opinions and use that to determine policy.  There are many other policies where this is not appropriate because of the requirements of our accrediting body, fiduciary responsibilities (the fiscal health of NCCAOM), or impacts to public safety need to drive our policy decisions.  NCCAOM is not a membership organization, it is a credentialing organization. Examples of this include: the elimination of the apprenticeship-only route, elimination of the pre-graduation route, and the revisions to the NCCAOM® Code of Ethics and the Grounds for Professional Discipline. These are examples that our policies are driven by our NCCA accreditation standards.”

But the NCCAOM did ask for input on the Code of Ethics and Professional Discipline, and their revised code reflected that input.

And the NCCAOM did step back from some of their announced changes in response to concerns from stakeholders. Clearly they had some flexibility, and could have done this prior to their announcement.

And in 2016 the NCCAOM shared –  “Breaking News! New Membership Organization Announcement!” describing their “Academy of Diplomates.” The Academy Board is a subset of the NCCAOM Board, your NCCAOM recertification fees support this organization, and links on the Academy website take you back to the NCCAOM. No wonder we’re confused.

In “Questions and Clarifications” we read – “It is no secret that the number of students taking the exams, annually, has dropped dramatically over the past decade.” Their upbeat NCCAOM Spring 2018 newsletter doesn’t mention it, nor has it been a topic in their frequent Acupuncture Today articles. Study their annual reports and you can uncover the truth, but that isn’t the news they’ve been sharing.

Fewer people taking the tests means fewer new practitioners. Shouldn’t the profession give scrupulous consideration to any policy or regulatory changes that make it harder to enter the field?

The NCCAOM’s current honesty regarding their financial concerns is appreciated. It also demands that we reconsider their previous denials that money drives their policy positions. Their support of efforts to require the herb exam of all practitioners (UtahNCCAOMletter), and their complicated PDA system, make sense from a financial perspective, not from a safety one.

The NCCAOM denies that their exams shape our education. They say schools should not teach to the test. They also advertise, “It is recommended that ACAOM Approved Schools Faculty members sign up for [the NCCAOM] practice tests to familiarize themselves with the process.”

They dismiss concerns that a new voluntary certificate program could become mandatory. They simultaneously support efforts to make the voluntary herb testing mandatory.

Underneath it all is the refrain, the “NCCAOM’s number one priority and mission is to protect the public.” This is as it should be. But one insurer recently reported receiving 1-3 reports of harm per week, including reports of pneumothorax, burns, and infections. In a profession of, at best, 30,000 practitioners, shared between multiple insurers, that’s alarming. Is there evidence that patients in Maryland or West Virginia, where there is no NCCAOM testing requirement, are more likely to suffer harm?

With great power comes great responsibility. The NCCAOM denies their power and their responsibility, but they are the gatekeeper to the profession. They have us by the short hairs. Their denials aren’t believable.

I’ve given them the benefit of the doubt for years. I’ve explained away their errors as bugs and defended their good intentions. It’s painful to acknowledge that I no longer trust the NCCAOM.

They need to get a lot more honest and a lot more competent quickly, or we need to get serious about finding an alternative.

 

 

 

NCCAOM Updates and Links of Interest

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The NCCAOM has responded to community concerns about changes to their testing procedures.

Here is an explanation of why they needed to change to limited testing windows and delays in providing preliminary results, along with a statement that they will delay this change to 2020. They will also work with the schools to set the testing windows to coordinate with graduation dates. Please do read it so you understand why these (temporary) changes will happen.

And here is the FAQ regarding the elimination of the Pre-graduation eligibility route. The date for this change is still September 1, 2018, and the FAQ isn’t quite so transparent. I do understand that the NCCAOM has to treat all applicants the same. Under the current system students of ACAOM-accredited schools can begin testing prior to graduation, while those in apprenticeship or foreign programs can’t. So, that’s not right. But some of the supposed benefits in the NCCAOM FAQ don’t seem all that beneficial. The answer to Q2 doesn’t actually answer Q2. And could they address the problem with less disruption? Allowing all students to sit all but one exam prior to graduation might address some of the problems mentioned by the NCCAOM without leaving new graduates in limbo for quite so long.

Here are some interesting links in no particular order. The issues may not be directly related to the acupuncture profession, but affect the bigger ecosystem.

A Dark Side of Chinese Medicine

Results of VT Medicaid Pilot Project using Acupuncture

The Value of the Doctor-Patient Relationship

For Fun if You are in New York City

Increasing Tuition at For-Profit Schools as GI Benefit Grows

Healthcare for those with Disabilities

Family Physicians on Nurse Practitioner Scope

Occupational Licensing for those with Criminal Records

The Acupuncture Observer’s Odds, Ends, and Action Items

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I can’t keep up, so prepare for some less polished posts as I play catch up.

First, housekeeping —

I’ve been using the blog for essays and analysis and using The Acupuncture Observer and Acupuncture Regulation-US Facebook pages to share articles of interest. Follow those pages, and if the FB algorithm cooperates, you’ll get important background and stay on top of current events.

I kind of hate Facebook and may give it up one of these days. Subscribe (if you haven’t already) to The Acupuncture Observer blog by entering your email address in the box in the upper right (under the banner photo) of the home page. Don’t count on Mark Zuckerberg to show you what’s important.

I’m considering a weekly (or so) blog post with links to a selection of the articles I’ve been posting to FB. Good idea?

Regarding The Acupuncture Observer —

I am not a journalist. I am an acupuncturist with experience on the board of state and national associations and the state regulatory agency. I am also a news junkie.

I have a point of view.

That point of view is informed by my experience, research, insider reports, news, transcripts of meetings, etc. I link to supporting information. My opinions are not based on hearsay or one individual’s report.

If I am wrong, let me know. That’s what the comments are for. I moderate to exclude spam and to reduce unnecessary rudeness, not to shut down differences of opinion. Reach out if you’d like to run a guest post.

If the position of you or your organization is already widely known, and especially if you have ready access to Acupuncture Today or widely distributed organizational newsletters, don’t expect equal time here. You already have a forum for your positions.

I’ll issue a correction if you can show me that I’ve got faulty information. But just telling me that I’m wrong or stupid or “clearly don’t understand” isn’t helpful. Show me the evidence.

And, an Action Item —

The NCCAOM has recently announced changes to their testing procedures.

1)      As of this September, people will no longer be able to sit the exams before they graduate.

2)      As of 2019, the exams will only be offered during four 12-day windows. There will be two testing windows for foreign language exams and reinstatement exams.

3)      People will no longer get preliminary results immediately after taking the exams and will need to wait eight weeks to find out whether they passed. That will give people a week, at best, to register for and re-take any exams in the next testing window.

See page 11 –  http://www.nccaom.org/wp-content/uploads/pdf/2018%20NCCAOM%20Spring%20Update%20to%20CCAOM.pdf

Unlike some changes at the NCCAOM, I don’t blame a profit motive. Each change, in and of itself, has a reasonable explanation. But, the sum total of the changes will have a negative impact on the ability of recent graduates to obtain state licenses in a timely manner. Enrollment in ACAOM schools dropped 18% between 2014 and 2018. Meanwhile, the demand for acupuncture is growing. It’s a terrible time to drag out the licensure process.

I hope you will sign the petition. (The petition language incorrectly refers to regulatory changes. The changes are to NCCAOM policy and procedures.)

 

 

 

Eight mini-Posts for Eight Nights! First Night – Acupuncturists, Weigh In!

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The NCCAOM is looking for feedback on a possible Safe Compounding and Dispensing certificate program. I don’t work with herbs so I’m not considered a stakeholder, but please reply if you are eligible. My questions/concerns —

  1. Will the certificate be available to anyone or just those with an NCCAOM herbal credential? Practitioners often delegate herbal preparation to office staff, so staff might benefit the most from the training. Additionally, some excellent and well-trained practitioners aren’t able to sit the NCCAOM herbal exam due to the nature of their herbal education. Could they still obtain this certificate?
  2. Will this certificate result in restrictions on the practices of those without it? The NCCAOM has previously developed credentials promoted as optional, which have, in short order, become requirements.

There are many areas of practice in where some of us could use more knowledge and training. It’s nice to have a way to show that you’ve got some special training or skills. At the same time, we’ve got enough battles with other professions and within the profession, and too often new credentials lead to new fault lines and new tensions.

Share your thoughts with the NCCAOM if you’re a stakeholder. Let’s help them serve our needs and understand our concerns.