Who determines your professional future? First, read An Example of one person, wearing two hats, limiting opportunities for LAcs. (He’s received honors for the work he’s done.)
We have one week to comment on the NCCAOM’s “proposed” policy changes. Do that here. Some of us think these changes are wise, some of us wouldn’t be personally impacted. We all should participate in the conversation. Ask your professional communities to comment. (You can see the NCCAOM’s response to my initial comments here.)
My follow-up comments are below. The NCCAOM is the most powerful organization in our profession. I have seen them, with our help, control regulation (or essentially subvert it) and legislation. Our interests may overlap, but don’t think your future is their primary concern.
Dear NCCAOM and Ms. Basore,
Thank you for your response regarding the proposed policy changes. Here are some additional questions and comments.
- You wrote “The Criminal Background Screening Program for new applicants will not take effect until January 2014.” Has the final decision to implement these policies been made?
- The Criminal Background Check and language requirements go beyond your mission as a “national organization that validates entry-level competency.” These policies usurp the role of state regulatory boards. (For example, Virginia exempts those serving certain communities from our language requirements.)
- Many states use the NCCAOM exams but do not require the NCCAOM credential. Establishing background checks and language requirements as part of the testing application circumvents those states’ specific desire to maintain an independent credentialing process.
- How many students responded to the assessment regarding the foreign language exams and what were their responses? Please define the demand “sufficient to offer a psychometrically valid defensible examination.”
- Is it significant to an applicant if the background check fee goes to the NCCAOM or to a third party? Could NCCAOM staff involvement ultimately increase exam costs?
- Can you describe the criminal background check appeals process? Would the NCCAOM risk legal liability if applicants were allowed to sit the exam upon appeal?
- Is there any documented case of harm from practitioners who had a criminal history at the time of sitting the exams?
- If public protection is the justification for requiring the background check prior to examination, should it be required prior to school admittance? This would protect individuals from making a huge investment in a career they will ultimately be unable to practice.
- Could the recertification process be simplified by trusting Diplomates to use their best judgment regarding continuing education? Has there been any documented patient harm as a result of unreviewed or unmonitored continuing education?
I believe that for much of the past twenty years the NCCAOM has provided a net benefit to the profession while honoring its commitment to the public welfare. More recently the NCCAOM has repeatedly acted out of self-interest, choosing control over the profession and the attendant financial rewards ahead of either the profession or the public. Your push for the full OM credential as a requirement for licensure in DE is a prime example of action that served the NCCAOM at the expense of all others. The stakeholder comment you request is routinely disregarded.
Re-consider these proposals. Acupuncture practitioners have an incredible record of safety. The imposition of additional de facto regulation is unnecessary and burdensome.
Elaine Wolf Komarow, LAc (VA)
NCCAOM Diplomate (Ac)
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