September 30th is the deadline to submit feedback on the NCCAOM’s proposed(?) policy changes. These changes will impact the profession and may impact you. Don’t be taken by surprise and don’t let the profession change without your input. Weigh in! (Why the question mark after the word proposed? Because according to the latest NCCAOM spotlight, the criminal background check is already in effect.)
There are Four Proposed(?) Policy Changes. As you prepare your feedback you will benefit from reading the NCCAOM’s Summer Newsletter for information on the NCCAOM’s role in the profession (which I will write more about soon) and for details of the proposed(?) criminal background check policy.
Here is my input to the NCCAOM (my email bounced back, so I’m sending via snail mail) —
As an NCCAOM Diplomate in Acupuncture, a member of the Virginia Advisory Board on Acupuncture, and a past board member of the Acupuncture Society of Virginia and the AAAOM, I share the following input on your proposed policy changes (which reflect my personal views and not the opinion of any board or organization)….
1) The public and the profession would benefit from requiring a reasonable degree of English proficiency of NCCAOM Diplomates. This goal is best met by requiring an intermediate score on the TOEFL or by other documentation of proficiency. The NCCAOM should continue to offer the credentialing exams in other languages. Many experts in this medicine were educated and trained in foreign languages. Many great scholarly works are not available in English and much is lost in translation. Continuing foreign language testing, while requiring documentation of English proficiency would ensure that NCCAOM Diplomates can communicate effectively with regulatory boards and the public, while also allowing the study of the medicine in the language which best serves the practitioner.
(Since writing this I realized that all of the language requirements fall outside the NCCAOM’s mission of determining competency. Language requirements should be left to the states.)
2) Based on the Summer NCCAOM News, input regarding criminal background checks for applicants is being requested after the policy change has been implemented. That is unfortunate. Reporting that the “appropriate” staff will review each case is not helpful. Who is the staff and what is their training? Is this policy change in response to specific failings of the current credentialing and licensing process, or is it a preemptive jump on the bandwagon? In the absence of evidence that harm has occurred that would have been avoided had the policy been in place it is unnecessarily invasive and potentially discriminatory and should not be implemented.
3) The PDA Provider Categories policy changes, especially the changes that seem to have been already established for 2015, will be detrimental to the profession and the public. While many professions trust licensees to obtain CEU’s useful to the needs of the practitioner, the NCCAOM’s increasingly restrictive policies seem designed to benefit only the coffers of the NCCAOM. I have not found NCCAOM PDA providers to offer a higher caliber of class or to provide the range of classes that would be most useful to my practice. I resent the degree of control the NCCAOM has over my continuing education through these changes and the hidden “tax” you will receive from every PDA point I earn.
These proposed changes contribute to my increasingly strong opinion that states should move away from requiring ongoing Diplomate status. (Since writing this I realized that because these policy changes impact who can sit the exams, getting away from the NCCAOM ongoing credentialing won’t address the issue. Until the NCCAOM ceases the standard inflation that has begun to feel like a shakedown, I’ll support states developing an alternate path to licensure that doesn’t depend upon the NCCAOM.) While I see the benefit in establishing a minimal level of education through the NCCAOM exams, your proposed policy changes work against the diversity that is an important part of Asian Medicine. Tightening the stranglehold on acupuncturists benefits neither the profession nor the public as increasing numbers seek our services.
Sincerely,
Elaine Wolf Komarow, LAc, NCCAOM 005020
The Sept 6 response from the NCCAOM, above in this thread, does indicate that these policies are in place no matter what kind of input we, as practicing acupuncturists, give. So what was the point of the survey?
I believe they are required to request comments from stakeholders as part of their membership in the NCCA — the group that accredits accreditation groups. (Too many initials around these parts!) Anyway, they request comments so they can say, see, we requested comments. I don’t think there is any requirement that they take the comments into consideration.)
“The criminal background screenings will be provided at a nominal cost and paid by the applicant directly to the vendor. The NCCAOM application fees will not increase.” So what if the additional fee doesn’t go to NCCAOM, it is still an unnecessary and additional fee for an applicant, effectively increasing the cost of certification. And does it duplicate what state boards are already doing?
“It is our sincere hope that this process will encourage all applicants to make public safety a priority and to assist in making the AOM community an integral part of the healthcare landscape for years to come.” How does this process encourage public safety? Is someone who is applying for certification going to say to themselves “Gee, I will applying for NCCAOM certification soon. I better not commit that crime that I was considering, in case they find out when they do my background check!”
And while we’re on the subject of fees, a Certification Verification by the NCCAOM costs a practitioner $35. Both my acupuncture school and my undergraduate school charge (or did the last time I checked) $5 for an Official Transcript. So, if an administrative person at the NCCAOM is being paid $20/hr as a very high-end estimate, that is assuming almost 2 hours of work time to send out a Certification Verification. The numbers just do not make sense to me.
If it costs $35.00 to look up and print out your certification, how much will an appeal of a background check finding cost? It is becoming clearer to me what a grave disservice we’ve done to ourselves by allowing NCCAOM to gain this degree of control over the profession. Unless I get some sense that the call for comments is part of a legitimate attempt to address the concerns of the professionals before enacting these proposals, (which I don’t get from the first response), I will certainly do what I can to get the states to consider an alternate avenue of licensure for acupuncturists.
Thanks for posting this article, and removing all doubt in my mind as to whether I wanted to cut a check to the NCCAOM for another 4 years of their blessing.
I understand the sentiment! I’m going to get a license in WVA while I still I can — one of the few states that doesn’t require NCCAOM testing. However, I must give you a heads up — the NCCAOM’s new policy on lapsed status means that if you allow your credential to lapse for more than 3 years, you will need to re-sit the exams in order to renew your credential. (And pay for them!) That means if life takes you to a state that requires the credential, OY! (I haven’t verified whether the NCCAOM will still report your test scores if you’ve been lapsed more than 3 years, but, I’m willing to take a guess :/
Thoughts on NCCAOM Policy changes September 10, 2013
Acupuncture Observer wrote: Unless I get some sense that the call for comments is part of a legitimate attempt to address the concerns of the professionals before enacting these proposals, (which I don’t get from the first response), I will certainly do what I can to get the states to consider an alternate avenue of licensure for acupuncturists
the following are tasks, questions that could be handled by more than one person and overseen by someone.
Mega/Overall:
Remind NCCAOM that their most important stakeholders are the people who pay their salaries, overhead, etc –
the licensed acupuncturists, OM, herbalists etc
and the acupuncture and herbal students who wish to sit for the exams
and others (International folks and those already practicing) who wish to sit for the exams
Other stakeholders: State licensing Boards who do not pay fees to NCCAOM (is this true?)
Is their assertion that the public is one of their stakeholders actually true? Is NCCAOM tasked with “protecting the public”? Isn’t this a duplication of what States, FBI, Police, NSA do?
Ask: (if not already in the public domain) NCCAOM to make their budgets and salaries, financial statements, IRS filings public knowledge, etc. known to all stakeholders.
How is NCCAOM run? Is there a Board of Directors? Are all stakeholders represented on the Board? If not, why not? If yes, how selected?
What is their mission statement? Who oversees them? What rules and regulations do they have to follow
Short term and on going for policy changes
(1) Ask them NCCAOM to put the proposed changes on hold. Remind NCCAOM that it is degrading and insulting to their key stakeholders to put policies in places without sufficient and fair vetting of such proposed policies. (see your quote above)
(2) Ask NCCAOM to come out with a detailed proposal: outlining the proposed changes and with supporting evidence of why these steps are needed.
The supporting evidence should include: needs statement (why do we need this, research that supports the needs , exactly how proposed policies will be managed, costs of implementation, etc. This should include how other licensed health care professions – MD’s, Nurses, Chiropractors, PT’s, currently deal with the same issues.
(3) NCCAOM distributes proposed policy changes with the detailed proposal to all stakeholders, asks for comments –
(4) NCCAOM tallies comments and then comes up with revised proposal and asks for a vote by stakeholders. This is what the Board of Directors of major corporations do for their respective annual meetings.
Comment: granted the above procedures are much messier than just being able to dictate policy – but the end result could be much better and less contentious for all
Sorry for the delay in posting this comment. I had hoped the NCCAOM would respond to my question about whether the comments they receive would impact their proposals, as that would help us know what actions might have an impact. Alas, they have not responded, so we’ll have to do our best to muddle through.
As far as I know, NCCAOM does not receive any funds from state licensing agencies. The money they receive is almost completely from folks applying to take tests/get the NCCAOM credential and the ongoing credentialing fees, as well as the cut they take from the PDA providers. However, it is difficult for any of these people to withhold funds from the NCCAOM — for most of us, without their credential, we can not practice. This is what I mean by, they have us by the short hairs.
The NCCAOM is a 501(c)6 group and, as such, their finances should be viewable. The do have a Board — you can find more about their structure on their webpage. Their mission statement is on their webpage.
They have made clear that they see they see the public as their “constituents”, not the profession. However, up until now, they have focused on protecting the public through verifying the educational attainment of practitioners. Getting into things like background checks seems to me like they are taking on a regulatory role that typically belongs to the states. By having these “proposed” policies control who can even sit the exam they are doing an end run around the states who have decided to depend only on the exams and not on the NCCAOM credential.
I think your path forward would make sense. However, the people who pay their salaries (Us) will lose our own salaries if we don’t keep paying theirs. The practitioners in any state that uses the NCCAOM exams (or who might ever want to practice in one of those states) are at their mercy. The only leverage we could have is to begin to change state laws to allow alternate paths to licensure. I’m all for that, but it is a heavy pull.
Ideally, our professional association — the AAAOM and the states associations would provide the counterbalance to the NCCAOM’s power grab. However, those groups either don’t see the risk or don’t have the resources or desire to get involved.
The NCCAOM has enough power at this point to ignore any contentiousness or upset. They can call the shots.
It’s a problem.
You can view the NCCAOM’s financials/form 990 by going to
http://www.guidestar.org/Login.aspx
and creating an account. You can then search their database for NCCAOM. The reports are there for 2009-1011.
Thanks, Neil!
Dear Ms. Komarow,
Thank you for your insightful comments related to NCCAOM’s proposed policy changes. All of the comments that we are receiving in the NCCAOM office will be reviewed by both the staff and the Board of Commissioners. You raise some very valid points of information that I would like to address.
1) As you stated in your email, English proficiency is important to ensure accurate communication between the practitioner and his/her patients, the public and regulatory boards. Communication protects both the practitioner and the patient in matters of safety and ethics. The NCCAOM conducted a needs assessment in 2010 to try and determine why the NCCAOM Foreign Language examinations (FLE) were so under subscribed. The assessment tool was translated into Chinese and Korean and distributed in all three languages to; accredited schools in the U.S. with acupuncture and/or Oriental medicine foreign language tracks, Asian AOM professional associations in the U.S., all government accredited Universities and Colleges in China and Korea with Traditional Chinese Medicine programs and all NCCAOM candidates educated outside the U.S. or living outside the U.S. The only respondents were students attending accredited schools in the U.S. with acupuncture and/or Oriental medicine foreign language tracks. The NCCAOM will always have the ability to offer the certification examinations in a foreign language and will do so when the demand is sufficient to offer a psychometrically valid defensible examination.
2) We appreciate your willingness to provide your views on the matter of background checks for new applicants. As a public protection organization, the NCCAOM’s mission and responsibility in the AOM community is to promote recognized standards of competence and safety. As noted in the Request for Stakeholder Input, screening applicants before continuing with any formal certification or approval process, allows us to immediately address situations that can pose a risk to the public. The Criminal Background Screening Program for new applicants will not take effect until January 2014. The criminal background screening services will be conducted by a Nationally Accredited and Certified provider of nationwide and international consumer data. The criminal background screenings will be provided at a nominal cost and paid by the applicant directly to the vendor. The NCCAOM application fees will not increase. It is our sincere hope that this process will encourage all applicants to make public safety a priority and to assist in making the AOM community an integral part of the healthcare landscape for years to come.
3) The NCCAOM PDA department has been working to improve standards for PDA Providers, PDA coursework content, and PDA coursework delivery. The NCCAOM PDA department is not able under current processes to review or monitor providers or their courses who do not apply with the NCCAOM to be a PDA provider. Therefore, the NCCAOM PDA department cannot assure that the providers and/or the courses meet NCCAOM recertification standards. To address this discrepancy, the PDA Department and Certification Services Department have requested that new categories of PDA providers be created for acceptance of PDA coursework in the area of Core Competency. All current providers will have the ability to continue to offer NCCAOM PDA approved courses by meeting the eligibility criteria of any one of the new PDA Provider categories; Standard, Institutional and Affiliate.
Your comments are correct in that NCCAOM’s intention is to require all recertification coursework in the section of Core Competency to be taken from an approved NCCAOM PDA Provider. This new policy is planned to go into effect for Diplomates recertifying as of January 1, 2015. The NCCAOM will be working with state regulatory boards and other healthcare organizations to meet the requirements of the new Institutional and Affiliate NCCAOM PDA Provider categories. There will, of course, be a transition period for all Diplomates within their four-year recertification process. Diplomates may use all the PDA points earned for their recertification under both policies.
As the new policy and PDA provider categories roll out, the recertification process will be simplified. The selection of courses in the area of core competency will be identified by a unique code by core competency domain which will be searchable on the PDA Search Engine and eliminate any guesswork for the Diplomate. The NCCAOM will also be providing, over the next year, a means for Diplomates to electronically record their PDA points online. The Diplomate will then be able to print an NCCAOM transcript of their PDA points earned for recertification documentation.
Coursework which is completed from an educational sponsor who is not an approved NCCAOM PDA provider will continue to be accepted for NCCAOM recertification in the Professional Enhancement Section under the Continuing Education category. The area of Professional Enhancement will remain unchanged.
Our goal is to make the process easier for Diplomates to recertify. Thank you again for your feedback. It is very much appreciated.
Sincerely,
Irene Basore
Director of Operations
National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM®)
76 South Laura Street, Suite 1290
Jacksonville, FL 32202
Ph: (904) 674-2471 Direct
Main Ph: (904) 598-1005 / Fax: (904) 598-5001
Email: ibasore@thenccaom.org
Web: http://www.nccaom.org Connect with NCCAOM:
Find a Nationally Certified Practitioner on http://www.nccaom.org
I sent them an e-mail they probably will not like but that it is to bad. I called a spade a spade. I told them that they have not done anything I know of in recent years to improve our ability to enhance our profession forward but yet they want us to spend more money we all don’t have. I told them that soon they will put themselves out of business. I doubt they will listen but that will be there mistake. I will be an OT by then and I probably won’t need them any more anyway. It is really a shame how they have allowed our profession to go nowhere in the 13 years I have been licensed.
They are asking for input, so they should be happy to hear what you have to say. I think it is important for all of us in the profession to be clear that the NCCAOM does not exist to promote the profession. They exist to grant credentials — and by advocating for their credentials to the states, they get us over the barrel. If we had a strong professional organization as a balance, we’d be in better shape. However, the professional organization, the AAAOM, has struggled for years and has depended on the NCCAOM for help in times of need, so there isn’t a balance. Many of our colleagues remain convinced that more credentials and more education are what we need, and so they support the efforts of the NCCAOM. For the most part, we have created the difficult situation we are now in.
Thankyou for your email….I agree with you!
I hope you will share your thoughts with the NCCAOM — that’s who needs to hear it 🙂
Elaine, I think the NCCAOM is trying too hard, way to hard. NCCAOM should just keep it simple and focus on the core mission and programs. They seem to want to make everything more complicated than it needs to be, and this is an “empire building” mentality that many organizations suffer from.
Elaine, I very much appreciate your vigilance and communication with this! Thank you.
Thanks, Anna!