Success is Accessible!

When choosing or upgrading your office there is one consideration that will have a profound impact. Prioritizing it will help you —

  • retain clients for decades
  • appeal to clients who need your services regularly
  • decrease the need to make house calls
  • contract with insurance companies
  • participate in federal programs (such as Veterans Choice and ACA plans)
  • gain respect and referrals from other health care providers
  • keep your office in one location for the duration of your career
  • reduce legal threats
  • minimize workplace injuries to you and your staff
  • comply with civil rights law.

It’s a win, win, win, win, win, win, win,win, win, win.

That consideration is compliance with the Americans with Disabilities Act of 1990 (ADA), a federal civil rights law that prohibits discrimination against individuals with disabilities in every day activities, including medical services. Any private entity that owns, leases or leases to, or operates a place of public accommodation (that includes your office) is responsible for complying with Title III of the ADA. (Source – DOJ/HHS Publication)

19% of the US population reported having a disability in the 2010 census.

If you are blessed with good client retention and a lengthy career your patient population is likely to increasingly include those with disabilities. You might develop your own temporary, or permanent, mobility issues.

Acupuncture schools need to teach students about our responsibilities under the ADA. Ethics classes should address the de facto discrimination that occurs when we choose inaccessible work spaces. And, when practitioners seek advice from peers about potential office arrangements, renovations, or accommodations (such as interpreters) emphasis should be on the legal, ethical, and practical benefits of compliance. Preemptive absolution is offered too often, especially by those who don’t understand the law.

The ADA does include exemptions to protect small businesses from accommodations that would be an “undue burden.” Is a $2,000 lift table an undue burden? How much have you spent on Biomats, lasers, tuning forks, and travel to conferences? Rent for a first floor office might be more, but house calls also affect your bottom line. (If you rely on house calls to comply with the ADA requirements for accessibility, remember: you can’t charge more, you must offer the same level of service, you have to offer flexible scheduling as you would to your in-office clients, and, if you are accepting new clients it is discrimination not to accept those whose disability would make your office inaccessible.)

It’s true, individual practitioners who don’t comply are unlikely to suffer legal consequences and many Practices flourish despite a lack of accessibility.

“Getting away” with not complying is no way to run a business or a health care profession. Doing all we can to meet the needs of those with disabilities is good business, good for the profession, and good for the public. It should be a top priority.

Here are some resources to help you understand the ADA and our responsibilities —

Access to Medical Care for Individuals with Mobility Disabilities

Americans with Disabilities Act Title III Regulations

Title III Highlights

ADA Q & A for Health Care Providers

ADA Checklist for Existing Facilities

ADA and Small Businesses

NPR Story about Accessing Care for People with Disabilities

Post on California Law impacting Lease negotiations

ADA Enforcement Activities

ADA in a Health Care Context

ADA for Deaf and Hard of Hearing

Insurance and Acupuncture 2015- The State of the Profession

Many Acupuncturists hold that increasing insurance coverage is necessary for our professional future. It’s a main goal of the NGAOM. HR 3849 is the same legislation the AAAOM has lobbied for in the past. The Acupuncture and Oriental Medicine Society of Massachusetts is working on legislation mandating insurance coverage, and a similar bill has been introduced in Vermont. A handful of states include acupuncture in their ACA plans.

I don’t believe Acupuncturists have to sell their soul to participate with insurance, and I don’t believe insurance companies are evil.

I do believe many practitioners haven’t considered the overall impact of insurance coverage on their business, the profession, and the medicine.

Participating with insurance invites a third-party into the treatment room. The Acupuncturist (or any Care Provider), the Patient, and the Payer share one goal – that the Patient feel better as quickly as possible. Beyond that, there’s plenty they don’t share, including – how to define treatment success and fair compensation. How many and what type of treatments are necessary. What provider types to reimburse. How best to control health care spending. How to provide care for those with expensive medical conditions. How to assess quality care.

Patients and providers often see the payer (a faceless bureaucracy that isn’t in the treatment room) as the bad guy. But the payer’s business depends upon watching every penny, and always trying to get more for less. Payers often say no (or that’s too much) to patients and providers.

In the past year, conversations about insurance coverage have included:

  • Practitioners about to open their first practice with no idea where to begin.
  • Copies of statements from an Acupuncturist who bills insurance $2,000 per treatment.
  • A practitioner insisting that billing a Manual Therapy code for point location is legit.
  • Many responses of “everyone has pain somewhere, so bill for that” to questions about codes for a specific condition.
  • Discussions of how to use CPT codes so that reimbursement amount equals desired amount.
  • Concerns about audits.
  • Concern regarding reductions in reimbursement rates.
  • Complaints that panels are closed (the insurance company won’t accept additional practitioners in-network).
  • Reports that companies are requiring current NCCAOM credentials for participating providers, even when not required for state licensure.
  • Anger when offers of expedited payments for reduced amounts are offered.
  • Complaints about time spent resolving billing or reimbursement errors.
  • Questions about proper policies around co-payments and co-insurance.
  • Discussions of how to serve the patient who has not yet met their deductible.
  • Concerns about retaining patients who have reached their treatment limit.
  • Stated goals of treating patients with limited resources, without recognition that those patients often have limited coverage.

We’re inviting a powerful bureaucracy into our practices, one with the power to define our medicine in the eyes of the public. Other professions have strong and responsive support systems to balance the power of that bureaucracy. We don’t. Are we prepared for the continuing effort that will be necessary to protect our interests? We play this game at our peril.

 

 

9 Reasons why Acupuncture Regulations There Matter Here!

Changes in acupuncture regulation in any state matter to each of us individually, and to the profession as a whole.

Here are 9 reasons why —

  • We don’t know what the future holds. Unexpected moves happen.
  • You may need to hire practitioners or sell your practice. Can interested parties easily move to your state?
  • Your patients might move and want a practitioner just like you. Will one be available?
  • Growth in the profession is not keeping up with demand. Regulatory uncertainty diminishes the appeal of the profession.
  • High educational and credentialing costs interfere with business growth. If the requirements vary from state to state, the impact is multiplied. (See this report on Occupational Licensing.)
  • Regulatory differences lead to divisions within the profession. With fewer than 25k acupuncturists in the US unity is critical.
  • What happens in one state impacts every state. States look at what has happened elsewhere when considering regulatory changes.
  • Changes in one state can lead to changes for everyone. When CA increased required educational hours every school and ACAOM soon changed as well.
  • Different regulations, training requirements, and titles make it difficult to educate the public about our qualifications, draw contrasts with other professionals, or advocate for our profession as a whole.

Staying informed is not easy. Neither is getting involved. We are all busy, we don’t always know how to assess the pros and cons of a possible change, and things can get heated and unpleasant when there are differences of opinion.

And, the future of our profession and our businesses is greatly impacted by regulatory changes – even those happening across the country.

Please, stay involved.

Forgive two posts in quick succession, but regulatory changes are on the way. You’ll hear from me again soon.

(Note — I advocate for standardizing and simplifying the regulatory process for acupuncture licensure. I am not advocating for standardizing the medicine itself. Our diversity is powerful indeed.)

How we Grow – The Acupuncture Profession in 2015

One Physician per 371 non-institutionalized civilians was the US average in 2012.

One Acupuncturist per 20,000 non-institutionalized civilians was the US average in 2014.

NCCAOM’s 2014 Annual Report is an important read for anyone who cares about Acupuncture in the US. From it we learn:

  • Applications for certifications dropped from 1744 in 2013 to 1494 in 2014.
  • The number of new certifications dropped from 1144 in 2013 to 972 in 2014.
  • 532 of those new certifications were in Oriental Medicine. Another 16 were for Chinese Herbology (likely existing LAcs choosing or being required to add the Herb certification).

I don’t know how many practitioners are leaving the profession, but many of my peers who were licensed 20+ years ago are stepping back from active practice.

Several current initiatives, including HR 3849 and state-level efforts to mandate insurance coverage of acupuncture would increase demand for acupuncture. (There are 49,435,610 Medicare beneficiaries in the US and 5.5 million Gulf War Vets.) If fully trained Acupuncturists aren’t able to meet the demand, who will provide those services?

At this rate, how long will it take to grow the profession to even one Acupuncturist per 2000 people?

Shouldn’t we focus on that?

I’m baffled. We’ve sued, signed petitions, and marched in the street, all to try to stop the “greatest threat to our profession” – other professions wanting to use the acupuncture needle.

But there’s been silence, or even approval, when Florida (with one DOM for every 17,760 people) changed their regulations in 2014 to require all 4 NCCAOM exams for licensure. Ditto in NJ where new practitioners will need the NCCAOM herb exam to use herbs in their practice. (How many citizens had been harmed by use of herbs by practitioners without the herbal credential? Was regulation needed?) In Nevada (approximately 1 Acupuncturist for every 47,000 citizens) the Board of Oriental Medicine is moving to require a DAOM of all licensees. Meanwhile, many insurance plans are limiting their provider pool to those with active NCCAOM certification, even in states that don’t require that credential. (After all, the vision of the NCCAOM is that “Acupuncture and Oriental medicine provided by NCCAOM credentialed practitioners [emphasis mine] will be integral to healthcare….”)

If we want the public to obtain services from well-trained Acupuncturists we need to make sure providers are available. One thousand new practitioners a year and growing self-inflicted restrictions on where and how we can practice aren’t going to do it.

The greatest threat to our future is an Acupuncture workforce insufficient to meet demand or effectively advocate for ourselves. Allowing or supporting credential creep, educational bloat, and practice restrictions are sowing the seeds of our demise.

Can we please focus on growing our profession?

 

Demographic Information From:

Acupuncture Today Density Map

Physician Data

Population Data

Medicare Data

Veteran Data

It’s Like Herding Cats

It’s a common refrain about reaching consensus in the acupuncture profession. But why try to herd cats? I learned a long time ago that opening a can of tuna would bring kitty running.

If there were an attainable action that would:

  • Increase patient access to Licensed Acupuncturists,
  • Assist in national marketing for the profession,
  • Decrease educational costs and student debt,
  • Decrease licensing expenses,
  • Increase political power,
  • Expand professional opportunities, flexibility, and mobility, and,
  • Increase the value of your practice,

Would that be like tuna to a kitty?

(Whirrr of can opener)

Tuna for me = Identifying the least restrictive licensure requirements necessary to protect the public and create successful practitioners and working to establish that as a standard in all states.

Before panic ensues, consider some of the situations I’ve heard about in the past few years:

  • Highly experienced and qualified LAcs unable to obtain licensure, even in states where there are so few LAcs that the public has little choice but to get their acupuncture treatment from Chiropractors.
  • Practitioners who want to sell their practices but have a limited pool of buyers because of the unique licensure requirements in their state.
  • Practitioners travelling many, many hours in order to practice, or leaving the profession, because life has taken them to a state in which they can’t obtain a license.
  • Practitioners and students who have no interest in using herbs being required to spend tens of thousands of dollars and thousands of hours learning herbal medicine in order to obtain an acupuncture license.
  • Acupuncturists supporting discriminatory laws or regulations such that the only group of people in a state who can not practice herbal medicine are other Acupuncturists.
  • Practitioners having to maintain licenses in multiple states because changing regulations mean that if they give up a license they will be unable to obtain it in that state again.
  • Acupuncturists being unable to advance reasonable state or national legislation because restrictive practices keep practitioner numbers so low that political support is unavailable.
  • The profession being unable to effectively educate the public about their excellent education and credentials because those credentials vary so much from state to state.
  • Acupuncturists struggling to build a practice in overserved areas, but unable to obtain licensure in nearby underserved areas.
  • Acupuncture organizations fighting for inclusion in managed care and federal health programs, even though many states have too few LAcs to serve the population. (Demographic data can be found at these links: Acupuncture Today LAc Map, US Population, Physicians per State.)

The current system in which some states require graduation from particular schools, others have their own exams, and others have their own educational requirements does not serve us as a profession. The situation is getting worse, not better, as states like Florida increase their requirements. Yes, states have differing scopes. (Those who advocate for scope changes should be required to consider and advertise the impact the changes will have on licensure requirements.) Yes, it is in the interest of the public and the profession to insist that practitioners limit their practice to the tools and skills in which they have been trained. Additional, optional, training can always be required for those who wish to practice more advanced techniques or modalities. The least restrictive licensure requirements have shown themselves to be sufficient for safe practice.

Limited, standardized, licensure requirements would lower practitioner expenses, promote mobility, ease national marketing, and help the profession grow. It sounds great — as good as tuna smells to a cat. Does it make you make you want to come running? Many changes in licensure requirements could be made at the regulatory level and are within our reach. It does not depend on establishing reciprocity. One problem — the LAcs within a state have the power to make or block change, and, especially in restrictive states, the small group that set up the rules is often in power. Another problem — many LAcs don’t care about this until they are directly impacted.

This is a place where national coordination is needed. I hope the CSA sees that this is a place where they could make a positive difference. Let your state association know if you support a more standardized and simpler licensure environment. It should not require any herding.

Cat Food

Cat Food

 

 

Assistance for the Working Acupuncturist

I went down the Facebook rabbit-hole, and while I was there I learned a few things.

For instance, “just a quick look” and “I’ll just scan my notifications” can quickly lead to a month without a blog post. I will not let that happen again.

Also, based on posts about HIPAA, insurance billing, choosing office space, maintaining records, etc., we have  a lot of questions and we are looking for answers. It’s great that we’ve got communities of colleagues to ask. It is also inefficient, and sometimes downright dangerous that our colleagues are often the only source of answers.

Looking at HIPAA and ADA for example, we see that some professions (but not acupuncturists) have access to lots of resources from their national associations.

  • a search of the AAAOM site gets one, not very useful hit, regarding HIPAA-related responsibilities.
  • Here’s information from the APTA (American Physical Therapy Association) site on HIPAA.
  • Here are the search results for HIPAA over at the American Chiropractic Association.
  • I can find no information on the AAAOM site about acupuncture offices and ADA compliance.
  • APTA provides these useful links about ADA compliance.
  • The American Psychological Association has great information about ADA compliance.

While acupuncture organizations are working on national legislation, increasing insurance coverage for acupuncture, adding an entry level degree, and fighting with other professions to limit the use of the acupuncture needle, we search for authoritative assistance on current practice issues in vain. (Luckily, the links above are pertinent to our practices.)

To make matters worse, sometimes it seems that we prefer ignorance. In my time on Facebook I was reprimanded for self-promotion when I shared useful links to this blog, and I was threatened with banishment from Acupuncturists on Facebook because I “acted like [I] know it all.” (I don’t know it all. I do know a few things.)

When many of us don’t understand or comply with our obligations under the ADA and HIPAA, are we ready to be a part of the Medicare system or have acupuncture be an EHB? Isn’t accurate information about ADA compliance an important part of our stated goal of having acupuncture accessible to all? It’s past time for our schools and organizations to make sure we have the skills, knowledge, resources and information to be successful practitioners now. The FPD, Medicare inclusion, higher standards, and expanding our scope/suing our competitors should wait.

Petitions, Medicare, and Licensure

Notable news items in the acu-world this week:

1)  We finally got a response to the petition to the White House to add acupuncturists to the list of Medicare providers. My regular readers already knew that a petition to the White House is not going to create the legislative and administrative changes that would be required.  (Newbies, you can use the tag cloud to find previous posts on the petition and Medicare.)  The response has (no surprise) created the usual teeth-gnashing, with acupuncturists (who seem not to have read the response) lamenting that Obama doesn’t like acupuncture, that it’s all about money and power, that we’re doomed,…. The conversation also shows that even among those most strongly advocating for becoming part of the system, there is still significant ignorance about what would be needed to succeed and the consequences for the profession of “success”.  Also not surprising — no response from the AAAOM or NCCAOM who helped distribute the petition — even though they should have known enough to predict the response and had a year to prepare.

2)  The latest Acupuncture Today newsletter included an article on the six states in “licensure limbo.”  I suspect that overzealous regulation on our part (for example, Delaware and Florida requiring extensive herbal credential requirements for acupuncture licensure) contributes to the lack of enthusiasm for a practice act among practitioners.  I also believe that the acupuncture community’s aggressive and disrespectful response to PT Dry Needling and to MD’s and DC’s who do acupuncture is a significant factor in the unwillingness of those communities to support a practice act in those states.  Actions have consequences.

3)  A new “threat” on the horizon — some LAcs on Facebook are up in arms about Tattoo artists who are doing “dry tattooing” for skin rejuvenation.  You know the drill — how dare they, we have so much training, we need to gather the troops to fend off this encroachment. My points — tattoo artists can use needles, they can do cosmetic work (tattooing eyebrows for people with alopecia and tattooing nipples for people who have had breast reconstruction, for example) and they could tattoo someone’s face completely blue if the client wanted it.  Facial rejuvenation acupuncture is typically not taught in acupuncture school. Is there any reason (other than arrogant self-importance) why we believe we should have control over this technique?

I’m still adjusting to the addition of Facebook into my life. I haven’t figured out how to stay informed and involved there without taking the energy and the dialogue away from The Acupuncture Observer.  For those of you on Facebook, like the Observer page and you’ll get breaking news updates between blog posts.

Also, for those of you interested in learning more about navigating the political/regulatory system I’ll be doing a breakout session at POCAfest,  on March 15th in Tucson.  I’d also be happy to come to your state association meeting, conference, or other event. Knowledge is power.

2013 Review for Acupuncture Professionals

As 2013 was dawning, the WhiteHouse.gov petition to include acupuncture in Medicare was circulated by the AAAOM, NCCAOM, and loads of school and practitioners. Because coverage is not determined by the executive branch, over 30,000 signatures made no difference. That our professional organizations either didn’t know enough or didn’t care enough to educate acupuncturists about how the system works did give me the final push to create The Acupuncture Observer. From the first post last January through # 49 today, I’ve tried to provide thought-provoking strategic analysis of where we are and where we are headed.

The planned March AAAOM conference on a cruise ship didn’t set sail, making 2013 the second consecutive year without a conference. Things began looking up with April’s announcement that experienced professional Denise Graham was named AAAOM Executive Director.

However, by mid December, Ms. Graham and three Board members had resigned. (Previous ED, Christian Ellis, managed only three months in the fall of 2010.) A majority of the current board members have been appointed rather than elected. Something at the AAAOM smells. The Whistleblower Protection Policy, prepared in conjunction with the Confidentiality Policy adopted in April 2012, never resurfaced after it was pulled by then President Michael Jabbour (who is now managing the “operational transition”). We’ll probably never learn what is really going on in the board room, but 2013 marks the year I gave up hope that the AAAOM could become a viable organization serving the profession. It’s now become a single-interest (Federal legislation) organization, under the control of a small number of people, and without the resources to accomplish its priorities.

Throughout 2013 qualified LAcs were denied licensure by the Delaware Acupuncture Advisory Council’s insistence on the NCCAOM OM credential. New Florida regulations will limit licensure to those with NCCAOM Herb credentials beginning in October 2014, putting another state off limits to many practitioners and greatly increasing educational costs and the regulatory burden for those who intend to practice in those jurisdictions.

Outrage at  P.T. Dry Needling continued throughout the year. Some LAcs made arguments that reflect poorly on our concern for the public, such as suggesting we’d drop our objections if PT’s agree to use hypodermic needles for this technique. Various state associations began efforts to redefine acupuncture and to push for discriminatory insurance policies in response to dry needling and the end of 2013 brought newcomer NCASI (and their lawsuit against Kinetacore) onto the scene.

Late Summer brought proposed policy changes from the NCCAOM that would move the group several steps closer to becoming a regulating rather than credentialing body. In a bit of good news, comments from the profession sent the proposals back to the drawing board.

Over the course of the year growing numbers of practitioners added insurance billing to their practices.  We’ve been quick to throw stones at the billing practices (or rumored practices) of PT’s, yet many acupuncturists offer justifications for questionable practices and few seem clear on the exact nature of their agreements with the insurance companies.

In the waning days of 2013 a job opening for a Licensed Acupuncturist at Brooke Army Medical Center was posted on Facebook. Initial responses cast an interesting light on our profession’s self-regard. There were complaints that the salary (about 70k) was too low, some suggested that a PT would certainly get the job, and others complained about the requirement for a flu shot.

In a few days I’ll be back and begin looking forward. What will serve us in the year of the Wood Horse? When the dragon brings the energy of the spring back to earth, how should the seeds of the profession grow?

Acupuncture & Insurance, Part 2 — Affordability

Many of us see it as a no-brainer. We want acupuncture to be affordable, insurance/Medicare makes it affordable, how could anyone be against that? This reasoning relies upon a superficial understanding of health care costs and affordability.

Consider:

  • Affordability must take into account premiums as well as co-pays and out-of-pocket expenses.
  • Both cost to the individual and sustainability of the system are part of affordability.
  • All medical costs are ultimately borne by the public.
  • When coverage is provided for the very sick, the premiums of many healthy people contribute to their medical expenses.
  • If health care spending exceeds what the insurance companies have planned for, premiums will go up and reimbursements for providers will go down.
  • Controlling health care spending depends upon providers accepting reduced payment for their services and upon a bureaucracy determining what services are appropriate.
  • The wealthiest in our system typically have the best insurance coverage.

A respected colleague said I give the impression that Community Acupuncture is the only way for people to get affordable acupuncture and that everyone should treat that way. My bad — I don’t believe that. I do believe it is a good way — it accepts the reality that acupuncture isn’t really more affordable if it doesn’t cost the system less. It provides affordable treatment to everyone, not just to those with the best insurance coverage. And it keeps big business out of treatment decisions.

I continue to treat one client at a time, in a private room. I have a generous sliding scale, available to all, to help a wide range of people afford acupuncture.  Some practitioners treat in private rooms and charge one low price to all patients. I have colleagues who reserve a certain percentage of their appointments for those who need steeply discounted services, and I have others who volunteer in free or low-cost clinics. These are all ways to make acupuncture affordable.

Disguising the cost of acupuncture by hiding the expense in co-pays and premiums (many so expensive that they are subsidized by taxpayers) doesn’t make it more affordable. Changing the way you treat so that your reimbursements match what you think you deserve doesn’t make acupuncture more affordable (or support arguments for cost effectiveness).

CA is not the only way to make acupuncture affordable and I certainly don’t think it is the only style of treatment that should be available.  But insurance increases the big picture affordability of acupuncture only to the extent that it limits reimbursement rates and access.  Insurance is not a magic wand, and those practitioners who believe it is are in for a rude surprise.

For more, check out this post, and these statistics about the increases in health care spending in the US.

The Acupuncture Profession, News and Analysis

Three dedicated AAAOM Board members and AAAOM (super-qualified, knowledgeable, and committed) Executive Director, Denise Graham (my last hope that things could get better) resigned recently.

One board member spoke of an uncomfortable and increasingly controlled board environment, a declining membership (now less than 2% of the profession), and poor relationships with national and state leaders. Another stated that the AAAOM doesn’t have the support, revenue, or credibility to make progress towards legislative goals.

This isn’t the first time AAAOM has been on the ropes. If it hadn’t been for money from the AAC and support from other organizations, I doubt they would have survived this long. Somehow, though, they still manage to control the conversation.

In other news, NCASI, the National Center for Acupuncture Safety and Integrity, has appeared on the scene. NCASI’s list of “10 Facts” should be titled “10 Things We Insist are True and/or Important.”  Dry Needling by PT’s is legal in many states. Review my past posts on dry needling and scope for more background. We take real risks when we files lawsuits like these.

For twenty years, the acupuncture organizations have insisted that our success depends upon —

  • Increasing credentials/educational requirements/scope. It doesn’t matter if the old education, credentials, and scope worked fine. It doesn’t matter if it increases practitioner expense, decreases practitioner flexibility, or prevents some LAcs from utilizing techniques available to any other citizen.
  • Getting someone else to pay for acupuncture. Fight for third-party payment systems even if other professions report they make good medicine more difficult and practice less enjoyable. Ignore the hypocrisy of participating in a system that requires discounting services while also criticizing LAcs who offer low-cost or discounted treatments directly to patients. Insist that practitioners who don’t want to participate won’t be impacted, and turn a blind eye to the fraud that many practitioners engage in to make the $’s work.
  • Demanding a monopoly.  There’s no need to earn your market share by providing the best product — instead establish it through litigation and turf battles. Don’t worry if this requires you to disparage your fellow health providers or contradict your message that the public should be able to choose their providers.

After twenty years many LAcs struggle to stay in business, and most voluntary acupuncture organizations struggle to survive. Got questions about ADA compliance, insurance billing, privacy issues, advertising questions, disciplinary actions? You won’t get answers from the AAAOM and you probably won’t get them from your state organization.

It’s time to change our strategy. We have enough training, clients who seek our services, and other providers who respect the medicine so much they want use it themselves. Yes, we always need be aware of and informed about the regulatory/legislative landscape, but we also need business skills, PR, positive marketing, and an easing of the regulatory burden.  We need a good hard look at the cost of education. We need legal advice and business tools and positive interactions with potential referral sources and colleagues. We don’t need more legal battles, more regulation, more legislation, more degrees that further divide us.

When our organizations provide these things, we’ll have successful organizations, and successful practitioners. (If you don’t believe me, ask POCA.)