FPD/DAOM required, Schools, ANF, Dry Needling — and more Acupuncture News….

New news:

Word is that the Nevada acupuncture board is poised to require an FPD (or is it a DAOM?) for licensure, even though citizens there are already under-served. I’m trying to get more information. Stay tuned for updates. State actions that limit our profession tend to stay under the radar until it is too late.

The acupuncture school landscape is changing. Last week brought news that Bob Duggan and Dianne Connelly will no longer be part of MUIH faculty or staff. For those who have been paying attention as The Traditional Acupuncture Institute morphed into MUIH, it shouldn’t have been a surprise. But it is sad. While TAI had its good and its bad, many who attended did so because of Bob and Dianne’s contributions. The announcement was quickly followed by a letter, in perfect TAI-speak, that, for the sake of the students, we shouldn’t get caught up in stories about this. As in, don’t even ponder what it is we aren’t telling you.

This week also included the news that NESA is merging with MCPHS, and ACTCM is merging with CIIS.  (Thanks, Integrator Blog.) Is the age of the stand-alone acupuncture school coming to an end?

Have you heard of The Acupuncture Now Foundation? They aren’t a membership organization, and they don’t want to get involved in acupuncture-politics. They just want to educate the public about our training, our skills, and the great results from our medicine. Please, support ANF! Marketing the medicine shouldn’t have to be an individual effort.

Older News:

Developments in dry needling, with the hope that we might learn from history:

  • Louisiana joined other states with an AG opinion that dry needling is within scope for PT’s and DC’s. Other AG opinions can be seen here.
  • Tennessee’s Governor signed Legislation formally adding dry needling to scope for PT’s, joining Utah and Arizona which saw similar legislation in 2014.
  • The Maryland Acupuncture Society came out in strength behind HB 979 and SB 0580 that would have set limits for dry needling by PT’s and DC’s. The bills went nowhere, perhaps a blessing in disguise as “success” would have opened a can of worms.  (The bills did not define dry needling, MAS support put the acupuncture community’s stamp of approval on a 200 hour standard for acupuncture training that had been previously unacceptable, and the wording opened the door for PT’s with 200 hours of training to argue that they were now, indeed, doing acupuncture.)

The AAAOM website has been updated with board bios and a revamped committee list, but still no answers for any of my sixteen questions for the AAAOM.

ACAOM responded to the petition in response to their Gainful Employment letter in the ACAOM Fall Newsletter.  The good news — they heard us. The bad news, they continue to believe that significant student debt is helpful for those who want to serve low-income communities.

There you have it, at least some of the news you aren’t seeing in Acupuncture Today.

 

Gainful Employment and Strategic Errors

The Gainful Employment final regulations have been announced. Forgive my commenting prior to a complete and thorough analysis of the 941 page document. (You can see some analysis here.) The gist is that for-profit schools (which includes half of US acupuncture programs) will soon have to show that graduates’ student loan payments are manageable with the profession’s available employment (not taking IBR into account). If they can’t, federally guaranteed student loans will no longer be available.

Why should taxpayers continue to provide loans for educations that history shows aren’t worth the investment? Imagine tuition rates and post-graduate employment assistance if the schools provided and guaranteed loans, and took the hit if they weren’t paid back in a timely fashion.

It is no surprise that for-profit schools are displeased about the impending end of the gravy train. Many for-profit schools, and their related organizations, did everything they could to block the regulations. And, just under the wire, the acu-educational establishment contributed comments (see ACAOM gainful employment word).

(The more expensive FPD, and pressure away from “acupuncture-only” degrees now carry a significant downside for the schools.)

Did ACAOM think their letter might exempt them from the rules or impact the final regulations? It seems unlikely that this little community would shift the tide. It was an unforced error for ACAOM to write a letter that reveals such little concern for graduates and such a strong desire to dodge responsibility. (Some of the more significant issues in ACAOM’s letter are discussed here.)

But our own strategic errors have allowed ACAOM and other other alphabets to disregard our well-being.

The petition that asked the alphabets to stop denying their role in our circumstances received 227 signatures. Petitions to stop dry needling often receive thousands of signatures. Which is more likely to limit professional success — a school that leaves students with extensive debt, poor business skills, and no job placement or alumni support, or a little competition? If we can’t survive the competition from those “untrained” professionals our education is surely lacking.

The Feds and the taxpayers pay a price when schools sell an education for far more than it is worth. We graduates pay a far more personal price. It’s too late for us, but at least the Feds are willing to look out for the interests of those who will follow in our footsteps.

What’s your Acupuncture Degree Worth?

Answer: Less than it used to be.

(Please, sign the petition.)

If you earned an MAc and Dipl. Ac (NCCAOM) twenty years ago, you thought you had it made. You could get a license in almost all states with licensure. The schools and the NCCAOM touted the caliber of the education and credentials. You knew you had plenty to learn about this medicine, but you could practice safely.

In the gainful employment letter ACAOM points to the (supposed) earnings of those long-ago grads to minimize the financial struggles of recent grads.

But in 1995 the NCCAOM added the Herbal exam, and later the OM. Some states now require those additional credentials of all practitioners. ACAOM has increased hourly requirements for school accreditation several times. And the NCCAOM has put additional limits on who can take their exams.

Some of our most esteemed teachers do not meet the current requirements for sitting the exams. Many practitioners are trapped, unable to relocate.

By increasing the range of degrees and credentials available before our “brand” was established and our profession was strong, the alphabets increased division and confusion. No wonder the public can’t figure out how an LAc’s education compares to that of other providers.

And here comes the First Professional Doctorate. With this new degree, my alma mater announces,

“[graduates] will be recognized as doctors, both professionally and publicly, and will have increased credibility and standing.”

If graduates with an FPD have increased credibility and standing, what has happened to the credibility and standing of graduates of Masters programs?

According to ACAOM’s gainful employment letter, licensure requirements just happen, and practice success is a simple matter of practitioner choice.

Really, though, the “alphabets” have played a significant role in the expansion of requirements and credential creep, and most of the schools do little to teach students how to make wise business choices.

If, as ACAOM wrote, the graduates of twenty years ago do so well, why have entry level requirements been increased so much? Why are grads struggling to pay off existing loans encouraged to return to school to maintain their credibility? Will the NCCAOM require an FPD to sit their exams? Will the alphabets encourage states to require it for licensure?

ACAOM/NCCAOM/CCAOM/AAAOM — if you represent us, defend the value of our degrees and credentials. Your “options” too often become a requirements.

Colleagues, did the gainful employment letter represent your views? If not, sign the petition. 129 people have, which means ACAOM etc. can still claim to represent 32,871 of us.

For additional information and analysis about educational costs and value, check out this from The New York Times and two posts from Dr. Phil Garrison

 

 

NCCAOM/Dry Needling/A Young Profession

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

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

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

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

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

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

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

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

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

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

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

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

 

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?

If I Had 3 Million Dollars

I would buy you all a boat.

Just kidding.

I would —

  • Compile and make available a list of the specific requirements necessary to obtain an acupuncture license in each state, making sure to highlight current and oncoming obstacles. (For example, as of October 1, 2014, Florida will require passage of the NCCAOM Oriental Medicine Module for licensure. Although the Florida rules will continue to show that those enrolled in school prior to August 1, 2007 need complete only a two-year course of study which does not need to include herbs, the new examination requirement means that no one with only the two-year education will be able to obtain a Florida license.)
  • Compile data on the professional success of acupuncture graduates of every US school. The data would be available to all.
  • Explore why those who aren’t practicing have left the profession and whether there are different rates of success among graduates of different schools. If there is a difference in graduate success, are there factors common to the more successful schools?
  • Gather data on the safety record of acupuncturists in various states. Does it matter if the state requires NCCAOM exams or credentials? In acupuncture? In herbs? If the states require graduation from ACAOM schools?
  • Use the data to identify the lowest common denominator. Identify the least restrictive education/credentialing necessary to ensure public safety and prepare practitioners for success.
  • Show how uniform and non-burdensome state standards are a critical step in providing acupuncture to the 313.9 million people in the US. Build consensus for reasonable minimum standards, and work for their adoption in all states.
  • Establish a team of public policy professionals with expertise in regulation and legislation to help develop a set of attainable and effective strategic initiatives.

Where would I get my 3 million dollars? Not by yet another “now is the time, we must submit legislation that mandates access to the federal healthcare system” fundraising effort. We’ve heard this before. We should know by now that submitting legislation is guaranteed to suck up resources, it is passing laws that can make a difference – if we’re prepared for the consequences of success.

Please, respond to the AAAOM’s call for comments by August 31st. With, at best, 30,000 acupuncturists available to 313.9 million people, is submitting legislation which has a snowball’s chance in hell of passage really the best use of 3 million dollars?

And, if you really want to do something that will improve access, ten minutes and two stamps will do it – here’s how.

A Mature Profession? Part Three

I’ve heard it said that, while “The White House Petition” in and of itself can accomplish nothing, it is still a positive development for the profession — that it stirs things in the right direction.  I disagree —

1)       Many people signing it, which includes practitioners and patients, don’t realize that it is meaningless. It increases hopes which are bound to be dashed, contributing to the destructive and already prevalent feeling that we’ve been wronged.

2)      The petition reveals a profession which does not understand how the system works.  It makes us look ignorant (because we are, mostly).

3)      The profession should have other priorities.  We still have six states without licensure.  If we want to have a national week of action on something, why not that?  (I’d say that’s a necessary precursor to being included in Medicare, for one thing.)

4)      We are completely unprepared to do anything with the attention this creates.  If the president called the AAAOM tomorrow and said, wow, we think this acupuncture thing is really interesting, how many practitioners are interested in becoming Medicare Providers, what answer would they get?  If they asked what sort of support we had for our last bill, do you think saying we had 37 Representatives sign on would be impressive?

A petition might be a reasonable piece of a well-thought out plan to change something that had widespread support in the profession, and for which we were on the verge of success, but as an independent statement it is a distraction, a waste of energy, and misleads rather than informs.  A triple threat!

A Mature Profession, Part Two.

(An intercepted letter)

Dear K,

Thanks so much for the time you’ve given to our dialogue and for the work you’ve done for the profession thus far.  You are incredible.  Forgive my response in a numbered list.  There are so many issues and it is often a battle between my natural wordiness and my hope for clarity (and that people will stay tuned in).  Also, I’m quoting you because you bring up good points shared by many; I’m not intending to pull things apart word by word as though your quick email was meant to be read like a scholarly article.

1)       You wrote ” I don’t really think anyone in our profession understands how the federal level works – our profession is still so young that it is really completely state regulated, and differently in every state.”  I agree that our profession has a shortage of individuals with a good understanding of how things work at the federal level.  However, our youth alone is not an excuse.  In fact, if we’d educated ourselves about how things work on a federal level even two years ago, the last time a petition like this went around, we’d be in much better shape today.  Our ignorance is due to the fact that no national organization has made it a priority (or, been able to act effectively if it was a priority) to do the important work of hiring some teachers and consultants to inform us about “how it works,” or even just to provide a safe forum for exploration.  The longer we stumble around in blindness the more lost we get.  The CSA and state orgs are great, but we need national leadership to help us see how state issues impact the whole, and an understanding of federal issues is critical.

2)      If you go to the NCCAOM site and click on the Job Task Analysis Fact Sheet you will see their write-up about the BLS process.  I don’t see a connection between the BLS process and Medicare in that document.

3)      You use the introduction of HR 646 as a clue to help you figure out potential connections (or lack thereof) between BLS and Medicare.  The existence of HR 646 shows only that Congressman Hinchey likes acupuncture and acupuncturists and, in every congress since 1993, has introduced a similar bill.   I’m not going to take time to compile a list of nutty bills, but I’m sure I could.  I’m not saying that 646 was nutty, but that having a bill introduced in Congress is not evidence of much.

4)      Regarding benefits and costs of Medicare Inclusion – I’ve read and written thousands of words on this topic in various acupuncture-related list serves and publications but I have yet to see a careful study and analysis by experts to help us explore this issue.  That is my main complaint here.  There is evidence from other professions on the impact of Medicare.  Let’s have a national exploration of the issue based on more than what you or me or my great Aunt Tilly thinks is a good or bad idea.  I’ve written a lot of checks to national acupuncture organizations over the years.  Is a well-done exploration of this issue too much to ask?  Is distribution (again) of an at best minimally useful petition the best they can do?  And let’s not forget, this isn’t just about the impact of Medicare inclusion on individual practitioners, but on how it could impact the medicine itself.   Issues such as best practices and standardization are sure to arise.

5)      Sorry for the confusion about my use of the word “covered.”  I was referring only to Medicare.  Acupuncturists are not listed as providers in Medicare AND acupuncture is specifically listed as a service that is NOT covered.  So, my thought/question was around whether additional action would be needed to remove acupuncture from the not covered list, even if acupuncturists were listed as providers.   There must be some expert somewhere who could tell me.  (And, yes, the piecemeal nature of state laws about things like titles for professionals who do acupuncture would no doubt complicate any action on a federal level.)

6)      Regarding the EHB effort.  I hear you.  I was on the AAAOM Board at that time and it was like something from a dystopian novel.  The people in power believed what they wanted to believe and anyone who didn’t accept their beliefs was shut down.  There is no way I can succinctly sum up the dysfunction I observed.   It just about broke me.

As for the rest of your email, it fits right in with my Barking up the Wrong Tree post.  We’ve got a bunch of “solutions” being promoted and we don’t even have a good understanding of the problems.   Not only that, it’s been a long, long time since we’ve had a forum or group that’s truly exploring the big picture, helping the profession really understand the problems and explore possible solutions.  That’s not to knock CSA and the hard work of many, many people, but it’s the national level that is missing.

 

With hope for the future,

EWK

A Mature Profession?

Not again.  That misleading petition, forwarded along by many colleagues and even by schools, the AAAOM, and the NCCAOM, is making the rounds again.  You know, the whitehouse.gov petition that we should all sign to have acupuncturists designated covered health care providers?  Well, just as it was last time around, it’s b.s.  It doesn’t matter how many signatures we get, the Executive Branch does not determine who is a covered provider under the Social Security Act.

It would be nice if I could tell you the process we’d have to go through to make acupuncture a covered service.  I can tell you that finding the information and understanding it isn’t easy, but that my efforts continue!  (Of course, I’ll share what I learn.)  But why should I be the one doing this work?  Surely, one of the national organizations has figured it out.   You’d think, wouldn’t you, that they’d be a resource, providing information so that we knew what we as a profession needed to do to effect change, that, as practitioners we understood what would happen after a “victory” in this battle, that they’d have some ideas about the implications of a win?

Well, I guess, if you’ve been around a while you wouldn’t think that.  And clearly you shouldn’t.  So far, at least to the eyes of an acupuncturist more involved than most, the total input of our national organizations has been to further distribute a misleading petition, encouraging more wasted qi, and doing nothing to educate or inform the profession.

If it is correct that part of this process is to be determined to be a “mature profession” by BLS, as another colleague reports, then this petition, and the response to it by our national organizations, works against us.