A Feature or a Bug?

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.





Copyright —

© Elaine Wolf Komarow and The Acupuncture Observer, 2013-2033. Unauthorized use and/or duplication of this material without express written permission from Elaine Wolf Komarow is prohibited. Excerpts and links are encouraged, provided that full and clear credit is given with specific direction to the original content.

25 thoughts on “A Feature or a Bug?

  1. 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 for our accreditation) based on stakeholder input. Please see NCCAOM Student Webinar: http://www.nccaom.org/nccaom-webinars-posted/student-webinars/

    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.

    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.

    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.

    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.

    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.

    • Mina —

      Thank you so much for sharing your comments. As you know, I have encouraged you to do that, as the people at the NCCAOM are the best folks to present that side of the story. The NCCAOM is also able to share their point of view to a far bigger audience than I reach through monthly articles in Acupuncture Today and your access to mailing lists that cover most of the LAcs in the US. One of the reasons I began this blog was to give at least some exposure to ideas and opinions that aren’t privileged to get that level of exposure. And yet, even here, I am happy to present your opinions and responses.

      I’ve got quite a bit more to say in response to your comments, so I will, as soon as possible, share this as a post and include my responses.

      Until then, I encourage you to read everything that I’ve written about the NCCAOM – I believe you will find it much more balanced and, at times, even supportive, of the NCCAOM than you give me credit for. I also hope you understand that my printing a comment does not mean I agree with it. I moderate only to prevent spam, abuse, cruelty, and, when I have the knowledge and time, to add replies that may provide context, corrections, or my own thoughts. For example, I don’t think I have done any complaining about the cost of an NCCAOM move to DC. I never understood why the group left the area, and even if the association did pay moving expenses that may be a very reasonable choice. Basically, whether the group spent money on the move ranks low in my concerns – and if you think it is my job convince others that they shouldn’t care, I await a job offer.

      • Elaine, thank you for printing my comments and your response. While everyone is entitled to their opinion, what I was concerned about was some of the information contained in your blog that needed to be corrected. I acknowledge that you have in the past provided information about NCCAOM thoroughly and without bias and you have reached out to me in the past to get clarity about a particular announcement or issue. However, this was not the case in the June blog as it created a forum for gossip and accusations that you even stated were not nonissues such as unproven and false accusations of financial irresponsibility. Our staff would have been more than happy to provide you with additional information and rationale on recent policy announcements. I’m always a phone call away.

        My job is not to get into a war of words with you or any of your readers, but to correct inaccurate and unsubstantiated statements. I understand you’re not a journalist, however, we are living in times when it is especially important that published information is fact checked whether it’s a newspaper or a blog. I The NCCAOM is an organization that responds to and is open to opposing voices; however. I would like to point out again that we are standard-setting organization and credentialing is what we do. We represent the thousands of NCCAOM National-Board Certified Acupuncturists. Of course, we are supportive of our own exams and our certification programs. And again, we provide information about our exams and certification when regulatory boards ask us to do so. In the case of Utah, I told you that the email blast that was sent out in support of Chinese Herbs scope and exam was on behalf of the state association, which is a free service that NCCAOM provides to many state associations. I never said that the letter was a mistake. Nevertheless, I’m going to move on from this issue to focus on building positive relationships, because this is what this profession so badly needs. I hope in the future you continue to reach out to me or any of our dedicated staff, like you had in the past.

        • When I open comments to all, then it will become a forum for some issues that I don’t consider relevant. Again, I am not responsible for what others think and don’t feel my blog post should be blamed.

          When you tell me that you did not say that the letter was a mistake, it only confirms I am right not to write about our discussions. Clearly, my understanding of our discussion was incorrect. It is really best if you respond so that I am not responsible for misrepresenting your position.

          You are aware that the letter you send on behalf of the Utah Association included a sentence saying that the NCCAOM supported the change. Is this correct? If not, why won’t you correct the record? If it is correct, how can you then say you didn’t take sides?

          I am not asking to continue a war of words but to clarify the NCCAOM position for my readers.

  2. About the Utah Herb requirement, I spoke with NCCAOM board members about it at the ASA conference in Denver. Over a lunch that NCCAOM sponsored, they assured ASA delegates that they look out for all Diplomats equally. The next morning over breakfast, I showed them the Utah Associations to Utah license holders about the proposed rule change to adopt the herbal exam as a requirement. It had the NCCAOM letterhead at the top. They claim not to have authorized it, which is a good thing. They assured me that they were looking into. However, one board member said that NCCAOM does not get involved in pushing the Herbal requirement she said “it’s your state do what you want.” I pointed out to her that telling a licensing board or an association “do what you want” when it comes to adopting the herbal requirement is not looking out for all NCCAOM Diplomats equally. She had no response.

    • My conversations with people in the NCCAOM about what happened in Utah provided several example of the “talking out of both sides of their mouth” that I highlight in this post. For instance, although I had someone tell me they shouldn’t have sent out that email, they have not been willing to issue a retraction. For another, although they say they only support what the practitioners in the state want to do, they’ve been unable to provide any info. about how they determined what the practitioners in the state wanted. And, you’re right, even if it were true that they said, hey board, do what you want on this, they aren’t looking out for the majority of their Diplomates, who don’t have the herb credential.

      When they had previously said “they made a mistake it will never happen again” in response to their advocacy for the herbal requirement in Delaware. I believed them. I won’t make that mistake again.

      Also, it would be appropriate if they revealed in any testimony that requiring the herbal credential is financially beneficial to them.

  3. “This profession has a poor record of finding good solutions to big problems.” I support unity in the profession. NCCAOM is about the best group there is for unified view of the profession. The Dip is a flop. Most LAcs do not renew. Judging by the comments here acu folks do not seem to understand how acu laws work across states. Practice acts vary widely. This makes licensing look like it varies widely. Can you imagine this kind of imprecision with another health profession? It does exist but not among mainstream professions. That is the #1 problem. Acupuncture is not in the medical mainstream. Once this takes place then VA, Medicare, standard training, JOBS instead of almost exclusively private practice, become realities.

    I am co-author on an unpublished manuscript that accurately places the number of licensees in the USA at 37.5K. I was surprised. Why is this important? I would argue because standard information about who we are sends a message that we are “unified.” My co-author methodically contacted every board that regulates in each state along with the various member orgs and came up with the figure. We think LAc earnings differ quite a bit regionally.

    I really do not see the value in bagging on NCCAOM which is the most professional entity in the profession. They do not make a lot of dough. Pull their 990s along with ACAOM. The business that so many LAcs count on for “information” like how many of us are there and what is going with our “growing” profession makes much much much more.

    • Again, running, but, in short —

      1) You are correct, we’ve got a poor record and I don’t have high hopes of doing better with this issue. That’s one of the reasons why I’ve been so resistant to acknowledging, even to myself, my own misgivings about the NCCAOM.

      2) You have your own lack of understanding. The dip is in numbers of people TAKING the exams – that is, entering the profession. NOT those maintaining their credential. Though I am sure there is a dip there as well.

      3) Is there a reason to take an unpublished manuscript as definitive?

      4) I have yet to see a count that corrects for practitioners holding licenses in multiple states and those who maintain a license without practicing. Did you correct for that in your count?

      5) Yes, they are professional. I, personally, don’t take tremendous issue with their income given their big job. The value is to hold them responsible for the ways in which they screw up regularly, making life a lot harder for us, usually for no good reason. They aren’t honest or trustworthy. Since you don’t actually have to deal with them in order to maintain your means of income, I can understand why you don’t think their problems are a big deal.

      • here is NCCAOM 2016 return – http://990s.foundationcenter.org/990_pdf_archive/112/112760706/112760706_201612_990O.pdf
        1. Poor record? I would say we have a poor understanding of what defines a profession. Plenty of professions have been down the same road.
        2. Dip includes recerts which has not been much of a revenue generator. http://990s.foundationcenter.org/990_pdf_archive/112/112760706/112760706_201612_990O.pdf
        3. Of course not. Think what you like. Use your own data.
        4. Addressed in new paper which we are presently revising.
        5. Statements made under this item capture well the problems I have with your blog. Why do I read AO then? I like to stay current with how close the profession is to joining the mainstream.

        • 1. I was quoting YOU when I referred to a poor record. Are you disagreeing with yourself?
          2. Enrollment in our ACAOM approved programs is down something like 18% in 5 years. There has been a corresponding decrease in number of new practitioners sitting the exam. I am concerned primarily about our ability to meet the growing demand for acupuncture. I’m less concerned with the NCCAOM’s finances, except for the disconnect between their previous statements that they don’t make policy decisions based on what benefits them financially, except now, when they are using finances to support their changes in testing policy.
          3. Thanks.
          4. I look forward to it.
          5. Well, I’m pleased that it serves you.

    • How many of those licensees hold dual or triple licenses, I certainly do and have for 18 years. I know many, if not most of the LAcs I know, also do. if they are so short on cash, why have they spent who knows how much on moving their offices first to Florida, then to DC? Who paid for the moving costs of the employees? Who made money off real estate deals in Florida for the employees? Where exactly do we find out that information? Why have they made giving CEUs a huge burden and problem for providers? The volunteer who handled CEUs some years ago after their ceu policies changed said they spent 100 volunteer hours giving ceus to our NADA conference participants….. I would love to feel represented by a national group besides POCA and NADA. I do not. You can’t fix a problem if you dont understand what it is.

      • https://theacupunctureobserver.com/wp-content/uploads/2018/06/NCCAOM2012990.pdf

        (We’ll see if I did this right, but it should link to the NCCAOM 2012 990, which is the most recent one I have.)

        Again, the fact that they have money to move isn’t hugely important to me. I don’t mind them having money — though, yes, if they are making life harder for potential test takers in the name of saving money, then it would be nice to see them economizing where they could.

        I agree that the CEU system seems burdensome. And, yes, many folks have multiple licenses. I did link to some math I did on that topic in the post!

  4. One hundred percent agree! It’s becoming an organization similiar to insurance companies. You can’t do anything without their oversight, yet they make it nearly impossible for anyone to want to enter the field with outrageous fees and crazy testing procedures/policies.

    • Not just enter the field. Many of us have to maintain active status with them. And, their efforts to get us included in the VA system were great, but came with a caveat – if you don’t have active status don’t bother applying…..

  5. You need to write a blog about the NCCAOM getting into the business of granting CEU’s, while making it harder for private organizations to get CEU’s accepted by NCCAOM for recertification.

    • I did mention their CEU system. And it’s one of the things that really pisses me off. So many topics, so little time! If someone wants to write a guest post about that, I’d be happy to run it.

      I took an expensive and lengthy class that had previously been NCCAOM approved. However, the teacher didn’t go through the approval process for that particular offering of the series and didn’t, imo, make clear enough that it wasn’t NCCAOM approved. So, same material that others got credit for didn’t help me (other than the increased knowledge, of course, which should be the only important thing).

  6. Yes, I agree with you both; I never fully understood the importance of a biomedical exam. among other topics.
    I cringe, literally, every time I see an email from them,”What are they up to now?”
    Some little add-on/loopphole to make the recredentialing process harder?

    In some ways, I wouldn’t mind they make the herbal exam mandatory for everyone. I’d be jumping off ship. I don’t even do herbs; well, there’s time, Recredentialing in 2020.

    • The biomedical portion was ramped up, I believe, in response to the acupuncturists who wanted to add “primary care” and lab work to their scope.

      An even bigger question is why you have to learn “TCM” since ACAOM does not require schools to teach that lineage. I haven’t seen any evidence that practitioners who practice according to post-1950’s codified TCM have better results than those who treat according to 5E principles, or Tan and Tung styles, etc.

    • But, yes, you should absolutely care if they make the herb exam mandatory. For one thing, many of us must maintain active status to keep our license. I have no choice but to re-credential. The truth is, though, they probably wouldn’t apply that requirement to existing practitioners. But even if it is only applied to new licensees, it would have a big impact on us all. Imagine you want to hire an employee, or sell your practice — a new requirement, which involves more schooling, and therefore likely more debt, further slows entry to the field. Employees get more expensive, new practitioners are scarce. At a time when the demand for acupuncture is growing, people will get it somewhere. It would be beyond stupid to work against increasing the number of acupuncturists at the same time other providers are increasingly offering modalities like ours. I hope we’d focus on growing our own profession rather than fighting with other providers. But that seems like a silly hope these days.

  7. Thanks Elaine, for recognizing many of the things I have been saying for decades. I certainly understand that giving people or organizations the “benefit of the doubt” is sometimes a good thing. The truth is that I have never trusted the NCCAOM. Perhaps it is because I was involved in trying to stop several of their early initiatives, many of which I saw as damaging to the profession. Over the years I have grown tired of being ignored or told that I was not sufficiently informed about their intentions. But, in my opinion, very early on they became a source of toxicity with regard to the healthy development of our occupation (or profession) if you prefer. I don’t care to recount this history. I get nauseous whenever I think about it. I believe that they have overextended their empire and soon they will go the way of all empires. The real question is how do we want to move forward from here.

    • Once I began to write about the ways in which they have let us down, made mistakes, taken damaging positions, pulling it all together instead of thinking about each event (many of which I didn’t even mention in this post) as an isolated incident I felt sick. It’s like realizing that the problems with your partner or parent aren’t because they had a bad day, or have issues expressing themselves, or any of the other things stories you’ve been building – but signs of a much bigger problem. There’s a lot of pain there, but hope that with the new awareness there’s a freedom to act. It is scary, too. This profession has a poor record of finding good solutions to big problems. Let’s hope we can find some unity rather than more divisiveness.

    • Good work Elaine. Thank you.Thanks to Joseph for trying. It’s going to take more of us, obviously, or the dissolution of the field. Where does one find their budget and financial information? II used to have a link to a site that reveals all nonprofit filings and budgets…… In Louisiana, when I was working on the NADA law that also got the MD employee requirement off the necks of LCS, they flew down to “help”. But the only “help” they would provide was testimony as to why they should put NCCAOM requirement in the law. They offered to send someone “on a day’s notice” to testify for that. Meanwhile, a LAc was headed to the Louisiana Supreme Court, challenging the requirement to be supervised by an MD……with a lawyer who had already been to the Louisiana Supreme Court and WON… the LAc suddenly died (never found out why), the lawyer wanted to run with it anyway and challenge them, , he was convinced he would win, but NCCAOM would not support that in any way. So it died right there. But Louisiana had no desire to put NCCAOM in the law, so as far as I know, it did not make it into the law. And many of my memories cause nausea. I’m sorry I’m not alone….

      • You can get some financial info from their annual reports, which are available on their website. There is also a Federal form that is on the public record, that they file with the IRS each year. I am running out the door and can’t get, off the top of my head, find a copy or remember the name of the form. Perhaps another reader can weigh in – or I will try to get back to you.

        But I relate well to your story about LA. The NCCAOM is great at showing up to testify on their own behalf (which is not a surprise) but they often pretend they are doing it for the good of the profession when it is anything but. Certainly in Utah, they stand by a letter expressing their support for adding the herb requirement saying it’s what practitioners wanted. Well, a few did want it, but many more didn’t. And, after DE, they certainly gave the impression they wouldn’t take a pro-herbal-requirement position again. But somehow, I guess, they found a different standard for UT.

        Like I said, there’s a lot of double-talk and varying position statements depending on their immediate goal. It’s frustrating.

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