Dry Needling and Acupuncture 2015 – The State of the Profession

Dry Needling wins again – it receives “the greatest threat to the profession” practitioner’s choice award.

In recent years, Acupuncturists have devoted more resources to this issue than to any other.

A (fairly accurate) review of legal and regulatory actions shows that we’re not having much success. (Here’s another review, APTA’s Dry Needling Resource Paper.)

Even our wins have been temporary. For example –

– the Georgia Acupuncture Board added language stating that Dry Needling is acupuncture. The PT’s then added Dry Needling to their scope via legislation. (Could Georgia PT’s now advertise they’re doing acupuncture?)

– the October 2014 ruling in Washington State against dry needling was widely celebrated. Now the PT’s have introduced bills which would add Dry Needling to their scope. With almost 5,000 PT’s in the state, and about 1,100 LAcs, it’s likely they’ll eventually succeed.

We say the PT’s:

  • are stealing our medicine! (But we don’t own it.)
  • are illegally expanding their scope. (The majority of states have ruled it is in the PT scope. Modifications to scope are common in health care.)
  • are using Regulation to do what should be done Legislatively. (Scope clarification is often done via Regulation, which gives the public and other professionals the opportunity to weigh in and is preferable to politically driven legislative action. The public is protected through regulation. The PT’s have been successful in passing Legislation allowing dry needling.)
  • are pursuing this because their own techniques don’t work. (Even if true, 1) why does that matter, and 2) does the argument apply to us when we add techniques lasers, essential oils, e-stim, herbs –  to our scope?)
  • can’t possibly know enough to do this technique safely. (Many clearly do.)
  • can’t possibly be providing good treatments. (Their patients disagree.)
  • wrongly say that dry needling isn’t acupuncture. (Is it better if they say it is? Is there a legal reason our definition should prevail?)
  • make the public fear acupuncture. (Insisting this technique is acupuncture will contribute to the problem. Don’t we have the same problem when we use the technique?)
  • should use hypodermic needles. (Does that show concern for public safety?)

We can continue the fight to stop dry needling – getting caught in the cycle of suit (complaint) (never-mind the SCOTUS ruling) and counter-suit (NC PT lawsuit). We can fight state by state, and attack any Acupuncturist who suggests anything other than “the PT’s must be stopped.” We can keep insisting that if we just devote more resources and fight harder, we’ll win.

Or, we can learn from our history and the history of all of the other professions that have fought to maintain a monopoly on technique or turf.

We could be fighting for strong regulations. Mandated adverse effect reporting, strict definitions of what dry needling is and what it isn’t (other than whether or not it is acupuncture), requiring direct supervision for all clinical hours, requiring PT’s to post their hours of training, requiring registration with the PT Board, requiring physician referral for dry needling – all of these are possible.

A PR campaign promoting acupuncture and helping the public find an Acupuncturist? That’s possible too. Supporting ease of licensure so that people in every state can find an LAc? We can work for that. Support for new practitioners so that the public can actually find an Acupuncturist? That’s a great goal. Building collaborative relationships with other professionals who want to decrease pain and suffering? That would serve everyone.

Putting our energy into stopping dry needling? Not so much. It’s our obsession with stopping dry needling that is the greatest threat to the profession.

 

 

Acupuncture Education 2015 – The State of the Profession

If we want people who want acupuncture to receive it from an Acupuncturist, acupuncture education deserves our attention.

There aren’t good statistics on how many Acupuncturists or acupuncture students there are in the US. But those handy maps printed in Acupuncture Today can give us some idea. The December 2013 issue (with an article on AT’s unprecedented growth) showed 24,342 Acupuncturist and 3,124 student issues mailed. In December 2015 – 24,231 Acupuncturist and 2,624 student issues mailed. That’s not growth. The 2014 NCCAOM Annual Report (the most recent available) also reveals – we are not a growing profession.

There is a lot of churn in Acupuncture education — schools close, schools open, programs merge, new degree programs are established. New Gainful employment rules adopted in late 2014 may well contribute to that churn. They require for-profit schools (about 50% of acupuncture programs) to provide at least some debt and jobs data to prospective students.

Small class sizes can skew the data. Still, check out these reports (selected because they came up first in Google): Emperors, ACAOM (the school not the agency), Arizona School of AOM, Midwest, AIAM, and Colorado School of TCM.

Only two schools reported job placement, at 50% and 67%. Median loan amount (omitting a 1.5 million figure given by Midwest that must be a mistake) ranged from 17K to 72K. A real eye opener was the percentage of students completing the program in the expected time frame. The average across all 6 programs was 55%. Omit the 100% reported by Arizona, currently on probation with ACAOM (the agency), and it’s 46%.

It’s not encouraging. Add student uncertainty that the degree they obtain will enable them to practice and it is no surprise our profession isn’t growing.

Imagine if we could tell prospective practitioners –  “A Master’s Degree in Acupuncture from any ACAOM accredited program will fulfill the educational requirements to practice in any state.”

I may not love the ACAOM standards but I’ll accept them to help the profession. Is there a downside to offset the upside?

NGAOM you have a stated goal of establishing uniform standards, yet are fighting to keep California schools out of the ACAOM system. Please explain.

We had some significant losses in Acupuncture education in 2015.

Spring brought news that Dianne Connolly and Bob and Susan Duggan would no longer teach or be part of the program at MUIH (which Bob and Dianne founded in 1974 as The Maryland College of Chinese Acupuncture). Bob and Dianne are part of the foundation of this medicine in the US. They profoundly influenced my acupuncture journey and it is a significant loss that they won’t be part of every MUIH student’s education. I am glad they are continuing to teach and share their wisdom in other settings.

Bob Duggan played an integral role in establishing acupuncture standards, credentials, agencies, and commissions. His goal in so doing was to enable this safe and effective medicine to be legally available to more people. He shared in a personal communication his ambivalence at how things turned out – that though his work enabled so many people to be healers and to be healed, “If I had real courage I’d have gone to jail and insisted this was the people’s medicine and we shouldn’t allow it to be professionalized.”

2015 closed with another loss, the death of Dr. Richard Teh-Fu Tan. Dr. Tan was an excellent teacher, deeply committed to teaching. Directly, and through his students, he eased the suffering of countless patients. Dr. Tan made no secret of his doubts about the caliber of acupuncture education most of his students received in their degree programs. Many seminar attendees reported learning more about effective acupuncture in four days with Dr. Tan than in four years of acupuncture school.

Attention must be paid.

 

 

 

 

 

 

Herbal Regulation and the Acupuncture Profession – A Better Way.

We’ve got competition. PT’s, MD’s, and DC’s are excited about filiform needles and LAcs are freaking out.

While our energy has been focused on that competition (our training and skills are superior, right?) we haven’t been paying attention to increasing restrictions on our ability to practice the fullness of our medicine. Adding insult to injury, the restrictions on practice are “coming from inside the house.”

I’m talking about restrictions on our use of herbs.

Yes, herbal medicine is powerful and complex and carries both potential risk and potential benefit. Yes, it takes many thousands of hours to come close to mastery of this branch of our medicine. Yes, people have been harmed by the improper use of herbs and supplements. And, yes, at some point the damage done by the misuse of herbs may result in stricter regulation. We may indeed lose access to more herbs.

It’s good that we want to be proactive, protecting the public and the profession from harm. It’s not so good if our actions don’t have the desired result. And not good at all if our actions increase risk to the public and the profession.

Let’s consider the terrain —

  • What portion of harm from herbs/supplements is the result of poor practice by Acupuncturists?
  • What portion of harm from herbs is from the use of raw herbs, what portion is from pre-made herbal formulas?
  • Does preventing certain LAcs from recommending herbs or supplements limit public access to these products?
  • Is the average LAc, even without herbal training, likely to have a positive or negative impact on client’s proper use of herbs and supplements?
  • Which are better tailored to the individualized treatment that is a hallmark of Chinese Medicine — pre-made/patent formulas or raw herbs?
  • Which are more likely to be contaminated with banned substances or prescription medicine – patent formulas or raw herbs?
  • Is it possible to draw a bright line between dietary therapy and herbal therapy?
  • Does limiting LAc recommendation of herbs interfere with the ability of other health care providers or salespeople to recommend or sell herbs or supplements?

See where I am going with this?

Anyone can get Chinese herbs, even dangerous ones. Increasing the regulatory burden on Acupuncturists would make sense if it would protect the public or our access to the full pharmacopoeia on an ongoing basis. It would make sense if LAcs were routinely endangering the public through unregulated use of herbs.

It doesn’t make sense for a subset of our profession to become the only group of health professionals not able to recommend herbs to their clients.

If the only groups weighing in are the schools and NCCAOM, formal (and expensive) training and credentialing will be increasingly required.

Let’s stand united against unnecessary restrictions. LAcs have an excellent safety record. Stay tuned for real-time developments and your opportunity to weigh in on the regulation of herbal medicine for Acupuncturists.

 

Acupuncture Licensing and Regulation – The Future

Imagine that your acupuncture license meant you could easily practice in every state.

Imagine that licensure exams focused on the skills and knowledge needed to practice safely.

Imagine that acupuncture schools used the time spent teaching things “you won’t need in practice but they’ll be on the exam” to teach things that you really will need in practice, including all that business stuff.

Imagine that acupuncture boards, associations, and organizations worked to make it easier and less expensive for practitioners to obtain and maintain licenses and practice within their skill set.

I wish I could say “it’s easy if you try” – but for most of us it isn’t. (Unless you look to other professions.)

The Florida Acupuncture Board now requires all new practitioners to spend thousands of hours and tens of thousands of dollars on additional education and testing to become Board-certified in herbs. Even though there was no evidence of public harm under the previous rules, and even for those who won’t use herbs in practice.

The Nevada Board is trying to change the regulations to require a DOM or DAOM of all applicants (about 40K on top of an 80K MAOM). Not because there is evidence of public harm, but because that’s the way it is in China. And never mind that the entire state is served by fewer than 50 acupuncturists.

In July 2015 the White House released Occupational Licensing: A Framework for Policymakers. While acknowledging that licensing can provide health and safety protections to consumers and benefits to workers, it concludes,

“State legislators and policymakers should adopt institutional reforms that promote a more careful and individualized approach to occupational regulation that takes into account its costs and benefits, and harmonizes requirements across States. If they are successful, the collective effect of their efforts could be substantial: making it easier for qualified workers to find jobs and move where they choose, increasing access to essential goods and services, and lessening heavy burdens on certain populations….”

Acupuncturists are the policymakers in our profession. Wouldn’t it be great to determine what’s truly needed for public safety and to adjust educational and licensing requirements accordingly? Rather than blaming others for our difficulties, wouldn’t it be more productive to direct our energy to changing the things we can control? We can demand that the insurance companies pay us more because our education cost so much, or we can make our education less costly. We can sue the PT Boards to try and protect our turf, or we can make sure that anyone who wants acupuncture is able to access convenient and affordable services from an acupuncturist.

I’ll be sharing actions you can take to change our practice environment for the better. Like the Acupuncture Regulation US page on Facebook and stay tuned in here, at The Acupuncture Observer, for updates.

 

 

 

Acupuncture Safety, and, a Matter of Fairness

Protecting the public safety is a good reason for regulation.

People have been injured by PT’s or Chiropractors doing dry needling.  When we see a story about that we share it. So I understand the comments on the previous post.

And, there were two recent threads on Facebook that caught my attention.

An LAc posted a question about whether it was possible to cause an infection by needling CO4. He’d treated a patient who later developed redness at the area. The patient visited an MD and was prescribed an antibiotic. I was surprised at the practitioner’s question, and surprised and mortified at the responses.  Which included: The MD is just trying to cover his ass, they just like to prescribe antibiotics, not if you used sterile needles, not if you used an alcohol swab on the area first, people freak out all the time, etc. A day or two later, the initial questioner reported that the patient was now hospitalized with a staph infection.

Another LAc wrote that a patient reported she’d had a pneumothorax from a treatment and was now asking for financial compensation for a portion of the medical expenses and several weeks of missed work. What should the practitioner do? Of course, getting some documentation makes sense, but the responses also included: if it really happened why doesn’t the patient have a lawyer, if you’d given her a pneumothorax you would have known it immediately, she must have had some sort of underlying medical condition so you aren’t responsible, etc.

Personally, I know some amazing practitioners who have firsthand experience with pneumothorax(i?) on both ends of the needle.

I don’t believe we have sufficient record keeping to know the relative safety records.  Dry Needling does involve a deep and aggressive needle technique and so is more likely to do damage.  That’s true even with an LAc holding the needle.

When a story comes out that involves harm done by an LAc, we make all sorts of excuses and focus on our generally good safety record. When we find out about damage done by a PT or DC, we trumpet the news, and make smug and superior comments.

When it comes to fairness, most of the things I hear LAcs complaining about are either self-inflicted or, sometimes, imagined.  The length of our training — we’ve been behind the increase. The differing insurance reimbursement — is that insurance thing working out for anyone?

This post is mostly blogger’s prerogative to give what is really a comment on the previous thread a higher visibility.  I won’t make a habit of it.  But hwds’ are one of my pet peeves — that’s hypocrites with double standards, and when our response to what happens at the pointy end of the needle seems to vary so much depending on who is at the handle, I think that term applies.

 

 

It was Twenty Years Ago Today

….. that I was granted my Virginia Acupuncture License (#4). I’d been licensed in Maryland for a few months, but the Virginia License was special. Throughout my years of acupuncture school I’d been involved with the Acupuncture Society of Virginia, working to establish a practice act. We were finally successful in 1994, and my documents were ready and waiting when the regulations were promulgated.

I’m happy I found this wonderful medicine when I did. I feel lucky to be doing this work, and look forward to continuing to practice for decades to come. And yet, these days, I’m mostly sad about the acupuncture profession.

Back in the day, when only MD’s could do acupuncture in Virginia, we argued that the public should have the right and the ability to choose their provider.

We discussed how our medicine could treat the whole person, and that treatments were uniquely tailored to the individual.  We didn’t see patients as a collection of ailments, to be sent from one specialist to the next.

We talked about the good value of our medicine and our belief that it could reduce health care spending.

We got used to the medicine being dismissed by the medical establishment, but held out hope that, some day, they would see the value of what we did.

We knew that this medicine would require lifelong study and learning, but experience told us that about 1500 hours of training was sufficient to produce competent practitioners.

We were happy when we were finally able to receive student loans to attend acupuncture school.

We had concerns about relying on one standardized exam as a precursor to licensure, especially one that was based primarily on one tradition. But we knew that it would relieve some of the burden on the states, and so might help with national acceptance.

It was a time of promise.

Now, my Facebook feed is full of rants — we’ve now decided that, just as the MD’s wanted to protect the public from us, we now must protect the public from the PT’s.

Rather than celebrating the professionals who see the value in this medicine and want to offer it to their clients, we scream that they are stealing our medicine and must be stopped.

We’ve justified our increasing fees (after all, if the MD’s deserve it, we deserve it), and, then chased the insurance dollar so that our patients can afford our services. We’ve adopted the billing games that come along with that, fudging fees, adding services, figuring out what diagnoses to use to get reimbursement, and expressing outrage when we’re called on our behavior. Some of us have gone so far as to attack those who have designed a system to make acupuncture truly affordable to the majority of the population.

We decided that more education would get us more respect, and so increased and increased, and increased again the hours required for entering the profession.  The number and complexity and cost of the exams increased. In a solution to a problem that didn’t exist, practitioners in some states decided an acupuncture education was not enough.  Acupuncturists now must also learn and be tested on herbal medicine, whether they want to use it or not. Various states added additional requirements, so any relocation runs the risk of shutting a practitioner out of the profession. The student loans we celebrated enabled schools to ignore the disconnect between the cost of the education and the likely income of graduates.

I could go on. I won’t.

Shaking my head at the missteps we’ve made, I comfort myself with the confidence that the medicine will survive, even if the profession won’t. Happy Anniversary.

 

 

 

17 Foundational Beliefs of The Acupuncture Observer

Embracing the season of gratitude and thanks, it’s time for The Acupuncture Observer to take a step back and share some of her foundational beliefs about the medicine, the profession, and life.

  1. Acupuncture/OM works. The unique situation of the patient and the unique skills of the provider influence effectiveness. No single tradition provides all of the answers or benefits.
  2. Acupuncture/OM has fewer negative side effects and risks than conventional treatment for many conditions.
  3. Access is a necessary precursor to effective treatment.
  4. Effective treatment will increase wellbeing and could decrease health care costs.
  5. Every means to increase access carries trade-offs. Those trade-offs must be understood as we determine our path forward. We should learn from the experiences of other professions.
  6. Understanding and explaining the mechanism of acupuncture from the knowledge base of modern biology and physiology is useful and interesting, but is not necessary for acceptance by the medical establishment.
  7. The current “science-based” understanding of health is known to be limited. Insisting that Acupuncture/OM be taught, thought of, or explored only in the language of modern medicine/science is unscientific and risks centuries of experience and wisdom.
  8. Consumers should have significant freedom of choice in health care. Understandable and clear information about potential benefits and risks, as well as an exploration of the costs (financial and otherwise) is necessary for good decision-making.
  9. Self-serving thinking leads to hypocrisy. Special attention is needed when an argument for patient protection creates an economic benefit for particular providers.
  10. Simple, easily learned treatments can be effective and safe.
  11. There is the potential for growth and success within the acupuncture/OM profession.
  12. Many acupuncture programs do not provide sufficient or accurate information about post-graduation life and do a poor job of teaching business skills. This can be changed easily and inexpensively.
  13. The financial and karmic ROI (Return on Investment) of positively promoting our profession is superior to that of engaging in political/regulatory battles with others.
  14. The future of the medicine and of the profession are interconnected but not identical.
  15. Thoughtful and respectful analysis can identify areas of common ground.
  16. Focusing on areas of common ground decreases factionalism, and builds unity, understanding, and participation.
  17. The profession lacks venues for respectful dialogue on these issues. As a result, many scholars and potential leaders within the profession avoid involvement.

Do we agree on some of these? Can respectful dialogue increase the areas of agreement? What if we read the Tao Te Ching, the I Ching, and The Art of War first? What if we go deeper than our Wei level response to some of these issues? I believe it is possible that we’ll be able to find a new path forward, one we can walk together, with our hair flowing free. After all, I’m an acupuncturist.

Talking about our Education

“We have over (2000 hours, 4000 hours, 3 years, 4 years) of education and they want to do acupuncture with (a weekend, less than ten, 200 hours) of training!The public is in danger.”

“The (PT’s, Chiropractors, MD’s) doing acupuncture are significantly undertrained! If they want to do acupuncture they need to go to acupuncture school, or at least take (400, 500,1000) hours of training.”

It’s a no brainer, right? But ….

1) We are comparing our total professional education to additional post-professional-degree hours.

An MSAOM curriculum includes: Biochemistry, Introduction to Organic Chemistry, Anatomy and Physiology, Microbiology, Introduction to Western Pathology, and a Survey of Western Clinic Sciences (3 semesters). M.D.’s have already covered these classes in their education.

2) Does the aspect of “our” medicine they want to use require a full TCM education?

Is Tai Qi, Qi Gong, Introduction to Botany, 40 credits of herbal medicine, a semester of auricular acupuncture and 3 semesters of point location needed for a PT to safely use a needle to release a trigger point? (If you insist they learn all of that, won’t they then argue that they can also do auricular acupuncture and distal points?)

3) How well-educated are most acupuncture school graduates? How worthwhile was most of their time spent in school?

ACAOM standards were based on the programs that existed at the time credentials were being established. They were not based on a careful analysis of what was needed to train safe, effective, successful practitioners. Acupuncture related Facebook groups include posts asking about using moxa to turn breech babies, how to treat TMJ (no pulse, tongue, or presentation information provided), and recommendations for treating people undergoing chemotherapy. With our thousands of hours of training, shouldn’t we know the answers to these questions? (Or have a better source than Facebook for answers?)

4) Is there a correlation between the length of a program and the quality of the graduates? Were the early U.S. practitioners (many of whom had less than 1300 hours of training) harming the public?

It is an article of faith in the acupuncture community — our training of X hours is necessary for safety, and anything less is an affront and a danger. Yet a colleague recently wrote “I am at a medical acupuncture conference. Exceeding my expectation. The presenters know their stuff. Lots of depth…. I am going to find out about their training. Maybe they are a special group….what i am seeing here meets any high standards TCM conference…. Very surprised.”

The more (as defined by us) = better has done us no favors. The numbers we fight for are arbitrary. The argument is easily refuted by other providers. Adopting it within our profession has increased the business strangling debt-burden new grads carry. And created internal divisions which only further harm our growth. (How long before a state (or the NCCAOM) demands the FPD to become an LAc?)

Please, let’s let the knee-jerk “less is dangerous, more is better” argument go.

Licensure News

Finally! At the May 6th Delaware Board of Medicine meeting two experienced and NCCAOM-credentialed acupuncturists were granted Delaware licenses, bringing the number of the LAcs in the state to just under forty. This is good news for the people of Delaware. It is also good news for the profession as whole. And hopeful news for the practitioners who are now commuting to Maryland, or not practicing, because they were unable to obtain a Delaware license.

Why did it take action from the MD’s on the BOM to get these practitioners licensed?

These LAcs had appeared before the Acupuncture Advisory Board four times since applying for licensure in late 2012/early 2013. At several of these appearances the Acupuncture Advisory Board members acknowledged the applicants’ excellent qualifications but refused to grant licenses despite having the authority to do so.

For decades one of our “sacred cows” has been that we need our own boards. Then we’ll have the power to control our destiny. Sadly, when given the chance, some of us prefer to control our destiny right down the tubes.

Consider the history of the independent California Acupuncture Board, with its unique accreditation and exam process, and its ongoing problems. Or Nevada, with an independent board, 53 LAcs, a $1000 application fee and $700 per year renewal fee.  If Delaware had an independent board my colleagues would have had to go to the courts to present the argument (made by a public member of the Board of Medicine) that requiring an herbal education and exam for individuals who do not want to use herbs in their practice, in a state in which anyone can sell and recommend herbs, is restraint of trade.

It isn’t the M.D.’s and “the system” that is limiting the growth of our profession these days. It is other acupuncturists. I’ve asked and asked, but I have yet to find anyone who can explain why the Florida (independent) Acupuncture board is increasing the education and testing requirements for licensure. Have patients been harmed? If a change is needed are there options that would be less burdensome for the profession?

I’ll be interested to see the full minutes of the May 6th DE BOM meeting. In a classic conjunction of issues, a practitioner instrumental in drafting the restrictive Delaware law, and a current Acupuncture Board member who had voted against granting licenses to the two qualified acupuncturists, appeared before the BOM to ask them to do something to stop PT’s from doing dry needling.

Did either of these practitioners consider that their previous actions that limit the number of LAcs in Delaware increase the odds that citizens will seek treatment from non-LAcs? Or that our political power is limited by our small numbers? Did the BOM wonder what’s up with this profession — they don’t want anyone to use a needle, even other LAcs?  (FWIW, the BOM doesn’t regulate PT’s.)

You’d think that our own self-interest would prevent the credential and educational creep that costs us so much. But it hasn’t. The AMA Code of Medical Ethics states “A physician shall respect the law and also recognize a responsibility to seek changes in those requirements which are contrary to the best interests of the patient.” Restrictive laws and rules that limit access to qualified acupuncturists are contrary to the best interests of patients. Let’s work for change – for the people who need acupuncture and the qualified individuals who want to provide acupuncture. Credential creep hurts us all.

A Call to Action

We have an opportunity to help Californians, and all acupuncturists, but we need to act now. As I’ve written before, states setting their own super-special requirements for acupuncturists seeking licensure is expensive and limiting for practitioners and the profession. I’ve never seen evidence that the public benefits from such requirements.

California has been one of the worst offenders. An exploration of the unique educational requirements can wait for another day, but we now have an opportunity to do something about the exam.  (Please note – much of what follows is based on my best understanding of the situation from respected colleagues in California.  I have not been personally able to fully research the California situation.)

The California exam has had problems for years, among the lowlights — a California Acupuncture Board (CAB) chair sent to prison for selling the exam; a point location exam shown to be so subjective that the State mandated that the CAB cease using it; incidents of extremely high failure rates and serious scoring errors; and CAB’s refusal to compare two exams for possible unfair scoring.

A recent Sunset Committee is turning up the heat on the CAB. Senator Lieu, the Sunset Committee chair, may support a bill that will allow potential licensees to take the NCCAOM exam rather than the California state licensing exam. It is time to let the Senator know that this change would benefit the people of California and all acupuncturists.

Please send emails this week to:

marty.block@Sen.ca.gov, ted.lieu@sen.ca.gov, tom.berryhill@sen.ca.gov,
ellen.corbett@sen.ca.gov, cathleen.galgiani@sen.ca.gov, ed.hernandez@sen.ca.gov,
jerry.hill@sen.ca.gov, alex.padilla@sen.ca.gov, lark.park@gov.ca.gov, Anna.Caballero@scsa.ca.gov, Denise.Brown@dca.ca.gov, Tracy.Rhine@dca.ca.gov, Sonja.Merold@dca.ca.gov, LeOndra.Clark@sen.ca.gov, kimberleywoo@sbcglobal.net, bluelotushealth@gmail.com, blueheartacu@gmail.com, crystal.clk@gmail.com, Spencer.Walker@dca.ca.gov

Some possible language —

I formally request that the Sunset Review Committee mandate that the CAB and staff use the national certification exam (NCCAOM) as the main exam for California Acupuncture licensure.

The NCCAOM exam is widely known to be a fair and comprehensive exam. It is relied upon in almost every state except California. Those practitioners who are credentialed by the NCCAOM have an excellent safety record. To require a unique exam for California, especially one shown to have ongoing problems, increases expenses for all California practitioners, costs which are ultimately borne by the public.

I urge you to require the use of the NCCAOM exams as the main exam for CAB licensure.

Thank you for your consideration.

We will all be better off when meeting one set of standards allows us to practice anywhere in the country. Changing the situation in California would be a wonderful step in the right direction.