Who determines your professional future? First, read An Example of one person, wearing two hats, limiting opportunities for LAcs. (He’s received honors for the work he’s done.)

We have one week to comment on the NCCAOM’s “proposed” policy changes. Do that here. Some of us think these changes are wise, some of us wouldn’t be personally impacted. We all should participate in the conversation. Ask your professional communities to comment. (You can see the NCCAOM’s response to my initial comments here.)

My follow-up comments are below. The NCCAOM is the most powerful organization in our profession. I have seen them, with our help, control regulation (or essentially subvert it) and legislation. Our interests may overlap, but don’t think your future is their primary concern.

Dear NCCAOM and Ms. Basore,

Thank you for your response regarding the proposed policy changes.  Here are some additional questions and comments.

  1. You wrote “The Criminal Background Screening Program for new applicants will not take effect until January 2014.” Has the final decision to implement these policies been made?
  2. The Criminal Background Check and language requirements go beyond your mission as a “national organization that validates entry-level competency.” These policies usurp the role of state regulatory boards. (For example, Virginia exempts those serving certain communities from our language requirements.)
  3. Many states use the NCCAOM exams but do not require the NCCAOM credential. Establishing background checks and language requirements as part of the testing application circumvents those states’ specific desire to maintain an independent credentialing process.
  4. How many students responded to the assessment regarding the foreign language exams and what were their responses? Please define the demand “sufficient to offer a psychometrically valid defensible examination.”
  5. Is it significant to an applicant if the background check fee goes to the NCCAOM or to a third party? Could NCCAOM staff involvement ultimately increase exam costs?
  6. Can you describe the criminal background check appeals process? Would the NCCAOM risk legal liability if applicants were allowed to sit the exam upon appeal?
  7. Is there any documented case of harm from practitioners who had a criminal history at the time of sitting the exams?
  8. If public protection is the justification for requiring the background check prior to examination, should it be required prior to school admittance? This would protect individuals from making a huge investment in a career they will ultimately be unable to practice.
  9. Could the recertification process be simplified by trusting Diplomates to use their best judgment regarding continuing education?  Has there been any documented patient harm as a result of unreviewed or unmonitored continuing education?


I believe that for much of the past twenty years the NCCAOM has provided a net benefit to the profession while honoring its commitment to the public welfare.  More recently the NCCAOM has repeatedly acted out of self-interest, choosing control over the profession and the attendant financial rewards ahead of either the profession or the public. Your push for the full OM credential as a requirement for licensure in DE is a prime example of action that served the NCCAOM at the expense of all others. The stakeholder comment you request is routinely disregarded.

Re-consider these proposals. Acupuncture practitioners have an incredible record of safety. The imposition of additional de facto regulation is unnecessary and burdensome.


Elaine Wolf Komarow, LAc (VA)

NCCAOM Diplomate (Ac)


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© 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.

4 thoughts on “Control

  1. Hi Eric,

    Thank you for your supportive and caring comments. I appreciate your position and the position of the observed. I am currently back in school for my third master’s in OT. I am hoping to combine them and continue acupuncture on another level. I believe this will be the answer for me. I am angry at our leadership in acupuncture and the poor directional choices they have made. We will all pay a price for that and many of us have already. I can’t help be angry with those individuals.

  2. I think the answer is that they don’t care and haven’t cared for many years. If they had cared and fought for us the way they should have our profession would not be in this place to begin with. I appreciate your efforts and respect what you are doing but I truly believe it falls on deaf ears. I have been listening and really understanding from the western world and our world. Recently, the Bureau of Statistics have declined Acupuncture to be listed as an Occupation. Reason: because other professions use it as a modality and it does not need it’s own clarification. That said it all to me. We have lost the war. It is just a matter of time. I am truly sorry about it. I can’t go down with this ship. I hope all of you find a way to continue to practice because what we do is valuable.

    • The BLS decision only matters if we continue to believe that incorporation into the system is the path to success. I know acupuncture is an occupation — I do it all day. If we walked away from the ongoing delusion that more regulation and “higher” standards and having clients give their money to some third party so that we can get some of it back, and instead went back to doing what we used to do we’d be fine. We have created this mess. It is close to being too late to doing something about it, but it isn’t yet, if we open our eyes.

    • Susan,
      Don’t give up. Our healing art has survived thousands of years and will survive this ego driven, mishandling of how acupuncture fits into the system. The best revenge is success. The beauty of our profession is that there’s still multiple ways to earn a living. If you don’t like the way “they” are defining the direction of the profession, do it your way and be a success while you still can. The public needs our services and if you have graduated and are licensed, you have what it takes to practice.

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