Dear Ms. Ward-Cook, NCCAOM Board of Directors, and NCCAOM staff:

The selection of Chief Executive Officer is a critical time for an organization. Continuity might be the primary goal when a business is thriving. When things haven’t been going well, the best choice might be someone with a fresh perspective and a willingness to shake things up.

As you know, the number of people entering the profession has dropped significantly. Without a change, the growing demand for acupuncture will increasingly be met by people who are not Licensed Acupuncturists. The profession we have worked so hard to build is at risk of becoming little more than a footnote, even while acupuncture itself becomes widely accepted. We must face this issue head on. Every decision made by our organizations must consider which choice supports growth of the profession, and which will contribute to our demise.

With such a small profession anything that divides us, or limits opportunities, is problematic. So is anything that inflates the cost of our education or entry to the profession. These all increase the odds that an interested person will choose another profession, or, having entered the profession, will struggle to succeed.

Over the years, the NCCAOM has made a number of decisions that have, in fact, divided us, limited us, and complicated educational choices and entry to the profession.

I hereby request you select a CEO committed to change, so that the NCCAOM can be an organization that unites, and that removes any barriers for entry to the profession that are not necessary for the protection of the public.

Your new Chief Executive Officer should –

  • Understand that it is in our best interest that everyone who passes the NCCAOM exams finds it easy and inexpensive to obtain and maintain their NCBA (Diplomate) status. In the absence of any findings of unsafe practice, active status should renew automatically, and at a minimal cost. With such a small number of practitioners, we can’t afford to exclude any competent and safe practitioners from employment or licensure. As it is, significant numbers of Licensed Acupuncturists are excluded from job opportunities even after passing the NCCAOM exams. The current system of CEU verification is complicated, and has no measurable impact on practitioner quality.
  • Develop exams that test only what is necessary for safe practice, focusing on crucial tasks and red flags. No particular lineage has been shown to be safer or more effective than any other. Testing requiring knowledge of one specific lineage adds to the cost of an education, complicates school choice, divides the profession, and increases NCCAOM expenses, all without benefit to the public. Since knowledge of a particular lineage is not required for competence, a Job Task Analysis focused on knowledge of a lineage is flawed and must be redesigned.
  • Fight any attempt to exclude any Licensed Acupuncturist from practicing to the limits of their knowledge and experience. The NCCAOM should never support efforts to limit, for example, the use of herbs to any subset of acupuncturists. They should be clear – the herb credential is optional, and acupuncturists without that credential should not be disadvantaged compared to all other individuals in a jurisdiction. Using resources gathered from Diplomates to support efforts to limit their practice feeds resentment and division. The addition of requirements for the herbal credential limits opportunities for practitioners, increases barriers to practice, and increases educational costs.
  • Ensure that the NCCAOM changes policies or procedures only after extensive consultation with all potentially affected parties, allowing us to minimize and mitigate harm. Changes that lead to additional costs or stress to students, schools, and licensing boards work against success and growth.
  • Prioritize execution. User friendly and functional portals are important. So is accurate information. Errors (such as incorrectly reporting licensure requirements) can have a huge impact on educational choices and employment decisions. For practitioners who have a choice, a frustrating hour spent fighting with the recredentialing process can be a deciding factor in whether or not they maintain active status.
  • Keep the focus on the core of the NCCAOM’s mission – ensuring the safety of the public through credentialing Acupuncturists. Lobbying costs money. Taking a position on a matter of politics leads to division and disappointment. The NCCAOM needs to minimize expenses for Diplomates, not use our money to fund activities that we may not support.
  • Leave education to the schools. When the NCCAOM develops educational programs, such as content for the CHCS COQ, it increases concern that the NCCAOM could one day move to make this certificate mandatory due to self-interest. Likewise, the approval system for CEU’s adds to the cost of classes and complicates maintaining certification. This system has no discernible benefit to the public, and stands in marked contrast to the practice of many other credentialing bodies.

I’ve held NCCAOM certification for the past 25 years. I have spent decades as a Board member – of my State Association, State Regulatory Advisory Board, and even the AAAOM. I know that many of my colleagues are quick to demand action, resistant to reconsidering their positions on issues, and eager to place blame. I know it’s frustrating to work hard to give people what they want, only to be criticized for your efforts.

I write now as a Licensed Acupuncturist, and do not speak for any other group or organization.

The existence of a national credential was a great help during our efforts to establish licensure in Virginia in the early 90’s. Over the years I have defended the organization countless times. But when I last renewed my board certification I had to grit my teeth.

As it stands, I’m no longer clear that the NCCAOM is a net benefit for the profession. I don’t trust you to look out for my best interests, even though I’ve been a Diplomate for all these years.

I would like to be able to defend you again. I’d like to know that you had my back. That my fees weren’t being used exclude me from practice. That lapsed status wasn’t keeping colleagues out of the profession. That your exam didn’t require people to learn a lot of information they’ll never need to practice safely. That my fees weren’t being used to fund futile turf wars. That the information you provided could be trusted. That your systems worked. And that when concerns were brought to your attention you didn’t deny or evade or misrepresent what happened.

It’s time for a CEO who understands the changing landscape, and understands that without a change in direction there will be no profession left to protect. For the sake of the profession, and the future of all of us associated with it, I hope that you choose wisely.



Elaine Wolf Komarow, LAc, Dipl.Ac. (NCCAOM)




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.

45 thoughts on “Dear NCCAOM

  1. Very well done letter, many of your points echo issues for which I’ve contacted NCCAOM on several occasions – I almost feel like I wrote it myself :).

    Looking through some of the responses here, it’s easy to see how we came to the current state of affairs: should herbal training be required for licensure or not? If I didn’t formally study herbs in school can I use them? Should herbs be regulated like pharma? How much biomedical training is really necessary?

    All, mostly, irrelevant.

    Part of the problem is: we do not invest in or support newly minted practitioners. If the statistics are to be believed, we have the largest attrition rate of any licensed medical professional in the US. There is virtually zero support for new grads and, for the most part, outside of starting their own business, not a lot of opportunity. Not everyone is suited to running a business and, wonder of wonders, our attrition rate is a virtual clone of the failure rate for first time small business owners. We do not have access to the same small business support or student loan forgiveness that other medical providers do. This is a problem we need to fix if we’re going to maintain our numbers.

    The second part of the problem is us. From the late 1970’s until just a few years ago, we mostly went after a certain segment of the population. That segment were those folks who were specifically interested in ‘alternative’ medicine. Historically, as a percentage, this is somewhere between 3% and 6% of the population. As our numbers increased, we maxed that percentage and had no plan for accessing the other 94-97%. We continued using an elegant, ancient, metaphoric, poorly translated, and poorly understood language and cultural artifact without appreciating that those terms are completely unacceptable to most of the medical establishment and a large slice of the 94-97%. Now that we have decent evidence from modern bioscience supporting us, we’re having difficulty capitalizing on the situation because, for the most part, we’re unprepared to play in that space. I’ve said it in lots of places to lots of folks, and I’m sure I’ll be saying it until I die: It doesn’t matter at all what terms we use when thinking about patient issues and their treatment. It matters a great deal what terms we use when talking to patients and other medical providers about those issues and their treatments. If we want to survive, we must become bi-lingual.

    In a nutshell: we need to create an environment where we can all be successful. To do that, we need to be able to access a larger slice of the population than just those who are interested in ‘alternative medicine’. To do that, we have to educate the public about what we can do AND we have to educate ourselves about how to talk to the public and other medical providers about what we can do in terms that make sense to them. If we can solve these problems, everything else becomes very easy.

    • Youall are my heroes and sheroes…. cheers for the non sheep amongst us…..!

  2. Oriental medicine (Acupuncture) and Western medicine ( biomedicine) together is the way of the future. NCCAOM doesn’t have a choice, but to move forward and yes some will be left behind.

    • I have no idea what you mean, specifically. Or, how your comment is relevant to what the NCCAOM should consider when choosing a new CEO and/or any of the points in the post.

  3. Every profession is currently in the same dilemma. Medical school, Podiatry school etc..

    • You’ll need to say more. If by “same dilemma” you mean more demand than there are professionals to meet the demand, I’ll agree. If you mean credentialing agencies that create unnecessary barriers to entry, you’ll have to give me some specific examples.

      • Every profession is not in the same dilemma. Taxpayers pay a most significant portion of the education for MDs, far beyond their tuition. We have no such support.

  4. Great letter Elaine, Thank you for taking the time to do it. Is there a way for us to support it? Should we also write in and say we support your position? Something like that?

    • I think the more people they hear from the better. I’d certainly send them your thoughts – either that you agree with the post, or, send your own ideas. Not sure how their FB page is set up, but social media posts might also work.

  5. Elaine,
    Your letter was well written and eloquently addressed many needs/concerns for many of us. In the state of Oklahoma, we have no licensure and one of my issues with the NCCAOM is that they require the study of biomedicine. I understand that the goal is to hopefully get us into an integrated medicine, but quite frankly I have ZERO desire to EVER work in a medical setting. I want to practice ACUPUNCTURE not western medicine.

    Also, I find that they have created a monopoly on training as the ONLY way (for the most part) to take the national test is to go to an NCCAOM approved school. Well, pardon me, but isn’t THAT what TESTING is FOR??? To determine the level of knowledge a person has obtained? So who gives a rip WHAT school I go to? If I can sit for the national exam AND pass it, then give me a license! Requiring an interested party to go to only certain schools leaves many in the dark or unable to get a license.

    I know to a certain extent I am “not as bio-medicine” well trained as those who have gone to the NCCAOM school, however, I absolutely no problem referring some out to a different practitioner or refusing to treat someone if I feel my treatments would either be of poor benefit or possible harm.

    Like you said, its a shame that the course the NCCAOM is going at this time, is only pulling our profession apart and dividing us. One of the other things they removed was the ability to apprentice. There was a time that that was the ONLY way to learn many professions! Sometimes, I think the person who has apprenticed has probably gotten a better education that the book/classroom educated person….not always, but sometimes.

    I hope that your letter is taken to heart. I pray for your voice to be heard and the NCCAOM to get their act together to UNITE us, NOT DIVIDE us.


    • Ahhh – there is so much in this comment. I feel like I need to get into the weeds and in some aspects will defend the NCCAOM, and others not. And I’ll be a bit nitpicky. And I hope in the end folks will see that I do strive to be fair and balanced and see all sides of the story. And acknowledge that there not super-easy answers to some of these questions.

      First off, OK definitely needs more practitioners. I have clients with family there. We were lucky enough to find a DC that did acupuncture, because that was the only option.

      To be nitpicky, it’s ACAOM that approves schools. Although, actually, you are right, because the NCCAOM determined that the ACAOM standard is necessary to sit the test. And, they do allow some folks who studied overseas in non-ACAOM schools to sit the exam. I’m actually in communication with an LAc trying to hire, and the perfect person for the practice hasn’t been able to sit the exam because the NCCAOM transcript approval contractor didn’t approve the transcript as ACAOM equivalent (though a previous contractor did approve people from the same program) and hasn’t provided any solution.

      As for the apprenticeship route — it is heartbreaking that it is gone. Years and years ago they talked about getting rid of it and a bunch of us mobilized and saved it. Somehow, I missed it when they moved to eliminate it this last time. It’s classic hypocrisy when LAcs complain about how acupuncture is being stolen by other providers when we’ve created a system in which individuals who are fifth generation Acupuncturists, and learned at their grandparent’s knees, are now told they aren’t eligible for licensure.

      The problem with leaving the determination of who is qualified to practice entirely up to the schools is that the schools have a huge financial incentive to say YES, and very little incentive to say no. That’s why, when we were working for licensure in Virginia, the NCCAOM was such a help. We could point to an independent group that could assess qualifications. Of course, given that a written exam can’t test most of the things that are actually needed to be a good Acupuncturist, the exams alone aren’t a good measure of quality. It’s a conundrum. There is value having a group independent of the schools weighing in on someone’s fitness to practice. The challenge is being clear on what determines fitness and assessing that, not a bunch of extraneous stuff.

      As for the biomedicine stuff — I’m not really sure what material is on that exam these days. I will say that some biomedical knowledge is important. For one thing, it helps us know when to refer. Some of my proudest moments as a practitioner were identifying diagnoses that were missed by MD’s and helping someone get western care they needed. Also, our clients expect us to understand their medical history, which is generally a biomedical history. And, if we do hope to function with the western the biomedical system on some level — as in providing an alternative to opioids for chronic pain, it helps us to have a common language with those with whom we share referral relationships. (Not that our current level of biomedical training seems to be effective given some of the anti-vax bs I’ve seen spread by LAcs. There are reasonable arguments to be made about the potential impact of vaccination, but most of what I see isn’t reasonable.)

      So, I’d have to look at the specific material, but my gut feeling is that biomedicine training and testing is more critical to safe practice than, for example, TCM diagnostics.

      Would you run into trouble practicing without a license? Great Britain doesn’t have licensure for Acupuncture, and things seem to be going fairly well there. Naturopaths don’t have licensure in many states. My fear, though, is if acupuncture is mentioned as being within scope for MD’s/DC’s (I think it is) you’d run the risk of being charged with practicing medicine without a license.

      Good luck! I too hope the NCCAOM will get their act together. We need more practitioners in more places. There shouldn’t be barriers that don’t serve an important purpose.

      • I have been successfully practicing for 5 years now with a certification from the school I attended. My previous trainings as a lay midwife & doulas have given me a nice little corner on understanding biomedicine. I too have found things in patients that Western medicine has missed.

        Because of the messes like you have metioned, i have seen other issues within the licensure process as well which is why I have become jaded with the whole idea of licensure. It IS a conundrum as you said.

        Keep the faith in your fight.

  6. Elaine,

    If you read my whole comment, I am in favor of taking herbs away from everybody, chiropractors, naturopaths, man in the street, if they have not been trained.

    • I read it. I understand your argument. But, in the here and now, there is zero support for such a change. In fact, huge numbers of people with resources, and grass roots groups who don’t want natural remedies to be taken away from them, would mobilize to stop any such change.

      My argument is that given that herbs are currently unregulated, is there any benefit to requiring only LACs to have additional expensive training to use this modality. And, if there is benefit, is it greater than the cost, which includes making Acupuncture a less appealing profession, at a time in which our numbers are falling.

      And, furthermore, even if we decided that there was a net benefit to requiring additional training, is there some less onerous requirement that could be equally protective.

      The overall point of the post is that our profession is faltering, and that we’d better take a good hard look at the obstacles that cause people not to enter the profession, and that a change in leadership in a group that has control over those obstacles is a very good time to get very clear about what is good and what is bad for the profession.

      Putting a significant training burden on LAcs in the absence of evidence that that burden is offset by benefits to the public is dumb.

  7. Going back to the herb issue, only doctors can prescribe certain medications. Herbs are medications of equal standing with pharmaceuticals. They are not food. They are not innocuous . They can be lethal.

    Here are some examples I encountered in my practice. A naturopath prescribed Health Concerns anti- viral medicine. He told the patient to take it for several weeks. When she, by chance, came to my office, she had such severe diarrhea that one would mistake it for cholera. Another patient with emphysema bought some strengthen the lung medicines on line. It was actually cough medicine and was not doing him any good. Another patient with allergies was taking cang er zi prescribed by another acupuncturist and got so dried out that he hardly urinated.

    If I were not living abroad, I would be working to limit the sale of chinese herbs only to people who have passed a qualifying exam. I would do the same for western herbs. Herbs are powerful. It takes a large amount of knowledge to know how to use them correctly. They must be prescribed with care.

    • 1) Of your three examples only one involved an LAc. The other two could continue to do what they are doing, even if only a small number of LAcs were permitted to use herbs.
      2) Even “fully-trained in herbs” LAcs sometimes make bad choices in which formulas they use.
      3) Many pharmaceuticals can be prescribed by non-MD’s.
      4) Your argument is that the risk to the public is so great from the use of herbs by LAcs without the NCCAOM credential (BTW, many very qualified herbalists can’t get that credential because their training pre-dated the ACAOM approved programs) that you think it is better to strangle the profession as a whole.

      Sometimes more harm is done by the “solution” than the problem.

    • “A naturopath prescribed Health Concerns anti- viral medicine. He told the patient to take it for several weeks.”

      Was this Coptis Purge Fire by any chance? I had a DOM (not the same person I mentioned elsewhere in these comments) prescribe it and tell me I could stay on it indefinitely, since it was helping me with sinus issues. Eventually, the digestive side effects got to be too much, and I took myself off. (Sadly, it is probably the best thing I’ve ever taken for my sinus problems.) When contacted directly, a Health Concerns representative told me it should not be used long-term.

      I nevertheless don’t agree with your proposal to tightly regulate herbs, and would certainly make a great deal of noise to oppose such regulations. Furthermore, I presume the DOM who gave me that formula has formal training in herbs.

  8. (The following comment has been heavily edited with an attempt to retain the issues discussed without creating privacy concerns/an attempt for the practitioner involved to share their side of the story, etc. I hope the original poster appreciates my hope that we can learn from this experience, without focusing on details that may be a distraction.)

    From the patient side, the NCCAOM thinks it’s okay for a Diplomate to unilaterally terminate treatment, effective immediately …. with no warning… and a day after the patient has reported suicidal fantasies for the second time, even after the Diplomate had been blasé about previous expression of suicidal ideation, and even after the Diplomate had been the one to emphasize the emotional slant of her treatment approach.

    But *none* of that apparently crossed any ethical lines, according the NCCAOM……..

    In my case, this might partly be a problem with my state’s relatively underdeveloped concept of patient abandonment. There are no state guidelines I have seen with a prescribed buffer period.

    I realize Elaine (and perhaps most commenters here) is not in favor of NCCAOM engaging in disciplinary action. I was happy they were there to turn to in a difficult situation, but I am completely unhappy with the outcome.

    As far as I’m concerned, it looks as if you can all screw your patients over and get away with it. It would be very difficult for me to trust any of you at this point, particularly with regard to emotional issues, but it’s moot, given how broke I am….

    I might end up outed for this, but I am feeling pretty desperate about the situation, so whatever happens, happens.

    (And yes, I am aware of the national and local hotlines I can call, clinics I can go to, etc.)

    • Dear Unhappy Patient —

      I am very sorry that you had a bad experience, and that you did not get the support you needed in addressing the harm done.

      I have read other stories of LAcs being confronted with difficult situations and not having the training to handle them in a way that takes care of all of the parties involved. This points to a lack of training and it is definitely something that should be addressed. Likewise, when I talk about the NCCAOM focusing the credentialing process on patient safety/red flags, this is an example of an area where we need to do better. I believe that far more harm is done from LAcs having limited knowledge of mental health first aid than from, for example, not knowing which acupuncture point TCM practitioners would not use in a damp heat situation, for example.

      I hope you will report this incident to the Adverse Events Reporting Database that was recently developed. Knowing about these incidents can help our school improve training so that future practitioners will be better prepared. Here’s a link to that resource

      Additionally, did you report this to the state licensing board? You are correct that I do not see the NCCAOM as the proper body to make decisions on most disciplinary actions. Their process is far from transparent, there were/are limited ways for practitioners to appeal findings, and the NCCAOM does not have the resources to properly investigate most reports. Additionally, the NCCAOM is quite limited in the actions they can take in response to a disciplinary finding.

      Again, I am sorry that this happened. Your experience was unfortunate, and practitioners do need more training in how to handle these sorts of situations. I hope you will file a report on the AERD, and if you haven’t filed a complaint with your state licensing board, you could try that.

      Thank you for sharing.

      • Thanks for your response. You cut out quite a bit, but it probably was the right thing to do. It’s very hard for me to resist the temptation to litigate this incident online, but it would not be worth all the very personal material that would be brought up. I probably need to cool it, anyway, since if I’ve learned anything over the past couple years it’s that I don’t have much power, and I’d better learn to deal with that.

        I did submit a complaint to the state board, and they dismissed my complaint.

        “I believe that far more harm is done from LAcs having limited knowledge of mental health first aid than from, for example, not knowing which acupuncture point TCM practitioners would not use in a damp heat situation, for example.”

        This makes sense to me.

        Not that I know much about training for acupuncturists, but I would broaden it to say maybe there needs to be more emphasis on the social/interpersonal side of treatment, in training. Once you get into addressing a patient’s emotional issues, you are getting into some of the same territory counselors and psychotherapists address, even if you don’t spend much time talking with a patient during a session. I do think there were transference, or at least transference-like, issues going on in my interaction with that practitioner.

        I will look into adding to the database you linked to.

      • I’ve decided to go public:

        I will understand if you think this comment is not appropriate to post, especially since it’s pretty OT at this point, and you have no way of knowing all the specifics of the situation I am describing. And obviously this blog is not about individual complaints against individual acupuncturists.

  9. Very well written and structured. I couldn’t agree more.
    Thank you Elaine for expressing what many feel. Being a newcomer to the field, i can see the seperation and division….makes me wonder if I want to continue? Taking boards presently and it has been very daunting. We’ll see what happens, but I am not eager to join!

    • I sincerely hope that you find a satisfying professional life. I love so many of my fellow LAcs. Somehow, though, when it comes to policy and regulation, we seem to tear each other down, and that’s had a terrible impact on our growth.

  10. To those arguing that the herbal credential is critical – you are arguing that the risk from LAcs without that credential is so great that it’s better to strangle the profession that allow them to use their own judgement in setting the limits of their practice.

  11. Brilliantly stated Elaine! Although sadly, I think your words will fall on deaf ears. After practicing acupuncture for 25 years it is my belief that the NCCAOM has done more harm than good to the profession, and all of the organization’s efforts in the last 10 years have only made it more difficult for acupuncturists to thrive. I recently retired , and the more I read coming from this organization the more I weep for my beloved profession

    • Recently, a colleague asked me why I was so angry about the profession, why didn’t I just leave.

      I am fighting to save something I love. I weep too.

      I heard from another colleague today. She really needs additional help in her practice. She’s in an area without many practitioners. But she has the perfect person she’d love to hire. That individual went to school overseas, and her transcripts aren’t making it through the NCCAOM verification process. It’s been held up for ages. No NCCAOM permission to sit the tests = not able to take the tests = no license in the state in question. The business-owner loses, she can’t hire needed help. The patients lose, they can’t get appointments. The would-be practitioner loses, her education is going to waste and she can’t do what she loves. Yup, I’m angry. And I weep.

  12. Why are herbs becoming an issue? In most states, herbs are considered food, so anyone can give food recommendations. Don’t need any education or certificate to give food recommendations.

    It would be awesome if the NCCAOM cleaned up its act.

    Thank you for a concise letter!

    • You’re welcome!

      If you read the comments, including some of the discussions on FB, you’ll see that plenty of our colleagues think it incredibly risky to allow LAcs without the full ACAOM approved training and NCCAOM testing to use herbs at all. They clearly don’t trust other LAcs to know their limits. I wonder if they know that all MD’s are legally allowed to deliver babies, even if they aren’t board certified obstetricians?

  13. Dear Elaine,

    You are completely incorrect about including herbs in the scope of practice of people who have not passed the herb exam. Studying acupuncture gives you only a vague idea about how to use herbs. Unlike Acupuncture, herbs can kill a patient or make them sicker. One of the recognized causes of illness is incorrect herbs.

    If we have people who have not studied herbs prescribing them, we will have more complaints about the safety of the herbs because they will be misprescribed. Then they will be withdrawn from the market as unsafe.

    Herbs should only be prescribed by people who have passed the exam.

    If other Acupuncturists want to prescribe herbs, they should study them.

    • 1) There is no reason to require the full herbal training for acupuncturists who don’t want to use herbs, but many states do require it.
      2) Herbs are prescribed by people who are not LAcs. So, you have states like PA in which Chiropractors can prescribe/sell herbs, but LAcs without the full training can’t. This does not protect the public. Herbs have been withdrawn not because of LAcs using herbs, but because of the actions of others. Excluding LAcs does nothing to prevent this.
      3) Show me any evidence that there has been harm from LAcs without the full training using herbs inappropriately.

      I know you, and many others, disagree with me. That’s why we have states in which LAcs are disadvantaged compared to all other providers, and states in which you can’t be an LAc without going the full herb route with the extra 20K or so in expenses. But, unless you can show me a real benefit, that our opinions differ does not make me wrong. We’ve got states that require herbal training and states that don’t. Show me the evidence that there’s a difference in risk to the public.

  14. Good luck.

    Over the years I have grown disaffected by the realization that this acupuncture profession may never find its feet here in America. Greed has won.

    This may seem cynical but I believe I am finally looking at the reality. Over the last 17 years in practice I’ve watched the acupuncture profession destroy itself, one bad decision after another. My youthful optimism of a growing, respected acupuncture profession has disappeared. My hope that acupuncturists as a whole could gain acceptance into society and become even somewhat as recognized as the established medical industry (or even chiropractors!) is shattered. The idea that acupuncturist could make a living wage to share the wonderful medicine turned out to be an illusion cooked up by the crooked, dishonest acupuncture schools so they could fleece the thousands of misinformed and gullible altruistic healer-types. And putting the veneers of licensure, certifications and state board committees onto a rotten backdrop of high student loans in disproportion to actual wages, mis-education, and unsustainable fees to maintain licensure, is ultimately harmful for the profession, to the individuals within the profession and to all people who will never experience or have access to the benefit of this safe natural medicine as the profession dwindles.

    What a farce.

    • There’s plenty to be sad about, for sure. My only quibble is that I think, at least for a while, Acupuncture was a respected profession – certainly on par with Chiropractic. Of course, for many people we were nothing more than a distant mystery, and certainly there are MD’s and others who dismiss anything unfamiliar. But there’s been plenty of respect too. Yet, somehow, we focused on those who were skeptical, and thought that if only we got the right titles or more education, we’d accomplish something more. So we made the education longer and more expensive, meaning fewer practitioners, meaning less access. And, if you want an MD to look askance, call yourself a Doctor. Meanwhile, if an MD (or PT or DC) shows an interest in acupuncture we freak out – “they’ll steal it.”

      And the anti-vaxxers, CBD promoters, and supplement sellers within the profession don’t help.

      There’s plenty of blame to go around. The NCCAOM, the schools, and our colleagues. A lot of Acupuncturists jumped on the more education is better, more titles are better, fight other professions to survive, demand insurance coverage and then be outraged when it isn’t the miracle you expected bandwagons.

  15. Thank you for voicing these concerns so clearly and persuasively!

    • You are very welcome! Feel free to share your thoughts with the NCCAOM.

  16. Elaine,

    Thank you for this incredibly thoughtful and potent letter. I am a student and I could not agree with you more on the issues you address. If there is anything we can do as students to help promote these changes, please let me know.

    I too would sign my name!

    • That’s great to hear Jamie. I encourage you, and any other students, to send your own letter. You can borrow from mine. Or send mine with an “I agree” note. You could email the NCCAOM — and, maybe even post it to their FB page. At this point, I think our best chance for change is to make ourselves heard!

      State associations might be interested to hear your thoughts….

  17. Elaine, this is a great summary of the obstacles to becoming an acupuncturist, maintaining licensure, and sustaining a worthwhile practice.
    You mention the importance of safety. How could a licensing body differentiate acupuncturists who have sufficient training and knowledge in herbs from those that do not?

    • Thank you!

      So, it would take another blog post (and I need to recover from writing this one) to fully answer your question. But a very good place to start is with another question — is there any evidence that a licensing body needs to differentiate between those with sufficient training and knowledge and those who don’t? Or, does the evidence show that licensees are capable of respecting the limits of their knowledge and training and drawing their own lines? We’ve got plenty of evidence that there is no great risk to the public from boards not making this differentiation, since many, many states do not regulate the use of herbs by acupuncturists. Additionally, the cases I’ve seen of serious harm from herbs that lead to increased regulation has not had anything to do with Acupuncturists – it’s typically related to supplement companies or weight loss “gurus.”

      I know that in the most recent case of an attempt to require the herbal credential, in Utah, it was not in response to any issues from inappropriate use of herbs by Acupuncturists. It was a state association/Regulatory Board that hoped to keep out graduates of a particular program. That same board, btw, determined that there was no need to regulate injection therapy by Acupuncturists because they wouldn’t dream of doing it without appropriate training – they could be trusted.

      And, even if a board/profession felt that a particular aspect of practice was causing problems and needed to be further regulated, the common practice would be to start with the least limiting change that might help. Requiring two additional years of training and an additional board exam is starting with a nuclear bomb.

      I know the acupuncture profession has been outraged by the way PT’s regulate Dry Needling — but they’ve been following typical licensing board practices. How can we address a problem – if there is evidence of a problem – with the least harm/restriction to the profession we are regulating.

      We’ve been doing the opposite. Maybe that’s a factor in why our numbers are dropping.

    • Feel free to email them a copy with a “What she said” note. Or, write your own thoughts. They should care what the profession thinks. Now is our best opportunity to make a change.

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