More on Acupuncture Education

The for-profit schools don’t want to take responsibility for the circumstances of their graduates. And they won’t let the new gainful employment regulations go into effect without a fight.  Within days of the posting they filed suit to block the regulations. They did the same thing when similar regulations were announced in 2012, so I expect the DOE wrote the new regulations carefully to withstand an expected legal challenge.

However, with a pro-business and anti-regulation majority in the House and Senate as a result of last week’s election, even regulations found to be legal might not be enforced.  If the funds to track compliance aren’t in the budget, for instance, enforcement can’t happen.

Of course, if the schools and alphabets were committed to doing the right thing — producing the best possible graduates at the lowest possible cost to the students, regulations wouldn’t be needed, and wouldn’t threaten the schools even if they were adopted. I don’t expect that commitment from large businesses like Corinthian. I wish I could expect it from acupuncture schools. But most acupuncture schools seem to have little interest in what happens to their grads, and continue to present an unrealistic picture of life after graduation to potential students.

We’ve gotten to the point where even prominent conservatives acknowledge that the current system is a “bad deal for students and parents” and at least some are advocating for change. And it’s true that regulations, however carefully written, often have unintended negative consequences. All too often the well-off and powerful find ways to exploit loopholes and other tricks to avoid regulation, while smaller businesses find themselves significantly disadvantaged. (Consider what happened with the organic label.)

If the schools were on the hook for the money students borrowed no doubt things would be a lot different — from materials provided to prospective students, to the admissions process, to the education provided, to alumni support.

I don’t expect that will happen. And with the change in the political picture here in the US, who knows what will happen with the gainful employment regulations. For now, all acupuncturists can help the market work by helping prospective acupuncturists look past the pitch. Anyone entering the profession should do so with eyes wide open.

(Read this for more on how the November elections will impact the future of acupuncture and complementary medicine in the US.)


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.

23 thoughts on “More on Acupuncture Education

  1. Mark and Steve —

    I suspect that there is much in your comments that folks would like to read and follow. However, I am not finding it easy to get through them and I probably have more patience than most in this regard. If you’d each like to write a 500 word (or so) post (or posts) that can pull out your major point I’d be happy to consider working with them as a guest post. But their length and complexity isn’t well-suited for the comments section.

    • Dear Acupuncture Observer

      First I wish to thank Steven for his utter transparency and willingness to communicate openly, something I modeled as first president of the original CCAOM council from 1982-1986, which was called National Council of Schools and College of Acupuncture, just as the original certification commission I served on as a founding commissioner was National Certification Commission for Acupuncture and the original accreditation commission was likewise focused squarely on acupuncture in this country. It is time for any national organizations that serve the public trust to get back to this focus on Acupuncture, a people’s medicine, and commit to open, transparent diaologue as well as ACAOM did in putting the ‘Acupuncture’ term back into the DAOM in August 2014 – so that any masters graduates, whether they wish to study Chinese herbology or not, might have access to such scholarly pursuits.

      The post I sent recently in response to Steven was far too long, representing a full year of deep reflection on where the heart had gone missing from our ‘way of medicine (yidao)’ and I apologize. One of our college’s former faculty members called it drivel making the same point about length.

      I am in the process of engaging in what the ‘neo’-Confucians from Zhu Xi [ who refined the Chinese philosophy vocabulary by 1200 in his ‘Reflections on Things at Hand’ on the ‘Four Books’, to Wang Yang-ming by 1527 in his ‘Instructions for Practical Living’ [both translated in the early 1960s by scholar Wing-tsit Chan, whose seminal ‘A Source Book of Chinese Philosophy’ started the American revival of that ‘School of the Way/ or daoxue’ tradition of learning, which is unfortunately rendered as ‘neo-Confucianism’ most typically]. Zhu-xi’s scholarship and dedication from 1137-1200 served to revive a dormant classical Confucianism, while integrating in the spirit of Sun Simiao as it were, speaking for our AOM ways, from the 7th century in his ‘The Professional Practice of he Great Physician’. This is summarized by translator Sabine Wilms [in the ‘Great Compendium of Acupuncture and Moxibustion or Zhenjiu Dacheng’ by Yang Jizhou, introduction from 1601, pages 11-12 [Chinese Medicine Database, Portland, OR, 2010)]. Much before Zhu Xi’s time, Sun Simiao gives his ideal for the great scholar-physician, which the Tri-State College of Acupuncture of Acupuncture I founded has taken to heart in adding such studies as of 2012, when the winds of hurricane Sandy blew it into our space, and which shall serve as its eventual DAOM doctoral program in various styles of acupuncture core focus. His ideal included stating one “wade and hunt through the general literature’, explained as the Confucian classics, the Dynastic Histories, the Buddhist sutras, and the Daoist philosophers to cultivate humaneness and righteousness; understand the ways of past and present; foster the virtues of compassion, sympathy, joy and abandonment (p 11).”

      The college has found that by starting with Daniel Gardner’s user friendly translations of major excerpts of ‘The Four Books’ -especially the first on ‘great learning’ and self-cultivation of the heart-and-mind, and the last, the ‘Zhongyong’, which Ames and Hall translated more recently based on new archaeological finds, for a popular version as ‘Focusing the Familiar’- on “enchanting the common, the ordinary” through such mindfulness practices in the everyday with full presence in our work with self and others in the here and now.

      Nursing doctoral scholar-practitioner Jean Watson, PhD, RN revived this same focus in her 1985 ‘Caring Science, Sacred Science’; and in 2014 with former doctoral student Kathleen Sitzman, PhD, RN in their ‘Caring Science, Mindful Practice’, where Watson’s “10 caritas processes’ for any heath care practitioner focused on caring of suffering rather than curing disease, the province of biomedicine, and Zen monk Thich Nhat Hanh’s ‘5 mindfulness teachingg’ to “awaken the heart” are integrated – as he shares in his beautiful ‘True Love’, whose last chapter and sutra is about ‘getting rid of our concepts’.

      It feels high time to get rid of the communist TCM textbook standardized concepts of pattern differentiation and prescribed treatments or bianzheng lunzhi started in the 1958 ‘Zhongyixue Gailun’ for the New Medicine of China, a failed Maoist venture that ended by 1987 when some 176 modalities of this way of medicine, starting with acupuncture, moxibustion and bodywork, were deregulated to become a people’s medicine with full access outside of TCM state-run hospitals – ‘folk therapeutics’ as medical ethnologist shares in her 1994 ‘Knowing Practice’, p 2012. it was the texts of the 1980s’ that served to ground our NCCAOM foundations and acupuncture certifications modules, and those foundations are tainted by overt Maoist ideology as Farquhar cites as well 2 pages later, referring to some senior doctors she observed in 1983, as “an ideology
      they can do without.” So should we.

      My point to Steven and to our Board in bringing these heart-sutra inspired teachings and practices back, is that this is why so many of us got into this deeply ‘faith-based’ classical acupuncture style of practice that, on page I of the ‘Ling Shu’ or ‘Spiritual Pivot’, likewise calls for the ‘High Skills’ of mindful presence, the essence of ‘the way of medicine’ or yidao as Sabine Wilms shares.

      We lost our way in going far too far (shidu) in the communist TCM direction, and it feels as if the new national acupuncture sentiment is shifting back to this deep respect for a drug-free classically informed acupuncture hat puts people’s healthcare and direct access to acupuncture coverage in the forefront, rather than political agendas and efforts to control this way of medicine with only one state’s model. That would restore free and easy flowing (tong), and harmony (he), the focus of this way of medicine as healing, called ‘attuning (tiao)’ by medical ethnologist Yanhua Zhang in her 2007 ‘Transforming Emotions with Chinese Medicine’.

      Steven, I must concur with some CT colleagues this week, that we do not need yet another politically motivated organization, but rather some sort of American Acupuncture freedom movement, to let our patients have free access to our Primary Acupuncture Care, to offer sliding scale and pro bono care when that is not possible, and to give back to those who have made American Acupuncture a household word in the last 30 years: the people, not the organizations that would speak in their names.

      Happy Holidays!


    • Dear Acupuncture Observer Editor:

      Feel free to break my last post into 2. I am done getting all this core information out there so cut and post as you deem fit. No one has done this research and your readership deserves to have some actual scholarship, just not political opinions, from someone who is still passionate about, and 100% committed to acupuncture as a stand-alone practice that all should have access to.

      Happy Holidays,


      • Thanks, Mark. Sadly, I continue to see that it doesn’t matter whether we come from scholarship, opinion, common sense, or logic, very few of us in the field seem willing to question their working conclusions. I’m as frustrated as you are.

          • Sorry. I was just expressing some bitterness at the general lack of civil and thoughtful dialogue in the profession as a whole. It had to do with some social media harassment directed my way on Facebook, nothing to do with your comments.

          • There is a very uplifting book on John Dewey’s 1919-1922 Teaching tour to China extended because he caught the interest of some in the New Culture Movement, and he was pitching his pragmatic philosophy via Neo-Confucian practical philosophy (Wang Yang-ming, INSTRUCTIONS FOR PRACTICAL LIVING, trans. 1963 by Wing-tsit Chan) that has definite usefulness today…I am sharing some of its ideas with people thinking how to start a new community of regionally self-defined people dedicated to sharing innovative ideas and also rallying when necessary around critical issues: JOHN DEWEY IN CHINA: TO TEACH & TO LEARN, SUNY, 2007, pp 104-124):

            “Democracy as a way of life is controlled by personal day-by-day working together with others. Democracy is the belief that even when needs and ends and consequences are different for each individual, THE HABIT OF AMICABLE COOPERATION, which may include, as in sport, rivalry and competition – is itself a priceless addition to life. (p.m113).”

            Things WERE like this in the first creative 5 years or so (1982-1987). THEN the NCCAOM board took on a life of their own with an all-out push to convince the California Acupuncture Board (CAB) to use those instead of its own tests which has still failed (!). The books are more and more TCM academic rather than acupuncture-moxibustion practical and lost all connection to the real word! And then the CAB related power blocks kept pushing that agenda while the actual CAB program standards are from the dark ages when we were trade schools, with tedious details that do not pertain to acupuncture at all. It appears ACAOM is to become the main agency involved in CAB program approval in about a year, so things could change.

            In the meantime in the ‘Oriental Medicine’ mania to get that status recognized instead of Acupuncture as the licensure title, after 11 years, they got an amended law that states LAcs can also use and prescribe all manner of AOM modalities including herbal, animal, mineral and plant substances and dietary supplements, TO PROMOTE, MAINTAIN AND RESTORE HEALTH – adding that this does not preclue anyone not licensed in acupuncture, or an other licensed healthcare provider from using these modalities.
            So after and additional 4th year and 660 hours of herbal training (210 f it clinical), one can recommend ans sell the 5 or so common products all Chinese herb suppliers carry which schools used to teach in 24 hours with Fratkin’s original patent book!

            Money back anyone?


    • Thanks for the 500 word offer Elaine. Sincerely. I am sure I can meet that limit. Perhaps some time in the next several weeks. I am working on several AOM related topics that seem to be of interest on this board (I have other work outside AOM): (i) the odd tradition of “obfuscation” and contradiction when it comes to reporting survey results from their three Job Task Analyses. I am referring to NCCAOM. (ii) The NCCAOM request/application that BLS grant an SOC for acupuncture. I participated in the process of editing that proposal. The first drafts were so far off from what was required, a naive reader might conclude NCCAOM did not read the very straightforward instructions in the Fed Reg. (iii) I am interested in the reporting requirements that AOM training programs are obligated to file to various monitoring agencies at the state and federal levels. I assume POCA folks reads the Observer so they should be interested in this topic. Preliminary analysis suggests very few schools bother to comply. Among those that do comply a handful use the correct format and provide complete data. Among the remaining group that submit something, the quality of their data is poor. Luckily for them, there seems to be little oversight. The action around the Gainful Employment Guidelines could change that. Political opposition, a Republican controlled Congress, or many lawsuits will not stop something that is already in motion. The irony is that ACAOM seems oblivious to this compliance issue. I would think ACAOM and the alphabets on the whole would be more interested in looking at workforce outcomes as a function of training.

      I spend most of my AOM time thinking about how to drive revenues to LAcs. As I am sure you understand I believe that route leads to working within mainstream medicine. Thanks for the offer and happy holiday.

    • Thanks for the link. However, there is MUCH more to this story than “the bad guys get off.” Gainful Employment Guidelines will not apply to the new school entity that will be created by ECMC, the buyer, which is a large scale lender. ECMC remains under scrutiny for aggressive foreclosure practices of debtors. In fact, ECMC will be required to discharge $4MM in loans for students who borrowed from Corinthian’s private loan company. Another issue is the ability of the ECMC’s new entity to operate 56 schools given ECMC has never operated any schools. Of greater concern is the potential for conflict of interest – ECMC referring students at their 56 new schools to themselves for loans. The article points out the sale is a coup for USDE given that USDE has its own image issues, having let student loans to for-profit schools become such a greedy scam. The AO is right on that point. Suggesting this sale is sleight-of-hand by powerful groups is IMO short-sighted. Suggest readers actually review the link as well as the GEGs and what are the metrics of that implementation.

      • Yes, I didn’t mean for my quick comment to serve as a full analysis of the situation, and I didn’t suggest it was a slight of hand. And I did include the link.

  2. I have really enjoyed reading the comments. I look forward to reading more on the subject. Please keep informing us of what’s really going on. Very interesting!!!!

  3. Steven —

    What is this about — “Standards prepared under the national professional organization with input from other professional orgs (NGAOM, CSA) are forthcoming. Let’s see if the profession is ready to endorse this unprecedented attempt to accept a guiding document for training and testing.”

    What national organization — the AAAOM that has been operating outside its bylaws for the past year and has a tiny membership? Is the CSA a professional organization (since professionals cannot directly join)? Has POCA, with over 650 practitioner members been involved?

    I could be surprised, but I can’t imagine the profession will be ready to endorse a guiding document that has been prepared behind the scenes by groups that don’t represent the vast majority of US practitioners.

    This seems like it might be yet another call for unity, once again made without any attempt to actually build unity.

    • And the point you are making is…? That the profession lacks substantive representation when it comes to number of members in any of the professional orgs. Best estimates of total LAcs in teh nation are 25K to 30K. My best estimate of total LAcs involved with ALL of the pro orgs is between 3,000 and 5,000. Given this most likely total it hardly makes a difference how many members are “involved” with any orgs. What are the monthly numbers for readers of the AO? Numbers of LAcs is not a very good metric when discussing meaningfulness. AO is content driven…for those interested in the the POV. Thoughtful content can be helpful. If the thoughts are evidence based I am even more impressed. When it comes to building unity I am confident the only number that will matter is income for practitioners and the pro org that is able to build towards that standard. POCA is not interested in joining any movement beyond their own. Their success is based on a working revenue model. They easily lead the field when it comes to delivering on workforce promises. I am curious why you think unity is the goal. This is a young profession without unity. Claims for unified representation have always been about bluster and self interest. I hope we can agree on that. My own study of other health professions shows that the disjointed nature of acupuncture can be found in the histories of many healthcare professions including medicine, chiro, osteo, PT, PA, RN, etc. A key turning point for each of the “developed” professions was the adoption of profession-driven KSAs (as opposed to KSAs developed by groups like ACAOM or NCCAOM). Pro developed KSAs drives conformity in training, testing, and licensing laws. But KSAs will not build unity. Workforce opportunities will and history has repeatedly shown those come with uniform KSAs.

      • Dear Steven,

        Yes I agree the history of all other groups except perhaps physical therapy has shown such fragmentation. I am relieved to heat a similar distrust of professional organizations: AAAOM from 1982 was a professional membership irganization with a desire to have representatives elected tits Board by regional distribution of voting licensed acupuncturists which gave Califronia a hands-down control of such representation and hence of the Executive Committee (EC) – the real devil in the mix as it is the EC of any nonprofit that drives the work between meetings and depending on the organization, the EC can leave that day to day work between formal meetings to its hired Chief Executive Officer and fire her or him if she fails to deliver; it can fortify her position with other assistant and associate directors which ACAOM has done under its excellent new leadership so that the executive director might actually be free to travel to CAB meetings, for example, and other important national and state meetings to work for USDE recognized standards that must have demonstrated national consensus from all stakeholders and have no substantive critiques in any Calls for Comments of public Hearings.

        ACAOM, like CCAOM and NCCAOM, were first established by a few of us who left the AAAOM’s educational committee in 1982 already convinced it would push only what soon became known as the California model for “8 Principle” Style as PRC textbook standardized style as called then, as compared to the “5-Element Style of JER Worsley”, an osteopathically-informed physical therapist who developed that acupuncture style to add a spiritual dimension (known for 200 years already in Europe by its German name – geisteswissenscaften – or spirit science as compared to naturwissenschaften – natural science among which the emerging biomedicine was positioning itself. By mid 19th century, when my first physical medicine spiritual science mentor, George Groddeck was practicing his own form of hands-on physical medicine while working to free the person from muscular holding patterns causing pain, discomfort, dysfunction and even disability in work and life, as well as spiritual holding patterns showing up as what modern Vietnam Peace activist, Zen monk Thich Nhat Hanh calls ‘lumps of suffering’ which are due to holding on to negative concepts that bind body, mind and soul to a label of disorder or illness that can be transformed through mindfulness breathing and deep reflection on the meaning of such suffering so as to be able to untie the knots and dissolve the lumps that make the person like a bomb ticking and ready to explode at the next provocation from a loved one or co-worker for example. Those who worked with chronic sufferers of pain, discomfort, dysfunction that also entailed emotional distress, as well as those who worked on the same sorts of mixed chronic complex signs of human distress from a more heart-centered, mindful, caring perspective, were all considered to be practicing such geisteswissenschaften, sciences of the spirit and their problems, disorders, illnesses (which would be BING in classical and modern Chinese) were not seen to have medical diseases that required doctoring, which by the end of the 19th century involved rudimentary diagnosis aimed at treating curing or preventing disease which is still the FDA defintiioon of the practice of medicine which is very precisely demarcated, and only physicians and other primary healthcare providers licensed to make biomedical diffeerntial diagnosis may claim to practice medicine in this country since at least the 1940’s if I am not mistaken. Osteopaths made a deal to be folded into medicine with all the PCP rights, except as surgeons and were granted the same doctoral level status as MDs, and had special deals to get all tuition covered if they agreed to work as GPs in small rural areas or underserved communities. By the time I started practice in NYC the secretary of the NY Osteopathic college program was fighting to save the 200-hour osteopathic manipulation requirement, which was ready to be downgraded to an elective and most DOs in NYC do not list themselves as DOs in any way, and do no manipulative medicine so they lost their art, their practice, their American laying-on-of-hands medicine soul in the bargain.

        Chiropractice, on the other hand, stood firm against such medicalization, while laying numbers games saying their 4,000 hours of education exceeded that of medical doctors, from whence the Persuasive Story held to by CCAOM’s president for 2 terms, which became the official position of CCAOM’s Q&A section of their consumer web pages, so that nay prospective AOM program student would see, and believe, that she or he had to go to a California Acupuncture Board-approved 4-year masters in Oriental medicine program mandated in that state based on rigid trade school level of detail communist TCM standards that leave no room to breath, and certainly would not fit the bill for the Knowledge/Skills/Attitudes practice standards you speak to. Those standards were 2,800 hours at that time, and the newly adopted post masters DAOM program in Oriental medicine only at first, was 1,200 hours so the total, 4,000 ours fit the bill perfectly, matched the California-minded California professional organizations and AAOM (which by then dropped the 3rd A, for Acupuncture, to claim to still be the national professional association, while DROPPING ACUPUNCTURE for a model that propelled the approval of 37 California Acupuncture Board programs nationwide out of 62 total acupuncture or Oriental medicine programs, ostensibly including most ACAOM accredited 4-year masters in Oriental medicine programs. The ACAOM standards were a bit less than CAB’s, so maybe 2,600 then, and maybe 2,800 now: CAB’s went to 3,000 hours for the 4-year masters in Oriental medicine in the drive, shared openly by CAB programs especially in California for arguing that the CAB programs had a pregnant masters (which they forced on ACAOM with undue influence, and hence after the 1987 3-year masters in acupuncture standards were USDE recognized, CAB programs there pushed for ACAOM 4-year masters in Oriental medicine standards for THEIR programs which had nothing to do with any national consensus, and was based again on sheer NUMBERS which you seem to think do not count, but they sure do in political undue influence (red envelopes help too, but anything on that front is pure hearsay!). From the moment ACAOM adopted those 4-year masters in Oriental medicine standards certain California and AAOM forces started militating for simply converting the CAB 4-year programs, increased for this purpose to 3,000 hours, to the first professional Doctor of Oriental Medicine (DOM or OMD), which non-ACAOM programs had been offering for little work and low cost since 1985 at least. Seeing this was still the chiropractic political model, which certain ex-AAOM Executive Committee politicos went and sold to other states like Florida, even to a certain extent in Pennsylvania and New Jersey, some of us seriously suggested the CAB programs hold a caucus where they acted to convert their status as licensed acupuncturists to Doctors of Oriental Medicine like chiropractic did, urge their members to be bold and use the DC title spelled out and abbreviated and lobby state by state for the LAW, with no doctoral degree to confer that status, which at least Rhode Island still does (Doctor of Acupuncture is the state licensure title on that diploma, and anyone who is NCCAOM board certified can apply for it still today). Some of unpointed out that it would be very easy for anyone to get the RI DAc license and use that license in their business PR in their states which no state would be able to fight, as it is a STATE license (one would have to out RI after the DAc).

        People that want Doctor of Acupuncture as a professional title have easy access in Rhode Island and it is as viable as using PhD from PRC for example, where people from PRC programs put: “PhD (PRC)”.

        The THING is, this political Maoist medicine informed movement which came from the 1958-1987 period of the NEW MEDICINE OF CHINA (TCM and Biomedicine in Joint work to serve the laboring masses and students healthcare needs which the WORLD HEALTH ORGANIZATION was impressed by enough to establish international 3-year standards for primary acupuncture care providers – PACPs (licensed nonphysican acupuncturists) and for medical doctors and other primary care providers for comprehensive acupuncture training, similar to those for PACPs with no medical courses as those were already completed in the main medical field; and then abbreviated training of 200 hours for medical doctors and other PCP level personnel to do focused acupuncture integrated into primary care to allow for maximum flexibility to design training programs to meet real needs.

        New York and California state laws developed in the late 1970s, and were informed by this WHO set of standards, and so both states have registered abbreviated programs for training medical doctors (and dentists as well in NYS) of 200 hours, and by 1993 that became 300 hours in NYS. The Tri-State College of Acupuncture is currently the only ACAOM accredited institution or program in an otherwise accredited AOM college offering the 300-hour training for medical doctors and dentists, which we have always done on a small scale for those rare doctors who are willing to recognize that the 3-year masters in acupuncture program graduates primary acupuncture care providers, with whom they study and work on clinic teams which narrows the field of applicants. The college always trained medical doctors and dentists this way, a handful a year even in Stanford, CT before NYS law changes allowed for our ACAOM programs in NYS in 1993. Two of those CT graduates went on to become prominent acupuncture researchers at Harvard and University of Vermont and a medical acupuncture program grew out of one of their efforts some 12 years ago. The UCLA Program under Dr. Jospeh Helms, trained in French Acupuncture as I was (from a non-physician association and Montreal program) and both of our programs for training physicians drew from the seminal work of Soulie de Morant, a non-physician who learned in the late 1880s to 1917 in Shanghai as the Nationalists were getting rid of the last vestiges of a Confucian way of life and self cultivation, and almost got rid of acupuncture-moxibustion in the process. For some 35 years the UCLA Medical Acupuncture program and the Tri-State College of Acupuncture masters in acupuncture and also medical acupuncture programs have taught de Morant influenced classical Chinese Acupuncture, which is meridian based without any required herbal medicine.

        By comparison, the Maoist Chinese Medicine model (TCM textbook standardized where herbal medicine is dominant and the term ZHONGYI, Chinese medicine is synonymous with Herbal Medicine) from 1958-1987 only lasted 28 years, and fell to the demands of the ‘laboring masses and students’ whose rebellions lead to a total deregulation of all of the ‘Way of medicine (YIDAO)’ as it was classically referred to in the last page of the first chapter of the first text on Acupuncture as a stand-alone practice, the LING SHU which was refined/revised at the same time that THE FOUR BOOKS of the new Confucian tradition ( known as DAOXUE, learning of the Way, that integrated classical Daoist teachings and practices, such as YANGSHENG life nurturing practices of self care, and the very popular Chinese Chan/Zen Buddhism and its mindfulness/self cultivation practices – that Sun Si Miao already termed the foundational literature of this Way of medicine that meant acupuncture-moxibustion, and herbal medicine and all variants of both by 1200-1400 when Imperial Court published authoritative texts were available to the educated public, all of whom would know the Confucian core texts on self cultivation and mindful practice.

        Famed American educator and philosopher John Dewey spent an extended 2-year teaching trip in China when the youthful New Culture Movement found his anti-positivist, pragmatic philosophy which made a good companion to Confucian learning of the mind-and-heart (XINXUE) which caught his attention and held it, leading to his influence at Columbia University’s teachers College of the now 20-year old Social Emotional Learning movement in the pubic school systems, which itsef was informed by Dewey’s reflective learning model that spoke of the Chinese Confucian term XIN, meaning mind-and-heart, to dispel the outdated (he already felt in 1922) dualistic mind versus heart/emotions model of thinking and teaching, which in turn fueled the sociological and educational research into the “hot” intelligences (social, emotional, personal) which is essentially the Confucian “great learning (daxue)” of the “heart and mind”(xin). The modern emotional brain research bolstered these studies, and recovered, resurrected a 19th century appreciation for the sciences of spirit (geisteswissenschaften) that includes what we would call the human sciences and psychotherapies today and 1950’s German psychiatrist Karl Jaspers called for using the sciences of the spirit (faith-based healing and all psychotherapies) for the problems of the human condition, which Canadian researcher Hans Selye called ‘disorders of adaptation’ or ‘problems in living’ in his research on the ;stress of life’ that informed the new field of behavioral medicine and cognitive behavioral therapies.

        Thanks to pioneering work by Dr. Arya Nielsen, PhD, licensed acupuncturist of the NYC Beth Israel Integrative Medicine Institute, and others the Joint Commission has ruled that acupuncture THERAPY be added to the care of chronic pain (along with physical and occupational therapies and osteopathic medical treatment) in early 2015, and 6 months later to the care of chronic stress, distress, behavioral disorders (with stress reduction and relaxation therapies including mindfulness breathing and cognitive behavioral therapies).

        So to speak to your very salient focus on standards linked to actual practice, I have spent my entire career arguing for (and crafting at the college and in my Acupuncture Physical Medicine or APM Style) Acupuncture as Physical Medicine and Acupuncture as Behavioral Medicine done in communication, cooperation and collaboration with mainstream and integrative medicine professions and providers, where it is our primary acupuncture care providers, trained in 2 classically informed French (APM) and Japanese (KM) styles, and in modern TCM (seen as Classical Medical Acupuncture linked to the pre-communist Way of Medicine or YIDAO (with Yidao and Dao not even appearing in the TCM textbooks in English from 1958-1987, or in Wiseman and Feng’s Maoist ‘Practical Dictionary’ where all the difficult illnesses (ZABING) that are mentioned with acupuncture treatment central in the LING SHU and original Shang Han Zabing Lun have been reduced to poorly and deceptively translated “miscellaneous diseases” which 1980’s Tietao Deng at Guangzhou TCM College reduced to meaningless patterns with no appreciation for the spirit of it all because modern TCM Maoist medicine, during the NEW MEDICINE 29 years, was informed by a positivist American and British medicine that knew nothing of this more existential German geistes (spirit) set of therapies for nonmedical disorders that are not diseases.

        Such disorders have come to plague AMerican and UK medicine, where the later still calls them “medically unexplained pain syndromes (MUPS)” in the field of pain management, and “medically unexplained symptoms (MUS)” in the field of behavioral medicine where CBT therapies are used.

        While you seem to feel that 27 years of work to establish the core KSAs as standards to serve national USDE recognized accreditation of first professional masters in acupuncture and post professional doctorate in AOM (DAOM) programs (now open thanks to our college’s work a year ago, leading ACAOM to do a national call for comments to adopt revised DAOM standards in August 2014, that allow all masters in acupuncture graduates to do the 18-month DAOM program [which deceptive and Maoist politically correct CCAOM machinations kept in the sole hands of their dominant CAB 4-year masters in Oriental medicine programs].

        Panicking at this new ability for masters in acupuncture graduates to do the doctorate in 1,200 hours with only 45-hours of introduction to herbal therapy, in advanced acupuncture with specialization in any AOM therapy except herbal therapy, has in fact defined the FIELD OF AOM as Primary Acupuncture, WITH (or without) any other AOM therapies, and has served to discredit the CAB push that that state stopped in 2005, for a Profession of Oriental Medicine.

        The work you speak of is being carefully developed by ACAOM expert Reconceptualized Masters Task Force and will be submitted to a national consensus building Call for Comments for certain. Finally freeing itself from any undue influence which you so rightly allude to, from the CCAOM which has shown itself to be a selfish group of CAB programs on the Executive Committee with no democratic way for critiques outside of the 2 tightly controlled national council meetings, or the AAAOM which has lost all credibility bu its history and practices since 1982 to totally control the profession with ONE WAY (are yo suggesting ONE WAY???) when in medicine and psychiatry and behavioral medicine for at least 20 years, the model is pluralism, with diversity of training options and ways of framing care built into ACAOM’s mission by those of us that established ACAOM in 1983.

        Your efforts sound sincere, but they are seriously misinformed and based on lumping ACAOM – whose commitment to consensually adopted educational standards that drive practice in all accredited training programs is mandated by USDE recognition standards in turn which are rigorous and nothing to make light of.

        ACAOM is THE ONLY USDE recognized accrediting agency for First Professional Masters in Acupuncture (since 1987) and Masters in Oriental Medicine (since 1994) programs for entry into the ACUPUNCTURE PROFESSION; and for Post Professional Doctoral Programs in the entire FIELD OF AOM (DAOM); and for accreditation of the institutions whose sole and primary purpose is to such AOM programs.

        THAT is the only set of standards a FIELD needs, which with post entry level doctoral programs, is able to keep fostering creative new theories, practice models and quality improvement initiatives to better position acupuncture especially, with other AOM therapies including herbal therapy as well, while the AOM FIELD writ large grows to meet the regional or specfiic aOM program needs rather than be bullied by AAAOM, or CCAOM or any GUILD OF ANY STRIPES OR PESRUASION.

        Because it is there, Steven, in post-socialist PRC, that the people, as workers and as students rose up against such professional guilds and state mandated TCM medicine practices to get back ALL OF THE WAY OF MEDICINE from before 1958 when Chairman Mao brought back THE WRONG CHINESE MEDICINE while he banned all of the ancient daoist, Chan Buddhist and especially Confucian self cultivation practices that would have allowed for what Dewey termed a Confucian Democracy for China which many still called for until the 1950’s, and which caught the people’s attention in pre-Communist Hong Kong, and in Singapore and in Taiwan where Confucianism as a spiritual practice in the German geisteswissenschaften manner is still very much alive.

        Your Guild thinks we need ONE set of standards when standards have already been carefully and laboriously developed over 32 years by ACAOM with great assistance by NCCAOM on many fronts, and from CCAOM committee indispensable work.

        BUT now, as the profession has matured to be perhaps the only nation in the world with governentally recognized first professional masters standards to enter the profession of Acupuncture (whose status will be formally sealed bny 1916 thanks to NCCAOM’s work to get it listed by the federal Bureau of Labor & Statistics, which AAAOM formally opposed as it did not meet their politcally correct, Maoist ‘Oriental Medicine’ agenda, for an OM that does not exist in this country as a field (DAO) or a profession (DE) – and so they all should read the Daodejing to see where DAO of Medicine, the whole of the medicine from the Linf Sgu until 1958, was first laid down as a philosophical position, not a political lobbying agenda item that has outworn its rights.

        The profession needs no guilds, of CCAOM colleges or of self-driven ONE MODEL FITS ALL AAAOM politicos. They have in effect and by their selfish actions of the last decade or more especially, become manifestly irrelevant and inconsequential, if not comical.

        Whether NCCAOM is needed any longer is a tough call. It was established by us original commissioners to stop states like California from giving their own biased, or incompetent, or unfair tests and the CAB has once again successfully argued against using the NCCAOM exams. Not one licensed acupuncturist in the state has ever had to pass any NCCAOM exams, so it is clearly irrelevant and of no consequence to 40+% of licensed acupuncturists. It has also always been denied as an option by the Maryland regulatory Acupuncture Board, as recently as 2 years ago until 2025 – at which point not one Maryland licensed acupuncturist will ever have had to submit to what has successfully been argued to be a TCM biased exam against the main “5-Element” style, for some 41 years. it would seem that such a track record of safe and competent practice must be due to the fact that most programs (all in MD and most in CA) are ACAOM accredited masters in acupuncture programs at least, whose compliance standards require that every graduate has met and exceeded all national standards, for safe and competent independent acupuncture practice. And since NCCAOM allows students who have completed 67% of their masters training to take all 3 foundations, acupuncture and biomedicine modules – before they have even completed any significant portion of their mandated senior community clinical year where such competence is acquired and tested before graduating them, those 3 multiple choice tests (in a world where it has been determined since the pioneering work of Miller as evidenced in the systematic review by Hundert et al, that professional competence in medicine is best assessed by supervisors who have an ongoing and intimate knowledge of the candidates competence, attested to in a series of multi-modal assessments by accredited programs done by licensed trained professionals, and that ‘patients are not multiple choice tests’ already recognized by 2002).

        We early commissioners who were acupuncturists spoke at length with state boards to see what they wanted, and we developed the Point Location Practical Examination (PLPE) through a rigorous 40-person 3-day focus group, on live subjects with standardized points known to all that do not defy any acupuncture traditions or styles point locations, as well as the much appreciated Clean Needle Technique test; the PLPE is oral-practical on live subjects and could be given by NCCAOM in various regions of the country as it used to, for any student who has finished Year I or later Point Location; the CNT course is already done in regions within AOM colleges and ACAOM could require that BOTH be completed BEFORE any student goes on to the senior community clinical (last 33.3%) of clinical training, and require that all such candidates for that senior clinical phase be required to have active CPR/AED training.The CNT and CPR tests have written and practical components, and the PLPE is practical. This trio could easily replace the trio of outdated multiple-choice examinations which are heavily TCM biased which CAB-approved programs could be required to take as an eternal benchmark of that TCM style which dominates the CAB program standards, while all other AOM masters in acupuncture students would be freed from the TCM domination that NCCAOM unwittingly fell into more and more with each passing decade and undue AAAOM/CAB influence.

        This would restore academic freedom to such students (and their teachers) who have been forced to teach a Marxist politically correct style of practice that is equivaletn to what CAB and AAOM called Oriental Medicine (AKA Herbal Medicine ) until 2005, when CAB was forced to poste the actual 2005 amanded law that makes it very clear the standards for scope of practice licensuere is for PRIMARY ACUPUNCTURE as a medical field, with direct access and able to treat certain diseases and conditions and pain and analgesia, as well as symptomatic care; while the rest of AOM including herbal therapies and nutritional supplements for health, as health food, may be recmmended and sold by any citizen of that state and by any other provider. This is not so different from NYSED’s 1998 position, that since anyone may recmmend and sell such products for health, under implicit FDA rules against claims to diagnose, treat, cure or prevent disease (JIBENG in Chinese in PRC since 1983 at last as Farquhar shows in her KNOWING PRACTICE page 148).

        As for the care of DISORDERS and ILLNESSES soon to be framed as Acupuncture in Physical Medicine (pain) and Acupuncture in Behavioral Medicine (Stress/Relaxation/Spiritual Self Care), and in SYMPTOMATIC RELIEF, and in WELLNESS and HEALTH and sports and performing arts where it already figures, THOSE ARE NOT DISEASES no matter how hard any professional association doth protest, even guilds, because these ways of understanding are being developed by the FIELDS of PHYSICAL, OCCUPATION and PAIN MEDICINE; and BEHAVIORAL MEDICINE AND PSYCHIATRY without our input.

        Now that NCCAOM will have managed to get ACUPUNCTURE listed as a Profession among all others, so proper national statistics might be kept for comparison; and that Beth Israel IM managed to get the Joint Commission to place acupuncture along with physical and behavioral therapies, as a THERAPY, not a MEDICINE, it is clear we can either work to integrate our graduates into ALL VENUES where Acupuncture is showing promise which means working with medical doctors and dentists and any other licensed PCPs who are doing acupuncture, in team-based collaborative efforts to OPEN THE WAY (Shudao), by dredging the horrific stasis CSOMA, AAOM and CAB
        Maoist infuenced politicos created, not in the way of Chaiorman Mao who actually made way for COOPERATION of all of Chinese medicine providers, of acupuncture-moxibustion, bodywork and herbal therapies and medicine, with western medicine providers and nurses.

        The model these selfish few have bullied their way into enforcing here and there (with California still held captive) IS NOT EVEN ABOUT CHINESE ACUPUNCTURE & ORIENTAL MEDICINE and it is not a political Way even Chairman Mao would have condoned. Somehow, somewhere early on, the CA world got convinced the chiropractic model and strategy of just DECIDING ONE DAY to call themselves Doctors of Chiropractic and then BACK INTO actual accredited doctoral degree programs.

        To have entry-level doctoral degree programs in fields like chiropractic and naturopathy which are very small compared to Acupuncture (62 programs versus about a dozen each in those other two older fields) is rather inconsequential in the larger FIELD of American healthcare and neither of these professions is considered to be part of MEDICINE so as to be able to work alongside mainstream and integrative providers. They have developed out of antagonism, in opposition to the mainstream where the MASSES of laboring people and students get treated as they cannot afford Private AOM care, unless it is given in innovative Community Acupuncture like settings where the cost can be kept low by shared use of space in open treatments settings.

        I argued with CAN folks who strongly opposed the adoption of ACAOM First Professional Doctoral Standards in acupuncture and in Oriental medicine mainly because my own council of colleges, CCAOM, managed unwittingly to stop all work on the FPD standards for 5 years from February 2008 until their adoption in February 2013. In that fight against what I saw as a turn-coat move by CCAOM (which AAAOM replicated in December 2011, stopping adoption that was highly anticipated for February 2011 which caused our college to have a successful NYSED external DAc first professional doctoral program review in late Fall 2012 and to be the first such program to apply to ACAOM 6/3/13, and make it to the last expedited commissioner review phase with ACAOM for potential February 2014 substantive change approval so that we might seek NYSED registration for a 2015 start date). NYSED determined that ACAOM FPD standards would need to achieve the same USDE recognition as it did in 2013, which took a decade, before NYSED would entertain such first professional doctoral programs.

        The college had already been ready to apply for the post professional DAOM, but it was always uncertain if MS/Ac graduates would be able to enter that program without 660-710 hours of Chinese herbology due to CCAOM Persuasion/Deception for the 4,000 hour total. As it turns out, MS/Ac programs of some 2,200 hours will be be able to run a Masters/DAOM combined program (when years are counted) of 3,200 hours, making the Deception of CCAOM – the council representing 62 AOM colleges since 2005 when the MS/Ac entry opened as posted in 2006 ACAOM manual standards, for almost 10 years.

        It is that sort of GROUP your organization should target to see how they managed to dupe all of us for all that time. And now that ACAOM revised/corrected DAOM standards to open the post professional 18-month doctoral program, some of the most influential CCAOM colleges with prominent representation on the CCAOM Executive Committee these past 12-15 years, are doing an end-run around all ACAOM FPD standards that took a concerted effort by some of us for 12 years, to do it their own way, without even going through ACAOM substantive change approval required of all ACAOM accredited masters programs to ensure these new doctoral programs do not negatively impact the accredited core entry-level masters programcs which most states, except California, require be ACAOM accredited. And it appears that by 2016, CAB will partner with ACAOM to let the professional accrediting agency – the ONLY USDE recognized accrediting agency, do the work of program approval to remove the appearance of undue influence that has weighed so heavily on that CAB board for 20 years.

        So Steven, while I share your distrust and dissatisfaction with CCAOM and AAAOM and NCCAOM, as groups that have failed to maintain the high moral standards I have tried to uphold when I was the first CCAOM president starting in 1982 for ONE TERM which i felt was the right thing to do ( the immediate past 2 CCAOM presidents dominated the CCAOM presdidency for 5 full terms, and were Provost and President of the same CA college for over 15 years of that time with neither being trained in any AOM licensed practice! ) and which I have tried to push for and still do.

        It is time for what those young Chinese militants in the New Culture Movement who appreciated John Dewey’s Pragmatic (anti-positivist, anti-dualist) ways, for a Confucian Democracy to be looked as a model for the AOM Field and Acupuncture Profession perhaps.

        I suggest everyone ask for 2 Holiday gifts from a loved one (ones self counts as a loved one:

        – JOHN DEWEY IN CHINA: TO TEACH AND TO LEARN by Jessica Ching-Sze Wang

        – TRANSFORMING EMOTIONS WITH CHINESE MEDICINE (on the role of the emotions during the height of the neo-Confucian period from 1350-1650 especially known,as Yidao, the Way of Medicine from the Ling Shu on which was dropped, along with the DIFFICULT ILLNESSES (‘zabing’, associated with ’emotion-related disorders (qingzhi bing)’ that were never considered as DISEASES as argued above).

        BOTH were published by SUNY Series in Chinese Philosophy and Culture edited by renowned classical Chinese philosophy scholar and translator Roger T. Ames who, now in his 80s, is militatingn in a way not unlike Dewey for an appreciation of this neo-Confucian (great learning/ daxue; of the heart-and-mind/xinxue) which is totally in line with Vietnam Peace activist Thich Nhat Hanh who walked alongside Martin Luther King, a Zen monk living in France since the mid 1970’s, whose popular manuals reveal the WAY of self cultivation through mindful breathing, listening, observing and reflecting, speaking, asking which is how Yanhua Zhang’s Beijing senior doctor in 1994 spoke of the “4 exams”, to engage in a shared “looking at illness/kanbing” that is as much spiritual in the geisteswissenschaften way of Germany (when Freud for psychiatry and Marx for sociology, both positivists to the quick, pretended to erect natural sciences, when we all know now these were simply 2 philosophies among MANY and those STORIES were corrected, by new DSM IV mental illness codes for psychiatry/mental health PCPs that stated the distinction between physical/ all other medical as opposed to mental disorders was fictitious and a remnant of the outdated dualistic, reductionistic mind/body dualism (which I argued against in my 1987 BODYMIND ENERGETICS, following Groddeck), and we have the joint Commission situating acupuncture in BOTH large fields, of physical medicine and pain management, and of behavioral medicine where the training at Tri-State College of Acupuncture in the voluntarily upgraded masters in acupuncture (to exceed all 54 ACAOM FPD Core Masters standards since 9/2/07 – since you speak of STANDARDS, Steven) formally on then physical side of the bodymind continuum in January 2015, and 6 months later on the behavioral mind side

        Rather than spin your wheels usefully maybe your efforts would be better served pushing ACAOM and NCCAOM to delete TCM communist exams for non CAB-approved programs, have an amnesty on NCCAOM exams where ACAOM and NCCAOM concur that for 2-3 years, as when we first grandfathered into the NCCAOM certification process, NCCAOM resolve that graduation from an ACAOM accredited masters in acupuncture program suffice to become NCCAOM certified in acupuncture(Dipl.Ac) which is what all Maryland Acupuncturists have been able to do since 1984, admitting TCM was not what they practiced; and develop tighter more useful curricular standards and knowledge/skills/attitudes competencies in the 5 core competencies of the Institute of Medicine espoused since 2002 for all 21st century healthcare providers including CAM providers: team-based care; patient-centered care; informatics; quality improvement and risk management; evidence based practice, THAT is what our college did, which made it easy to meet the 54 Core Masters doctoral level FPD standards which are likely to serve as the template on which ACAOM’s Reconceptualized Masters Standards are written.

        THEN add as specific statement based on current best evidence on what constitutes ACUPUNCTURE PROFESSIONAL PRACTICE including:
        – what medical and nonmedical models other than the outdated positivistic, dualistic medical model of disease and its sole evidence based model (which is only a model, NOT the truth) including biopsychosocial, pluralistic (methods-based), functional, behavioral and cognitive behavioral medical models, as well as nursing caring models;
        – what fields of mainstream healthcare routinely utilize acupuncture as part of care and what potential is there for this in other fields (like physical medicine/pain management/ and behavioral medicine, which should be part of entry-level acupuncture training – NOT relegated to optional post professional DAOM specializations; as should training in treating athletic and performing arts injuries; occupational medicine/work related repetitive strain /RSI and cumulative trauma/CTD; post-traumatic stress and other related disorders.

        While wellness is nice, it has very little to do with caring for human suffering and is an elitist and niche angle that all multidisciplinary professions are grabbing at selfishly with NO evidence (what evidence will ever be provided for being well, for integrative health, which should never, will likely never be covered by any healthcare plans, as serious mainstream and integrative medicine, as well as primary acupuncture care providers are too busy caring for suffering bodies, minds and spirits to be doing concierge care for the well-to-do (I trust the Community Acupuncture Network has taken its sharp look at such models that are so very not in line with why most of us got into acupuncture; and will make Acupuncture, finally being taken seriously in care of physical and mental disorders, and listed by the Bureau of Labor & Statistics, look JUST LIKE THE OTHER WELLNESS HAWKERS TO ‘THE WORRIED SICK’ (See Hadler’s powerful book by that name!). TAISophia’s founding president’s Jesuit mentor and militant, and a powerful anti-professional activist like John Dewey, Father Ivan Illich [in his celebrated MEDICAL NEMESIS (on the expropriation of health) in its revised forward as an address to nurse practitioners looking to establish a first professional doctorate (which failed, and lead to a model so parallel to ACAOM’s USDE recognized 3-year masters entry-level and optional 18-month post professional doctor of nursing practice), stating the biggest threat to human beings was the “pursuit of health” which no less than feminist militant Barbara Ehrenreich blasted with great humor, and which a popular CBT therapy – A.C.T. – Action Commitment Therapy makes its main target, both citing work on resilience in trauma and hardiness in general, to help people develop a moral, ethical, non-entitled, stance much like Stoic, Cynic and Epicurean pre-Christian care of the self practices (the name of Foucault’s 1984 book) and self cultivation known as the ‘great learning’ which Father Keating of the Christian Contemplative Tradition calls the perennial philosophy which was the core of the ‘sciences of spirit’ or geisteswissenschaften that both Freud and Marx attacked (and then came Stalin and Hitler and Mao and Mussolini in rapid succession!). SO following Thich Nhat Hahn’s Zen take on self cultivation and mindfulness practices to “awaken the heart” – the aim of all Hindu informed ‘heart-sutras’, in his TRUE LOVE, we would do well as he advocated strongly in its last chapter to GET RID OF OUR CONCEPTS that no longer serve: all TCM concepts from a failed New Medicine Effort that led to the re-appropriation BY THE PEOPLE of the way of medicine, including free access to all their own spiritual practices (daoin, yangsheng, xinfa art of the heart self-cultivation) and free practice by all of its providers with only Chinese herbal MEDICINE limitd to STATE licensed hospital-based DOCTORS OF CHINESE MEDICINE [whose herbal medical training, supported by that of licensed herbal pharmacists – the real and indispensable experts in such medical use of herbs as drugs] , integrated often with Biomedicine and a in a bigger and bigger BIG PHARMA process which might make great advances in a few new drugs for some serious diseases like cancer, MS, Parkinsons.

        Everything about the NCCAOM examinations is ALL WRONG for American Acupuncture as a profession, now that it has been LET LOOSE from the power grip of the deceptive but unfounded ORIENTAL MEDICINE which has never existed in this country.
        Let ACAOM and NCCAOM give our masters in acupuncture graduates a present this Holiday season and for 3 years to come, and make all ACAOM accredited masters in acupuncture and masters in Oriental medicine graduates become Board certified for the price of those exams and the Dipl.Ac. process, and submission of CNT, CPR, and ACAOM transcript. THAT has been done for 5-Element graduates for some 21 years, so why not all masters in acupuncture graduates in all other styles?

        As for those who want a fast, cheap Doctor of Acupuncture certificate suitable for framing that is a legal document, apply for Rhode Island Licensure and for less than $1,000 you will have a bona fide state license calling you a DOCTOR OF ACUPUNCTURE which is all the proposed FPD Doctor of Acupuncture programs will afford you. So you too will have to do what well respected PRC faculty at our college and elsewhere do: list the state/country in parentheses where the doctorate was bestowed so in this case:

        that will surely vie as well as using those degree designations for any possible DAc program in the net several years until ACAOM is able to gain the same USDE Recognition for the First Professional Doctorate as for the already well established First Professional Masters. In making that case, which it can do once one non-profit FPD program has gained DAc candidacy, for example, or one for-profit program, full accreditation – so in some 3-5 years perhaps. Until then the sale on First Professional Doctorates will be in full force, and it might be ACAOM will be forced to require that any such program that goes outside its required substantive change approval process, put TRANSITIONAL after its name like in PT: Doctor of Physical Therapy (Transitional); or DPT-t.

        RHODE ISLAND or RI has such a more American ring to it, don’t you agree?

        A bona fide Doctor of Acupuncture (Rhode Island) and DAc (RI) is well within any NCCAOM board certified acupuncturists’ grasp and much easier on the pocket book than the $10,000 or so the ‘t-‘ DAc or ‘t-‘ DOM is likely to cost. And if you all join in lobbying the NCCAOM to join with ACAOM in an amnesty that allows all ACAOM accredited masters graduates to get NCCAOM certified in acupuncture [it seems like the least NCCAOM can do for the 27 year slavery to TCM California Acupuncture Board program standards, and after a 3-year Joint Task Force, it might come out with non-TCM biased actual practical written exams with all 3 having a practical component, one on live models and one on self that already in place ready for s simple rehaul (PLPE; CNT; CPR wirth AED). NCCAOM has always been successful in selling the states on its processes, and this one has NO TCM-bias, is all focused on SAFE and COMPETENT INDEPENDENT SKILLS of Point Location on a live person(s); Clean Needling according to OSHA standards on self, so live needling, and
        live satisfactory performance of COR with AED skills for emergency care while calling 911. If ACAOM/NCCAOM require that ALL ACAOM accredited and candidate programs require successful completion of those 3 examinations BEFORE starting Senior Year community clinic it is a HUGE improvement in their joint efforts to promote safe and competent care, of actual college clinic patients rather than wait until they have left and are licensed, which then fortifies ACAOM’s status of guaranteeing to states that only those who MEET & EXCEED ALL NATIONAL STANDARDS FOR SAFE AND COMPETENT PRACTICE BE LICENSED IN ACUPUNCTURE.

        If I were a player on NCCAOM or ACAOM now, I would lobby the entire ACUPUNCTURE COMMUNITY which especially applies to the Masters in Acupuncture students and graduates who have been given a very raw deal for a very long time.

        What so impressed Dewey in that New Culture Movement was the total disdain for politics and political groups, and unfortunately the rising Marxist group that carried Chairman to Power with a STORY of a CULTURAL REVOLUTION the horrors which just came out a few years ago in his biography for naive English speaking readers who wore Marxist garb and had little red books under one arm as they hawked their own and their friends Communist Manifestos which has poisoned American Acupuncture.

        Time to stop drinking the cool-aid and like in that celebrated New Year’s Eve movie open the window and your MAIL TO ALL buttons and shout with me:

        – NO MORE TCM


        – GIVE MASTERS IN ACUPUNCTURE GRADUATES FROM ACAOM PROGRAMS A 3-YEAR AMNESTY AND RELIEF FROM TCM-BIASED COMMUNIST CERTIFICATION EXAMS THAT MARYLAND HAS NEVER REQUIRED WHILE NON-BIASED PROCESSES ARE BUILT INTO JOINT ACAOM/NCCAOM PROCESSES to ensure safe and competent independent primary acupuncture care and leave the testing of knowledge/foundations to the accredited programs who are he experts in that regard.

        – And if any new national groups do develop, let them have NO EXECUTIVE COMMITTEES and form them as regional Communities of Practice (cf. Etienne Wenger(, formed pragmatically, as Dewey would have appreciated, around a common PASSION for Acupuncture and its potential in THAT region of the nation, with no tolerance for any efforts to impose ONE MODEL or ONE STANDARD. ACAOM’s missions precludes that and fosters diversity.

        NCCAOM needs to join ACAOM in that regard.

        As for CCAOM and AAAOM, based on Wenger’s model of viable ‘communities of practice’ with a PASSION for Acupuncture & Oriental Medicine, and hence a reason to exist;: these 2 organizations have shown themselves to model what Confucius himself called XIAOREN behavior, which is to say petty, base, lowly. The Confucian solution for such pettiness is to stay clear and show once how ashamed you are of your fellow human beings for letting you down in YOUR shared passion, in your communities of practice.

        A letter showing how ashamed you are of how AAAOM and CCAOM colluded with a CAB Communist model that did GREAT HARM to 3-year masters in acupuncture programs from 1987 to today. The First Professional Masters is secure and will be even more solid when ACAOM adopts revised standards in the foreseeable future; and the DAOM is now secure thanks to ACAOM’s morally and ethically correct actions to adopt revised standards to OPEN that program that CAB-programs tried to co-opt and monopolize for their own selfish ends, which Community Acupuncture Network said would happen, and both are USDE recognized.

        What happens to the unstable and unpredictable First Professional Doctoral programs (DAc or DOM) is anyone’s guess and the better option is on the east coast, in the old state of Rhode Island, where a Doctor of Acupuncture license legally awaits with no pretenses and no stories.

        This is as accurate and true as I can make it, and I have spent countess hours researching all of this, which I have been sharing with ACAOM, CCAOM, and NCCAOM for over a year now. It cost me an early retirement as president of the college I founded and directed since 1982, which I had hoped to do on my 66th birthday in June 2015 (so much for thinking one can control the mandate of the heavens). It also cost me a scary 3 days in the neurosurgery ER/ward when eventually non-emergent conclusions were drawn for what is likely within the range of normal for an older man like myself with familiar slowly degenerative muscular dystrophy. THAT gave me room to do more serious work on the Art of Suffering and the Art of Dying (having already done my best at the art of living and following my passion for a livelihood as college president and busy acupuncturist to its natural end) as Illich suggests.

        My own poor working class Methodist and rather recently adopted Neo-Confucian Faith makes me far more committed to such work, as one among so many wounded healers who have no delusions that their medicine will cure disease and ward off death, and a deep disdain like Illich’s, and my mentor Foucault’s for the practice of those who sell health to the healthy and wellness to the well, even when it is called INTEGRATIVE.

        This train of thought got re-provoked as I took a look at a Florida based WELLNESS organizations $19 seminar. Based on the well worn chiropractic model that caused us all to take notice for the past 30 years( leading to serious decline in that field with its colleges grabbing at First Professional Masters and now First Professional Doctoral programs in AOM, with NO interest in the post-professional rigorous doctorate which would make those grads upstage their DC fellow students whose profession has never valued a post professional doctoral, ostensibly because there is nothing advanced left to learn after graduation, while medical and osteopathic grads can do very respected 2-4-year residencies in specializations like the DAOM affords, and just like advanced nursing practice has endorsed with formalized textbook standards as of 2014, for a post professional DNP). The live teleconference promises to teach what a Wellness Program consists in, as per Obama’s initiatives. But this is not meant to run a 1-hour wellness workshop and be done with it (which would be a great gift to all our patients not to be sneezed at). NO, You will also learn “how to sign up 80% of your audience as new patients”…YUCK.

        As Thich Nhat Hanh says in that last chapter of TRUE LOVE, on discarding our concepts, and in keeping with Ivan lllich’s probing warning (which DID lead doctoral nursing pioneers like Jean Watson, PhD, RN and her Watson Caring Science Institute by 1985 to call for caring science, sacred science informed in 2014 by Thich Nhat Hahns 5 mindfulness practices, not to talk of wellness and health, but of suffering and HUMAN CARING.

        I suspect that is a message President Obama would appreciate. Signing up gullible people after a wellness spiel is, as the German word ‘spiel’ denotes, a Game, not a show of compassion and human caring.

        We can avoid these empty slogans that make would make our graduate degree programs look the same as a 2-hour $19 teleconference. That is what Ivan Illich was deliberately and mindfully doing as speaker before that group of advanced nursing practitioners looking at doctoral education, whose conference coordinator planned to have that very effect.

        I hope everyone will look hard at the about to be fortified (perhaps for the last time) 27-year old USDE recognized ACAOM masters standards in acupuncture for sure (who knows what will become of masters in Oriental medicine, now that it is clear that profession never existed); as well as the hard-won revised ACAOM post-masters DAOM standards, which any Masters in Acupuncture graduate can now look into doing without EVER being obligated to do a doctorate for entering he profession which is also USDE recognized.

        Does our field also need a First Professional Doctorate in Acupuncture which Rhode Island Licensure would afford so well, and much less expensively? And it surely does not need a First Professional Doctorate in Oriental Medicine for the same reason a masters in Oriental medicine is sounding like a hard sell, except for those with no options in CA programs seeking licensure there and in other states that might adopt CAB program standards.

        After all, Ted Kaptchuk started the practice in 1983 of calling his Diploma in Oriental Medicine from the same Maoist Macau program with classmate Dan Bensky, DO, who listed it a ‘Diploma in Oriental Medicine’. If someone of Kaptchuk’s Harvard stature can misrepresent a diploma as a doctoral degree, in fact as the “O.M.D” after his name (when he only has a bachelors degree) then it would seem ANYONE can do that, and cite Harvard faculty member Ted Kaptchuk’s O.M.D, used there for some 3 decades as precedence.

        If all the CAB program graduates with the Masters in Oriental Medicine did an online massive people’s assembly to vote a resolution on their collective authority, as chiropractors did ONE FINE DAY; and agreed to all use the initials O.M.D. (never listing ‘Doctor of Oriental Medicine’, and then like Ted, and any of us good 70’s folk, saying to patients and professionals JUST CALL ME TED and NEVER putting ORIENTAL MEDICINE spelled out ANYWHERE, then the O.M.D. is not a false representation perhaps, but just an agreed upon abbreviation after your name – O.M.D , and then under that the true statement – licensed acupuncturist (NY, #000171) if it were me for example. O.M.D. might well convey – “OH MY DEAR “with the veiled meaning, TED did it, so why not me (us)? Or “Out of Maryland” where anyone can get licensed without ever studying Maoist TCM or passing any communist NCCAOM exams in that biased style. That is the first state where I got licensed, and staid licensed, while working and paying dearly in time and money in nearby CT, to get the NYS law passed to allow for US trained grads to practice here.
        And that work led to the CCAOM and NCCAOM and ACAOM as we know it, since TSCA had an enormous impact in doing good for the community as a whole, and hence for our patients. I put in my 13 anarchist years taking risks, so why not some of you? And I have spoken up in true Cynic mode, as here, to be true to my mentor Foucault who urged me to follow this pre-communist, French translated meridian acupuncture path in November 1977. Being true to one’s teachers is a daily vow that must be made each night as a neo-Confucian. Then one has to be true to passing on one’s way (like in Do-Jo), so others may safely and with good foundations follow that way: my dear colleague and friend Kiiko Matsumoto and I have each made our Do-Jo’s as best as we could, and trained a new generation of clinical faculty to carry it the next 30 years, while we ready ourselves for the DAOM advanced clinical training program where we can take licensed practitioners and really look deeply at what we have shaped and what they are doing with that style of practice. And finely as a neo-Confucian, one must daily also recognize that one’s best efforts at doing and saying and knowing as part of human becoming are only one’s own best efforts, and any faults in the practice, and deficiencies in my own APM Acupuncture practice, I readily own up to. There too I have done my best, and I see that other, even younger and smarter and more talented minds and hearts are seeing things in ways I would never have been able, like making this style become MINDFULNESS-BASED ACUPUNCTURE which all of our MS/Ac students are now learning.

        Any errors in living and doing and saying and teaching and sharing and loving this life I have been blessed to enjoy these 65 years are my own. Like Illich and Foucault in their later hours, I can truly say as my mother always did that if this night while falling asleep is my last, or if this day I am waking up to will bring suffering, pain, lack of wellness and lack of health and major challenges to test every fiber if my human becoming efforts, I was never promised, or given a rose garden, and I do not appreciate any manner of entitled living. So I will go when the last breath has been lived, as the way of all things, my own judge if I did OK, my best, according to ethical standards I embrace every day.

        Have our professional organizations besides ACAOM done their best? If not, do we need any of them? Do we need new ones? Serious, ethical, moral questions I leave you all with this Thanksgiving week. I would give anything to be able to still treat 20 patients a day and teach and supervise clinic 2- 3 days a week, and I am still very blessed t mange to average 4 patients a week, one a day, and to train one Year II APM clinical practice team in my Home/Office every Wednesday from 2-5:30 to be part of readying them to take over the community clinic this June from those who will have just graduated. Our Year II students use my style, LING SHU meridian style APM, to already be able to work as a team of independent primary acupuncture providers who do one APM rotation in summer and one more in September, and then a TCM rotation in Summer and a second in Fall, and 2 KM Japanese acupuncture rotations in Fall and early 2015. At that point they are ready to use clinical judgment to concur on integrated treatments using 2 styles from February to May. We know our graduates meet and exceed all national standards, and so this matter of being done with TCM multiple choice standardized communist tests, as someone who helped write the first version in 1985, is a focus in my Art of Dying that I will not lose sight of.

        When things go astray, even if one helped create them, one MUST say it is wrong and work to change it.

        Thanks to ACAOM these past few years, MUCH has gone right and I urge you each to thank executive director Mark McKenzie, MSOM, and Chair Catherine Niemiec, JD, MSOM, this Holiday season for the tireless work they do for our community, with solid standards you do disservice to, Steven, by suggesting any guild could come close to matching.

        Happy Holidays,


      • I didn’t suggest unity was a goal. Though I think it would be great for everyone if we could find more common ground. I wrote of unity because you wondered whether “the profession” would be ready to get behind this unprecedented effort to write a guiding document — and I can’t imagine why they would be. I mean, I suppose this document could surprise me, but given what I know of the NGAOM and the AAAOM, their positions are not likely to be something “the profession” will be likely to get behind.

  4. Dear Observer:

    I find it curious that you use such a dualistic and overly simplistic differentiation between for-profit and non-profit AOM colleges as if one is bad and the other good without addressing the far more fundamental issues you touch upon at times regarding the quality of acupuncture education and the right in a non-communist country to train in and teach non-TCM acupuncture.

    Having spent my entire professional career from 1982 in Stamford, CT because NYS law did not allow for acupuncture programs until 1994 when we moved to NYC, from the vantage point of a small for-profit school where all administrative faculty have worked at least 2-3 college jobs to make a good living (myself like others as AOM college administrators, faculty and clinic supervisors, and often with a part-time private or faculty practice as well), and having just stepped down from a 32 year long presidency and as director of education and from most of my private practice due to my own health problems, I find such characterizations grossly inaccurate, knowing how hard many other small for-profit AOM college owners and lead administrators and senior faculty have worked for the past 3 decades.

    It was through the concerted efforts of the now 41 out of 62 ACAOM accredited institutions, which must comply with all USDE recognized ACAOM first professional masters and post professional doctoral standards, that in 2002 the masters in acupuncture was established as the minimum entry-level standard, with the masters in Oriental medicine in California Acupuncture Board approved programs while work by CCAOM and ACAOM on First professional Doctoral standards was undertaken [when ACAOM was pressured through legal means by some Southern California Maoist ‘Oriental Medicine’ forces to develop First Professional Doctoral Standards in AOM; Post Professional DAOM doctoral standards had just been adopted, after much work that pitted those who envisioned California Acupuncture Board (CAB) standards for a 4-year masters in Oriental medicine as the sole entry-level, with the Doctor of Oriental medicine degree handed out with no extra program requirements for what they argued was an overly fecund masters].

    The majority of ACAOM institutions outside California offered primary 3-year masters in acupuncture training and were in states, like California from 2005 onward as well, that only allow for the practice of Chinese herbology within implicit FDA regulations against any claims to “diagnose, treat, cure or prevent any disease”. Under strict Senate Oversight Committee scrutiny from 2005 on, CAB’s website for the public clarifies that licensure there is in primary acupuncture, with the practice of all manner of other AOM modalities, including Chinese herbalism within FDA laws, to “promote, maintain and restore health” with a final clause clarifying that this amended acupuncture law was not meant to prevent any citizen in that state, or any other licensed healthcare provider from such AOM practices. And while TCM CAB program standards still read like a rigid Communist manifesto with no academic breathing room to teach anything outside the Marxist-Leninist catechism, CAB licensure examinations have always only tested in some 52 herbal formulas, while ACAOM masters in Oriental medicine standards call for training in almost three times that many as do NCCAOM Chinese herbology and Oriental medicine certification programs.

    And since a CAB program graduate anywhere in the 37 such masters in
    Oriental medicine programs nationwide can sit for California licensure examinations with such ‘abbreviated training’ with Chinese herbal practice outcomes that anyone could meet by reading a Chinese herbal company’s flyer to buy from the common 50+ formulas with no herbal education or experience, it seems this Oriental medicine program hype by all 37 such programs is far more deleterious to the state of AOM practice in this country than whether it is conducted within a non-profit or a for-profit institution. And if the college is not an ACAOM accredited institution (common for ‘health sciences’ institutions where entry level chiropractic and/or naturopathic programs are often run alongside entry-level CAB approved 4-year masters in Oriental medicine programs, as well as in other integrative medicine or health institutions with regional accreditation now ready to offer First Professional Doctoral programs outside the 12-year hard-won ACAOM First Professional Doctoral standards and substantive change approval processes, thus allowing regional accrediting agencies like WASC on the West coast and Middle States in states like Maryland to approve, without any professional ACAOM program scrutiny or initial approval to protect the public, such doctoral programs under their regional accreditation, thus accessing immediate Title IV Finanicial Aid funds for programs that have not been held to any national AOM program standards. What links such non-ACAOM accredited institutions’ programs together is the desire to ALSO operate entry-level masters, and first professional doctoral AOM programs while offering competitive naturopathic, chiropractic, nutritional science and other health science programs for maximum profit from a smorgasbord of programs, keeping the ones that are profitable with no commitment to AOM graduates over any other graduates.

    In the meantime the 41 ACAOM accredited institutions are AOM focused colleges with AOM programs, and the level of diversity thanks to ACAOM’s mission that is dedicated to such diversity, stands in stark contrast to CAB California based programs which must teach to Marxist TCM strict standards. Since 1987 some CAB approved programs in that state have argued that the current 4-year program should just be called a FPD program offering the OMD doctoral degree which was offered by several schools there from 1984-1996 when ACAOM cracked down on unapproved doctoral programs where meaningless O.M.D. initials could be had for $10,000 red envelopes. Global University ran such a scam on both coasts and was run out of NYS by the education department there, and stopped in CA in short order.

    This desire for a quick OMD degree with no actual education has nothing to do with for-profit versus non-profit schools and either type stands to make a small fortune if allowed to operate non-ACAOM substantive change approved FPD programs.

    In the meantime ACAOM rose to the critique of some ACAOM accredited institutions in NYS, to work to revise DAOM standards which it adopted August 17, 2014, to again allow ( as in 2005-2008) masters in Acupuncture graduates to enter DAOM programs with only 45-hours herbs, for training in any advanced acupuncture styles and ANY other AOM modalities except Chinese herbology (medical Qi Gong, life nurturing practices, self-cultivation and mindfulness, daoin physical practices for example), that would foster diversity and arm masters in acupuncture graduates with practical skills for best acupuncture care. This work to provide a diversity of training is espoused by smaller or larger for-profit and smaller or larger for-profit schools. And the schools pushing for maximum profit making activities are those that are not ACAOM accredited, which offer a panoply of entry-level programs where the First Professional Doctoral programs fit well. Such institutions already offering entry level doctoral programs in chiropractic or naturopathy are unlikely to endorse or operate post entry level DAOM doctoral programs, as those would represent a far higher level of clinical doctoral education than they offer in their other existing programs.

    Such decisions are made based on maximizing profits with no clear notion of where AOM programs fit, and no necessary dedication to AOM entry-level standards or the good of AOM college graduates. That would seem to be a clearer focus for the criticisms the Observer has levied of late.

    But one would be hard pressed to imagine a real argument against the new ACAOM post professional DAOM standards finally open to the majority of masters in acupuncture graduates in this country, who will never be required to do such doctoral training, but will now have that option for the first time in well over a decade, while CAB approved masters in Oriental medicine programs have monopolized that training in the name of the illusory “Oriental Medicine” profession CAB can no longer claim exists in that state.

    Perhaps the really radical stance would be to call on ACAOM and USDE and the states to eliminate 4-year masters in Oriental Medicine programs which require a year of useless Chinese herbal education for very little legal rights at the end of it to practice this as Oriental “medicine”; and to call on ACAOM to put the First Professional Doctoral Standards on hold for the same reason, to see if there is any consensus now, with no undue influence operating, with a similar national survey ACAOM conducted for the revised DAOM standards for a FPD program in Oriental medicine, to see if both first professional programs might just follow newly revised DAOM standards in all of AOM practice, for a 3-year masters in AOM (MAOM) entry-level program standard open to associates degree graduates (5 years total to licensure) – as well as a 4-year doctorate in acupuncture according to ACAOM FPD standards in acupuncture, with any other AOM areas as part of the training to fit college missions, open to those with 90 credits (or better yet, a Bachelors degree which many states will require for such an FPD program – 7-8 years total).

    This would allow the masters in acupuncture to remain the minimum standard as it has in so many states and programs since 1987 with a 5-year educational path, and a competing 7-8 year Acupuncture and Chinese herbology path which would allow the consumer to decide.

    While the FPD could become a forced degree in California and a few other states that require CAB 4-year training including Chinese herbology, like Florida, unless it also became the main program in a critical mass of AOM colleges and other multi-disciplinary institutions – with full national consensus, it would never become the required entry level nationwide.

    NCCAOM is required to follow actual acupuncture and Oriental medicine practice in the US, and its work that is close to success to have Acupuncture alone finally recognized as a profession by the federal Bureau of Labor and Statistics for a possible 2016 listing date, will seal primary acupuncture as the minimum entry-level training required, which has already stood the test of time in virtually all states for over 27 years.

    Here is the link to Maoist influences on (Traditional) Chinese Medicine. It should be noted that while some Maoist ideologues pushed WHO to use the term “Traditional Chinese Medicine (TCM)” as the name for this PRC practice since 1958, WHO adopted its generic nomenclature that has far freer applications: hence, Traditional Medicine of China, Traditional Medicine of Japan and of Korea and Taiwan, with some serious talk by some within PRC for Traditional Medicine of Tibet as THE national traditional medicine in PRC, now that most of Chinese medicine and acupuncture-moxibustion has been deregulated by popular demand, and State mandated hospital based Chinese (herbal) medicine is aligned ever more with Western medical research to produce new global market medicines with little commitment to acupuncture, moxibustion, Chinese bodywork, daoin, yangsheng or other care of the self classically rooted practices which the public is free to pursue as folk therapeutics with their local providers.
    Chairman Mao Invented Traditional Chinese Medicine – Slate…/traditional_chinese_medicine_origins_mao_inven...
    Oct 22, 2013 – Chairman Mao Zedong (left) and Vice Chairman Lin Biao acknowledge the waving of “little red books” by a crowd in China. Photo by …

    • Mark,

      You cover a lot of ground here. First, I completely agree that the for-profit/non-profit distinction is not necessarily all that useful. I would certainly hope that ALL schools, and especially all acupuncture schools, would want to track the success, or lack thereof, of their graduates, and would constantly be working to make their programs better based on what they learn from that tracking.

      I would hope that the board of trustees of non-profit schools, not having an economic reward for overseeing a diploma mill, for instance, would fulfill their responsibility to students in a way that investors in a for-profit school might not. But, still, I agree that all schools should held to high standards and should be reporting to all potential students the actual experience of their grads.

      I’ll address a few other points in your comment — I don’t think you’ll get much sympathy from acupuncturists regarding the multiple jobs and limited income of those folks working for acupuncture schools. After all, many of us are also working multiple jobs — often other income producing jobs, and, if not, wearing the multiple hats of janitor, office manager, practitioner, insurance biller, marketer, receptionist, etc. Many of us do all of that without earning a good living, without having any benefits whatsoever — not sick leave or maternity leave or health insurance or paid vacation — and with having to pay off tens of thousands of dollars of student loans. (What percentage of Tri-State grads rely on IBR plans?)

      I think I agree with at least some of what you say about herbal training. I am deeply concerned about the move to require herbal training for licenusre in a growing number of states.

      In any case, there is more I could say, but, yes, both for-profit and non-profit schools should care about their graduates and should be making sure that what they are teaching is what students need to be successful in practice.

      • Mark – how about some periods and shorter sentences! I will address just the workforce outcomes which is applies to quite a few of your statements. The Gainful Employment Guidelines (GEGs) are not the first org to require schools to provide workforce outcomes. California’s Bureau of Private and Post Secondary Education (BPPE) has required this since 2011 as part of a Performance Fact Sheet (PFS). At least half of the schools approved by the CAB to take the Calif Acu Licensing Exam (CALE) schools submit the completed report to BPPE. Those that do rarely submit a completed report. The PFS requires standard data that is also required by the GEGs. These data include salaries and whether graduates working in the profession. A source for these data is rarely provided. Many schools create their own version of the standard PFS form. All these schools are ACAOM accredited. I doubt that most acu schools care to colelct graduate workforce outcomes. I fact, I doubt that most AOM schools have the expertise to do such according to USDE guidelines which are specified by the GEGs. The same holds for the NCCAOM appeal to BLS for an SOC (Standardized Occupation Classification). The requirements to qualify include collecting very specific workforce outcomes data. The NCCAOM request was comically off-target, choosing to present the familiar marketing schemes as justification for winning the SOC. The SOC requirements are very clear and straightforward and and based on reliable and valid workforce outcomes data which the NCCAOM collects as an adjunct to its JTA. NCCAOM gets a pass from much of the profession when it chooses to avoid transparency inits reports to the profession. I am certain this will not fly with the SOC Policy Committee. The BLS surveys occupations that provide the same classifications of data of all occupations that seek an SOC. The ability to follow directions is important. One more thought. The diversity which ACAMO endorses is actually a standard of convenience and not excellence. Acupuncture laws vary so widely among the 45 states with a licensing law that ACAOM wisely chooses to adapt its standards to fit the widely varying laws. The same is true for how NCCAOM recommends which of its exams will meet the standard of each state’s law. This will only change when true national standards developed by the organizations representing practicing licensed professional are endorsed. Standards prepared under the national professional organization with input from other professional orgs (NGAOM, CSA) are forthcoming. Let’s see if the profession is ready to endorse this unprecedented attempt to accept a guiding document for training and testing. For the record, California has the highest educational standard in the nation with 84 specific areas of study with specific hours of training attached to each area. This is a practical solution given that 40% of all LAcs reside in California which also has the only state licensing exam. Multiple reviews comparing the NCCAOM to the CALE have shown both have strong and equivalent psychometric qualities. This does not mean wither is valid in terms of what an LAc needs to learn to be successful. However, it should be clear given NCCAOM’s own workforce outcomes findings that what is being taught in most AOM programs does not lead to the ability for most LAcs to earn a living.

        • Dear Steven,

          Sorry. My doctoral studies with mentor Michel Foucault encouraged a form of embodied ‘thinking-and-feeling (or mind-and-heart) – xin in Chinese’ which brought Greco-Roman ‘care of the self’ practices (the focus of Foucault’s posthumous last written text by the same name) from Socrates, born 500 BC and those of Confucius born at the same time, whose GREAT LEARNING ( Daxue) on self cultivation became the first of THE FOUR BOOKS as Zhu Xi refined the from 1137-1200 and were further popularized by Wang Yang-ming by 1527 as “the learning of the heart-and-mind”.

          I have studied the California Acupuncture Board guidelines and recognize well this trade school/vocational school attention to every “nut and bolt” – if one misses the class on nuts, one cannot use the bolts. The Tri-State College of Acupuncture was also regulated at first in Connecticut as such a vocational/trade school. But the AOM profession moved to masters degree level standards for all ACAOM accredited acupuncture programs in 1987, and for 4-year California Acupuncture Board approved programs by 1994 with CAB mandated 660-hours of Chinese herbology training.

          As an active member of the CCAOM council of colleges from 1982 when I was its first president, until 2008 when aggravation of genetic muscular dystrophy symptoms made such travel too exhausting, I weighed in fully on how the colleges as communities (with active input from administrators, faculty, students and alumnae which ACAOM standards require), must scrutinize any development of standards for educational merit, as improvements in education leading to improvements in practice. I pressed NCCAOM to develop actual practical examinations that would protect the public with safe practice, which NCCAOM did wit the Clean Needle Technique Course and examination of clean and safe needling according to OSHA and other guidelines that it gave over to CCAOM as a much desired income producing activity, rather than take full responsibility for its continued refinement. Likewise I co-chaired the expert task force that developed the Point Location Practical Examination which met various state needs for an actual practical examination,like NYS, and our Chairman of the Board, Bill Skelton who overlapped with me on NCCAOM was a PLPE NCCAOM examiner for many years in several states including NYS and we have discussed recently how that examination, which matched far more closely the actual skills of point location of live subjects, was far superior to the various written examinations NCCAOM replaced it with with no rationale for dropping yet another practical examination. When the PLPE was used, senior clinical interns knew they knew point location and simply focused on how the test would be conducted to prepare. Once the PLPE was dropped and replaced by a written multiple-choice examination with strange pictures that had nothing to do with the reality of live subject, senior interns started spending inordinate amounts of time worrying about and studying Year I textbook memorized point location over the refined point location they developed in 200 hours of clinical practice under close direct supervision before entering the first community clinical rotation at the end of Year II. THAT is a waste of time and undermines solid hands-on clinical know-how with textbook standardized nonsense.

          Textbook standardized training moving from patterns to predetermined point (and herbal) formulas known as ‘bianzheng lunzhi’, which Judith Farquhar studies very carefully in her 1994 KNOWING PRACTICE based on 1983 fieldwork and study at Guangzhou College of Chinese medicine, carries with it a veiled yet decisive critique of what some senior scholar-doctors she observed were “feeling to be an ideology they could do without (ibid, p 214).” She shows how that Maoist, Marxist-dialectical ideology which is of course a Western philosophy approach to thinking and learning developed by German theoretician Karl Marx, served to undermine the classical ‘Way of medicine’ or ‘yidao’ as stated in the first chapter of the SPIRITUAL PIVOT or LING SHU which is rooted in ancient Chinese philosophical understanding of ‘Dao’ as the overarching concept of ceaseless transformations refined by the ‘modern’ School of Dao (‘daoxue’, often translated as Neo-Confucianism) by Zhu Xi by 1200. Another medical ethnologist starting from Farquhar’s probing study of the actual process of the clinical encounter in Chinese herbal medicine, known as ‘looking at illness or kanbing’, Yanhua Zhang shows how this learning of the heart-mind that characterized the way of medicine in China from the beginning was rooted from 1350 to 1650 especially, in heart-sutra informed Chan (Zen) Buddhist practices that Sun-Simiao already references in the 7th century CE, along with Confucianism and Daoism, as the ” general literature” of acupuncture-moxibustion and herbal practices. From 1350 to 1650 all practitioners of the way of medicine would have been versed in Zhu Xi’s refined FOUR BOOKS (Cf, Gardner’s excellent user friendly book of excerpts by that name, with Zhu Xi and his own commentary) which speak to the need for daily commitment to self cultivation where 30% of one’s ‘reflections on things at hand’ (the name of Zhu Xi’s collected writings translated by 1965 by Wing-tsit Chan), of the 10,000, or ‘myriad things’ is about those things themselves in their dynamic nature, and the other 70% of learning of the heart-and-mind entailed gaining what Wang Yang-ming termed ‘instructions for practical living’ in his collected work by 1527, which Wing-tsit Chan also translated in 1963, the same year his seminal A SOURCE BOOK OF CHINESE PHILOSOPHY came out, where he shows that as far as we moderns are concerned, that philosophy IS ‘Neo-Confucian’, and hence entails a refinement of classical Chinese self-cultivation practices while incorporating a thousand years of Chan Buddhist, heart-sutra informed mindfulness meditative practices and Daoist theory already felt to be core for Sun Si-Miao by the 7th century.

          Sabine Wilms’ excellent introduction to the 1601 GREAT COMPENDIUM OF ACUPUNCTURE AND MOXIBUSTION (‘Zhenjiu Dacheng’) by Yang Jizhou for Chinese Medicine Database of Portland, Oregon which is seeing to the full translation of all volumes) speaks to this classical foundational philosophy rooted in self cultivation and life nurturing (‘yangsheng’) practices which Farquhar and coauthor explore in modern Beijing in TEN THOUSAND THINGS.

          Yanha Zhang’s ethnographic study of the role of the emotions (‘qing’) and emotion-related disorders (‘qingzhi bing’) that are at the root of chronic internbal difficult illnesses (‘zabing’ which appeared in the original ‘Cold Treatise’ text but were dropped, as was the acupuncture discussion, from PRC simplified modern Shang Han Lun (originally Shang Han ZABING Lun), in her 2007 TRANSFORMING EMOTIONS WITH CHINESE MEDICINE, shows clearly on pages 87-90 how central these difficult illnesses, which modern (T) CM texts largely ignore, was from 1350-1650, coming to be seen as stagnation (‘yu’) of ‘Qi’ or more simply, as ‘butong’, or blockage of circulation of Qi and Blood. And when one compares modern Zen ‘art of the heart’ practical manuals like Thich Nhat Hanh’s TRUE LOVE: A Practice for Awakening the Heart which ends with a chapter of “getting rid of our concepts” to dissolve “lumps of suffering”, or his TAMING THE TIGER WITHIN: Meditations for Transforming Difficult Illnesses we can appreciate how long-lived these popular, personal, self cutlivation practices have been, and how they represent a radical non-dualistic practice akin to modern cognitive behavioral psychology and training in the role of the ‘hot intelligences (social, emotional, personal)’ that modern emotional brain (Ledoux) research has unveiled that serve as an antidote to logocentric, positivist, and also Marxist dialectical ‘scientific’ thinking that totally ignores this ‘general literature’ recognized and stressed by Sun-Simiao some 1400 years ago, and fails to appreciate the central and predominant place mindfulness breathing and deep listening practices played during the formative years of acupuncture, moxibustion and medicine in China from 1350-1650 when authoritative texts became widely available, and core glossaries of key nondualistic concepts of popular, everyday, common philosophy (‘yinyang’, ‘qixie’, ‘tiandi’, ‘wuxing’) also informed the study of the way of medicine or ‘yidao’.

          What is at issue in this ‘Great Learning’ or “Learning of the Heart-and-Mind’ is NOT contained in the anachronistic, highly outdated, rigid and Maoist ideologically established California Acupuncture Board program standards which were originally in “Oriental Medicine” until 2005 when the Senate Oversight Committee there forced CAB to stop such scope expansionism and just list the original law in that state “for Oriental medicine through acupuncture” defined as treatment of certain diseases and conditions with a later 2005 amendment – the best the ‘Oriental Medicine’ forces could get passed in that State, for “use and prescription” of all manner of other AOM modalities like massage, dietetics, and use and prescription of herbal, animal, mineral and plant substances and nutritional supplements, “to promote, maintain and restore health” – hence as health foods and self-help practices withe a final sentence that clarifies that nothing in this California acupuncture law amendment is meant to prohibit any person not licensed in California, or any other licensed heal care provider from use of any of these modalities.

          The “Oriental Medicine” emperor has had no clothes and been blowing smoke for almost a decade. Furthermore, as a state that has never been required to submit the competency of its graduates to any ACAOM or NCCAOM national standards even as benchmarks, and given that CAB examination standards in Chinese herbology seem to only require competency in some 52 formulas (about what any bona fide GMP compliant herbal company carries and lists in its basic bulletin for consumer use), as compared to about three times that many in national ACAOM and NCCAOM standards that were developed out of undue and constant CAB-approved school pressure to MEET CAB licensure standards, it would seem that any national consensus set of standards which the organization (what organization, I missed the name?) you allude to is devising will be useless if they do not start with the utter fallacy that CAB program standards, now reworded as ACAOM’s revised DAOM standards were 8/17/14, to PUT ACUPUNCTURE BACK IN, so that those standards are for the ‘Field’ of Acupuncture and Oriental Medicine (AOM) which became the consensus larger field when all national organizations added AOM to their name, for the PRIMARY PROFESSION OF ACUPUNCTURE.

          There are no laws in place in California that would allow for practice of what ACAOM was pressured to develop out of CAB-program pressures by 1994 for a 4-year masters in Oriental medicine program, defined and followed by NCCAOM in its postgraduate Chinese Herbology certification program, as “the use of Oriental herbs in the context of Oriental medicine”.

          I have presented this critique to ACAOM and NCCAOM as they look at all of this more closely while ACAOM’s Reconceptualized Master’s Task Force is at work on revised standards and have called for an discontinuation of ACAOM 4-year masters in Oriental Medicine standards (which CAB-approved programs have always wanted to simply transform with little if any extra work into a lucrative ‘completion’ or ‘transitional doctorate’ that will do nothing to upgrade masters in Oriental medicine graduate’s knowledge of skills set, and that will in no way require that colleges make a serious effort to throw off the yoke of Maoist ideological CAB-program standards, and get with the program of restoring the actual ‘foundations’ of the ‘way of medicine’, rooted in the Daoist, Chan Buddhist informed Neo-Confucian FOUR BOOKS that anyone who studies Chinese acupuncture and moxibustion and medicine can now read freely with excellent philosophical interpretations, thanks to the pioneering classical Chinese translation scholarship of Roger T. Ames from the University of Hawaii at Manoa since 1994 when PRC ‘recent archaeological finds’ like those that uncovered the ‘Dingzhou fragments’ unveiled, leading him and Henry Rosemont Jr to do a new translation of the second of those 4 books, ‘THE ANALECTS OF CONFUCIUS; and he and David Hall to do a new philosophical translation of the 4th and central book, the ‘Zhongyong’ which portrays the self cultivation practices as “Focusing the Familiar” in a way similar to Thich Nhat Hanh, which is the way they translate that title.

          Instead of a labored list of the nuts and bolts of TCM as CAB has been using for way too long, we need to take full advantage of ACAOM’s USDE mandated policy of academic freedom that allows for teaching in the many styles of acupuncture-moxibustion that have survived transplantation to our soils from Canada, French Canada, France, England, Taiwan, Japan, Korea and the PRC, including lineages in PRC that are being recognized as bona fide ‘folk styles’ like Dr. Wang’s ‘Applied Channel Theory’ known to us via his book with Jason Robertson from SIOM, with another lineage bearer, Nyssa Tang in NYC, just as French Meridian and Japanese lineages or Do-Jo as one wold say in Japanese, have been established with compassion, love and great attention and care at the Tri-State College of Acupuncture for 32 years.

          What you speak of sounds like more of the same CAB-rigid articulation of a sole (T) CM style with absolutely no evidence in that state or national standards based on hat state’s demands, for a Chinese herbal medicine that could compare with that of Chinese Medicine research hospitals in PRC where ‘zhongyi’ doctors work with the enormous help of Chinese pharmacists who are the true experts of pharmacognosy and herb-drug interactions, and with ‘xiyi’ doctors and residents for a concerted integrative medicine hospital research-based training; or the rigorous Korean OMD training programs that give real weight to that degree designation; or that which Japanese Kampo Medicine trained licensed pharmacists and biomedicine trained doctors acquire.

          Where is the evidence that CAB standards when matched to CA Acupuncture amended law from 2005, train for more than what the licensed Japanese acupuncture practice allows, for using some 70 common tea pills as an adjunct to acupuncture, but never portrayed as Kampo Herbal Medicine?

          The new DAOM standards our college has applied under, open to any masters in acupuncture graduate with a 45-hour introduction to Chinese Over-The-Counter products [that meet all FDA and GMP requirements against any claims to diagnose, treat, cure or prevent any disease], will amply train those M/Ac graduates to safely add such common products that any citizen can go and buy in any East-Asian store that sells such products, as part of the person’s own self-care or life nurturing practice. The FDA refers to such uses, just as is done in PRC since 1987, as “folk uses” of such products which are absolutely allowed in this country.

          In my mind, the best thing to do until this matter is really addressed, would be to lobby NCCAOM and ACAOM to defer finalization of Reconceptualized Masters in Oriental Medicine standards and establish a separate expert Chinese Herbology Task force to refine those standards no longer “in the context of Oriental medicine”, which has no standing in the USA since 2005 at least but rather “in the context or primary acupuncture” which would be an honest and true outcome statement against which serious Chinese herbology standards might be developed. And if that happens, I would hope the AOM college, student and practitioner communities would rise up in an ad hoc consensus movement to petition every state, starting with California, Florida, New Jersey, which are 3 examples of states whose actual laws do NOT support the “use of Oriental herbs in the context of Oriental medicine” or anything even remotely similar to abandon what is likely a very dangerous legal status for our graduates when FDA and other laws are soberly studied.

          Mark Seem

          • Mark – John Wooden used to say never confuse activity with achievement. The California Acupuncture Board (CAB) is a regulatory body that oversees licensure in the state. ~40% of of all LAcs and half of all training programs reside in CA. There are no profession derived KSAs such as those found in every established health profession in the nation. That is a good place to begin standardizing this profession. ACAOM and NCCAOM adapt their standards to suit the needs of licensing laws in the 45 states with a law. The standards shift for each state. This is a standard of convenience not excellence, regardless of political and dialectical origin. The CA acu law states “The purpose of this article is to encourage the more effective utilization of the skills of acupuncturists by California citizens desiring a holistic approach to health and to remove the existing legal constraints which are an unnecessary hindrance to the more effective provision of health care services. Also, as it effects the public health, safety, and welfare, there is a necessity that individuals practicing acupuncture be subject to regulation and control as a primary health care profession.” Furthermore the law states “Acupuncture” means the stimulation of a certain point or points on or near the surface of the body by the insertion of needles to prevent or modify the perception of pain or to normalize physiological functions, including pain control, for the treatment of certain diseases or dysfunctions of the body and includes the techniques of electroacupuncture, cupping, and moxibustion.” The scope of practice includes other provisions: “To perform or prescribe the use of Asian massage, acupressure, breathing techniques, exercise, heat, cold, magnets, nutrition, diet, herbs, plant, animal, and mineral products, and dietary supplements to promote, maintain, and restore health. Nothing in this section prohibits any person who does not possess an acupuncturist’s license or another license as a healing arts practitioner from performing, or prescribing the use of any modality listed in this subdivision.” This latter section notes that other licensed practitioners of the “healing arts” may also employ heat,cold, magnets nutrition, etc.
            I gather your wish is to endorse traditional practices which you have richly described and documented (although I would hardly know) that do not fit with common healthcare training pedagogy (practical exams is an area in which I have knowledge and experience). The practices you describe apparently are more commonplace in Japan and China than in the USA where healthcare is widely tied to EBM and the scientific tradition. The struggle to design AOM training to fit a “folk style” conceptual model has resulted in a profession that does not fit into the mainstream of medicine (with the recognized poor workforce outcomes). I used to refer to California as the tail that wags the dog. It is the dog. The CAB has a simple mission: protect public safety and approve training programs. Neither ACAOM or NCCAOM is commissioned to protect the public or approve training programs. Along the same lines, your training focused on common OTC products as a prelim req for learning about herbal products aims at patient safety. As you can read above CA does not exclude “nutrition, diet, herbs, plant, animal, and mineral products, and dietary supplements” as part of an LAcs repertoire. Here is the link:

          • Dear Steven,

            You are kidding right?

            If anyone can use and prescribe all of those aspects of AOM in California [which you do honestly quote from mandated, finally accurate and no longer scope-expansionist CAB- website pages for the public] including those not licensed in acupuncture and any other licensed healthcare provider, then ipso facto such use of natural products MUST be under implicitly intended federal (and State if appropriate) FDA laws.

            Play with the term primary health care a you like. Dreams come cheap for those who never went to med or osteopathy college or did any residencies IN THIS COUNTRY.

            If you CLAIM to diagnose, treat, cure or prevent any disease it is the practice of medicine.

            Acupuncture-moxibustion, amma, tuina, shiatsu, sotai are not medicine in China, Japan, Korea, Vietnam and never will be. They routinely included study of the classical medical and Confucian, Chan (Zen) Buddhist and Daoist texts as Sun Simiao advocated for any serious scholar-physician in the 7th century. From 1350-1650 especially as Yanhua Zhang’s superb medical anthropological study shows (TRANSFORMING EMOTIONS WITH CHINESE MEDICINE, SUNY, 2007, pp 87-90 and chapter VII) at the height of the neo-Confucian dominance in education which lasted until 1905 under he Nationalists, and was not banned by Chairman Mao until 1972 after a 1 year period so people could read it (whose FOUR BOOKS were back by 1987). Anyone in Japan, Korea, Vietnam, Taiwan knows this and has read these things. ONLY the communist, Maoist Chinese medicine new doctors from 1958-1987 were left in the dark and if they decide no to know it is because they have gone for the lofty (and rigorous) road of doing serious herbal medicine in hospitals with TCM doctors and residents and herbal pharmacists supporting their study and SAFE NON-Toxic practice, with those herbal pharmacy residents and biomedicine doctors and residents all around, which NO CAB Chinese herbal department could hope to match. They are serious now about Chinese herbal medicine in PRC, Our programs are playing Chinese herbal doctor at such a low level in comparison.

            The reason no one ever wanted to do what you are suggesting (which I started in 2002-4 when CCAOM’c core curriculum committee determined it had to work on FPD standards to meet ACAOM’s Task Force needs. I took the first edition of Physical Therapists Guide to Practice, wrote a similar practice guidelines preface and got full consensus at our college from a 17 member faculty focus group and after surveying what we actually treat in our community clinics and in our faculty’s private or group or hospital practices (from new practitioners to very senior people with 20 + years) and came up with 33 conditions ranked by % seen. That lead to adjusting our clinical training focus to teach more about pain management and other areas, and less about others rarely seen. We then established a Year II Research Methods initiative with the PhD and 2 post-doc industry research scientist teacher where her masters students vet systematic reviews and meta-analyses for the preceding year (our 17 faculty did the job of the initial list if studies to start the Acupuncture Practice Guidelines) and Michael Jabbour, new AAAOM president was one member of that group vetting studies and we offered to share our process with all AAAOM members and CCAOM colleges with NEITHER group interested after many efforts. I wrote a rigorous Independent Study Project for older grads with no research methods training (we offer it all 3 MS/.Ac years) to so the same development of practice guidelines for their own practice with 6 months of survey of what they treat etcetera which will allow them to easy track with MYMOP, SF 36 and their tools, how they are doing with then most common problems and sharing that with their own patients ans the college community. We will use that in our planned DAOM in acupuncture in 2015. We then had the class of 2011 work in concert to do practice guidelines for the TCM, KM Japanese and APM French Meridian styles we train them in, and those are in place for any senioir clinic interns to do.

            WE FIRST tried for years to get CSOMA to allow us to piggy back our work into their practice guidelines, with no luck so we linked ours to theirs as long as that was possible. Based on the Acupuncture Practice Guidelines we passed approval in 17 clinical externship sites for the eventual FPD or DAOM and got NYSED registered approval for such externships for post masters credits and many grads did these from summer 201o with most dormant now as grads are tired of hearing about a promised FPD or DAOM and want PROOF – who can blame the? And the Community Acupuncture Network critique of such FPD programs started to ring more and more true as I shared in my last blog of an hour ago.

            Anyway our college did the work, tried with CSOMA and AAAOM to develop national acupuncture practice guidelines (the very premise of doing them for herbology being impossible as all concurred). And since CAB standards are ostensibly tied to meeting state licensure standards, which since 2005 is just to be able to run a health food business within one’s LAc practice within FDA rules, and as CAB only required competence and testing of some 52 formulas rather than the 140+ of NCCAOM and ACAOM’s 4-year MS/OM standards, that looked like a fight not worth the effort.

            Since CSOMA and AAAOM and CCAOM had no interest in establishing national acupuncture practice guidelines which WOULD have yielded what you suggest and more, along the lines of what PT was clearly doing right, and following the Institute of Medicine’s clear guidelines for establishing practice guidelines in the first place, and their later clarifications that for fields where the evidence base is soft, especially in CAM fields where ‘evidence-informed’ is he best one can shoot for (included OT, PT, Osteopathic manipulations, DC, and all psychotherapies and behavioral medicine stress reduction and relaxation and mood disorders practice where evidence is hard to come by, often impossible to do RCT-level studies and so no systematic reviews or meta-analyses of any wort would be easy as SAR clarified by 2008).

            To speak of Evidence-Based Medicine in AOM is empty verbiage Steven. And no one in California or AAAOM OR CCAOM wanted any part of what promised to a rather futile effort. IN the meantime I am hoping ACAOM’s reconceptualized Masters Task Force puts the Institute of Medicine’s 5 core competencies into the revised MSAc and MSOM standards which we did for the class of 2010 in 9/3/07 thinking the FPD or DAOM in acupuncture was in our college’s future and because it made for a much better program. We shared all of this widely with CCAOM colleges and AAAOM and NOTHING came of it. We urged CCAOM colleges to voluntarily upgrade the MSAc level at least with patient centered care, team-based care, informatics, quality improvement/risk management and evidence based practice CORE IOM standards again to no avail. So we did a solid job and got high praise from a PhD RN WASC expert NYSED approved external reviewer in a 11/2012 external FPD Doctor of Acupuncture review NYSED balked at in favor of the post-grad DAOM and that is where things stand.

            I agree that CCAOM and AAAOM have dropped the ball across te board in this regard. Selfish desires to control and monopolize the field with NO efforts to be sure our grads get good jobs and solid careers was NEVER a priority for either group as CAN charged from late 2007 onwards and hence its critique of the FPD in CAB programs as a pure selfish money making scheme, that feels about right as the first programs open up (SCU’s 4,000 hour program looks solid indeed and states it will seek ACAOM approvals even though it got WASC so at least one program is doing it up right), and as the owners or leaders of those programs are at least 65+, and as I received several offers to buy annually for the last decade from such CAB programs looking into NYS and others settings outside CA, I can see retirement plans loom heavy and selling out like PCOM did to Quad Partners and many for-profit schools did to Cortiva in massage, makes it look like the field shift.

            How many other colleges, I wonder, have a 30-year plan like our college does? With NO interest in selling and no possibility of selling for 30 years???

            We know how to train in 3 styles of acupuncture including TCM. With only an introduction to herbology so hey can recommend and sell products as health foods (s in CAB schools in that state) which is also now required (45 hours) to apply to DAOM programs in primary acupuncture. It looks like our region of the country and yours are very different. I suggest you and your colleagues see the beautiful GRANDMASTER from PRC, same director as Crouching Tiger, Hidden Dragon. It is about the value afforded to a daoist view of MANY WAYS, many Do-Jos as the Japanese would frame it, with a way of having regional associations and a plurality of styles that would come together to pick a new Grandmaster, with FULL realization that he may pick a young successor who does a totally different style than his own and he picks the man who becomes Bruce Lee’s teacher (as it is a true story more or less) who does a simplified Hsing Yi style with 3 main moves which is closer to the ways Kiiko Matsumoto and I have developed our 3 decade-old styles, our do-jos. The Grandmasters style which his daughter mastered like none other was based on 64 Ba Gua moves – TOO complicated for all but the rare ones, AND she was a woman at a time when the boxer-rebellion memory called for STRONG MEN.

            Do you run a college? Do you have a style? Do you practice and what do you practice? We only invite guest faculty since at least 2O years ago who will do Grand Rounds demo treatments of community clinic patients in a clinical theater and SHOW HOW they KNOW HOW to DO acupuncture, which is the way competence-assessments of medical residents is now done since 1/1/2014. Multiple-choice exams are used by schools to test foundational knowledge. But everyone knows patients are not mutiple-choice exams – except for those trained in 1958-1987 in PRC, in textbook standardized, memorized, rigid ways that have little if anything to do with the Way of Medicine (yidao) before 1958, or after 1987 for the masses of deregulated practitioners who are free to practice lineage and family styles kept hidden for those years.

            So are you actually calling for a US American AOM licensed practice based on a 1958-1987 failed communist NEW MEDICINE OF CHINA model?

            Where all that was retained at the state mandated teaching Hospital level is Herbal Medicine that very few in this country can do?

            Curious indeed.

            A guild with no takers. But then you said numbers are deceiving. Is a guild still a guild if it has no takers except the founders, because that is just like AAAOM functioned for most of its 32 years, and the early CAB from what our CA schools told us until 1994.
            and we do have the serious recent history of a CAB member in charge of translation of the Korean exam who went to jail for 3 years for selling the answers to that community without instructions recommending against a perfect score (!). And then several years back, the alleged hacking into the entire 20+ year old NCCAOM Exam Item bank. HOW is that possible?

            Did the profession as whole verify that fact before NCCAOM truedn those questions into test prep tools, and then did a totally new external exam agency process to PROTECT the items, with a rapidly -and from my discussions with those who wrote items, TOTALLY insufficient process aimed at quantity of test items fast over any quality; and the instead of quality, there is a new model of computer generalized item selection I still have a hard time believing is even a good thing, except that it prevents against any such theft and any cheating. But does what it tests have anything to do with entry-level acupuncture competence. The answer in the state of Maryland whose regulatory board has successfully ruled against using it for 3 decades just as CAB has in that state for different reasons – as totally TCM biased in MD, against their predominant 5-Element style, and too weak in TCM for TCM-biased CAB taste.

            Sounds like the NCCAOM exam has been shown to be unsatisfactory and unnecessary to ensure safe and competent independent primary acupuncture practice in 2 states that represent about 43% of all licensed providers and since Maryland, like most other states, only requires a masters in acupuncture with NO required Chinese herbology standards. How do you propose that CAB-grounded herbology TAINTED from my point of view as a senior acupuncturist with 37 years experience doing Ling Shu style, French meridian acupuncture consistent with that of Soulie de Morant who trained and practiced in Chine from the late 1880s to 1917??? Which is also fairly consistent with French Acupuncture Association style as taught by Dr. Helms in his almost 40-year old medical acupuncture program which has more REAL acupuncture in it than any TCM programs I have ever taught at in the USA, Canada, French Canada, the UK, the Netherlands. I took on challenges from several very prominent textbook authors and NONE would do any live demo treatments of real patients, which is ALL I EVER CONSENTED TO do, Grand Rounds style whch I learned from my 5-element TAI colleagues from 1983 on, who NEVER turned t[down such a chance to show what they did and loved doing, nor did any French physician acupuncturist I ever met. Why is it that the purveyors of so much textbook verbiage who have chained our non-TCM students brains to the TCM texts/com for far too many wasted hours, are not willing to SHOW how they KNOW HOW to do what THEY wrote about doing with such certainty?

            We know the answer. They think unlike medical residency programs in this country, that patients ARE JUST LIKE multiple-choice exams and that Knowledge/Skills/Attitudes should ever come from such texts.

            If NCCAOM ever dared to hold a from scratch Blue Print Consensus meeting like we did in 1983, with ALL known styles of practice represented (which would yield real experts with 25-30 years experience now, whereas we were all new with maybe 7-8 years tops), this NCCAOM TCM biased test would NEVER fly.

            And if CAB programs refused to play, I would suggest they contact your guild and CAB and NCCAOM because the current TCM-biased NCCAOM exam has CAB-program written all over it.

            And yes, I am suggesting that acupuncture-moxibustion coupled with basic AOM bodywork (and associated cupping, guasha, external applications, electro-stim) HAS more than proven how safe and effective it is based on American public use of acupuncture itself, as practiced by licensed acupuncturists with no mandated herbal training as well as by medical doctors and dentists trained in CA, MA or NYS registered medical acupuncture programs that exceed WHO standards for such abbreviated medical training. THOSE statistics do not lie and there is so little to suggest anything but a safe and effective practice, it could be be run like in the state of Maryland without ANY external NCCAOM or other examinations. It is THAT safe and has THAT GOOD a safety record and high level patient satisfaction which counts plenty in these patient-centered care days.

            You must not read the enormous amount of critiques of the very premise of evidence-based medicine, let alone evidence based PRACTICE, or even evidence INFORMED practice. EBM is based on the same outdated, anachronistic, dualistic, reductionistic postivistic mind/body STUFF no educated scholar in AOM or medicine or behavioral medicine fields could ever tolerate.

            I for one am delighted our college will allow me, since I am formally done as president to serve as director of doctoral studies for an eventual DAOM program where these professional doctoral students will get far more savy than the scholars you have been consulting on such matters where REAL authentic American acupuncture from traditions older than TCM in PRC (remember, the New Medicine of China went from 1958-1987 only and Taiwan, the earlier Hong-Kong, Japan, Korea, the UK, and most of Europe, and most of North America NEVER went TCM at all.)

            If not for card carrying PRC communists from before 1987, WHO are you advocating for exactly???


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