The NCCAOM is preparing to update the Code of Ethics and Grounds for Professional Discipline and is asking for input. Informed comment requires not only a review of the documents, but also an understanding of the role of the organization.
The path to become an MD in the US is straightforward. Go to college and medical school, sit the licensing exams, complete a residency, apply to a state regulatory board, and, if desired, obtain a board certification in a specialty. (It is not necessary to be board certified to become a licensed medical doctor, and it is not possible to become an m.d. without successful completion of the licensing exams.)
When the NCCAOM (then the NCCA) was established in 1982 few states had formal licensure. Rigorous credentialing was thought necessary to gain acceptance by the medical establishment. Having a group supported by the profession to ease the regulatory burden on states regarding this new profession was also helpful. Some states weren’t (and still aren’t) at all interested in licensing acupuncturists. In those states, a formal credential to attest to an ongoing fitness to practice was appealing.
But conflict in the early days of the profession, both within the community and from the outside led to disparate paths to practice. There was disagreement about how to test and evaluate the huge knowledge base and varied traditions of the medicine, and how much power to give to any one group. Additionally, the political climate in the various jurisdictions differed greatly.
The NCCAOM‘s official role is to validate “entry-level competency in the practice of acupuncture and Oriental Medicine through professional certification.” But, the NCCAOM is really a chimera, a hybrid, due to the factors mentioned above. It has become a quasi-regulatory agency in some states, establishing practice standards and acting as a disciplinary agency. In other ways it is more like a specialty board — attesting to a particularly high level of qualification (but not exactly, since some states require NCCAOM certification for entry level practice). And, the ongoing weakness and dysfunction of the AAAOM (I’m still waiting on membership numbers, but the practitioner search function reveals the weakness) has led the NCCAOM to fill promotional needs and provide professional support, roles typically handled by professional organizations.
So, does the Code of Ethics and Grounds for Professional Discipline support the NCCAOM’s role of validating entry-level competence? Should it fill the role of a regulatory agency with control over whether or not individuals can obtain or maintain their license? Should it uphold a particularly high standard of practice, suitable for a selected subset of practitioners? Should it fulfill a PR need for the profession? These all need to be considered as we get ready to provide feedback to the NCCAOM.
The NCCAOM has requested input by September 12th. In part II of this post, coming soon, I’ll share more background information and provide my own thoughts about the documents. I look forward to hearing what you think about the documents and encourage all of us to offer input by September 12th.
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Glad I saw this post. Good question however several are actually out of question, as in they do not and cannot apply. The NCCAOM does function – as you point out – in different roles for different states. Myself and co-authors describe that role in more detail in our Acu Laws paper published in EXPLORE this past June. I can add to your post by clarifying that certification is the process of measuring highest standards, thus the Diplomate status. Certification is about the best or highest knowledge standard. This is the opposite of licensing which is about minimum standards. Minimum standards protect the public which is what regulatory boards are supposed to do. I am sure you know the difference but your readers may not. In either case the basis for evaluating possession of knowledge or skills is supposed to be based on competencies or KSAs – knowledge, skills and abilities. Acupuncture has never had KSAs. ACAOM will tell you they have KSAs as will NCCAOM. However, KSAs are supposed to come from the organization that represents the professionals. In this case the only KSAs of which I am aware proposed by a professional org are those set out by NOMAA and AAAOM. Trying to establish how many LAcs which any of the various “pro” groups can count as theirs is MOOT: open to discussion and of little practical value. When a profession is fragmented as ours no group is “winning.”
Your point that the NCCAOM does not establish entry level competency is consistent with what is the function of certification. However, if some of the states with a Practice Act want to use it as such…that is their decision. I do not know of any state where NCCAOM acts in a disciplinary role. I need to know at least one where this is the case. That would be unusual since that is the function of a state regulatory board. Of course, that is another mystery uncovered in our Acu Laws paper: only 16 states have an acupuncture board.
My point is you are asking too much in the way of feedback.
“…support the NCCAOM’s role of validating entry-level competence?” MOOT. Up to the states. I cannot imagine NCCAOM supporting their function NOT be used for validating entry level competence.
“Should it fill the role of a regulatory agency with control over whether or not individuals can obtain or maintain their license?” MOOT. States use NCCAOM because they do not want to fund their own licensing exam. It is an economic decision.
Should it uphold a particularly high standard of practice, suitable for a selected subset of practitioners? WHY NOT? WHO ELSE WILL?
Should it fulfill a PR need for the profession? PROBABLY. PREFER NCCAOM TO ANF.
If you have not seen the Acu Laws paper, Elaine, I can share with you.
Steve — Have you reviewed the code of ethics and guidelines for professional conduct? You will see that the NCCAOM does have a disciplinary procedure, which can include loss of your certification, which in some states equals loss of a license. So, in states that require active NCCAOM certification the organization serves as a de facto disciplinary board. That would be the case here in Virginia.
Likewise, in states that require NCCAOM certification, the minimum standard and highest standards have become the same thing. And when a state shows signs of stepping away from the NCCAOM requirement to set their own minimum standards you can bet the NCCAOM does a full court press to keep that from happening.
If you include Advisory Boards, the opinions of which are typically acted upon by medical boards there are far more than 16 states. I think you’ll also see that the states with the most extreme limits on practitioners are those with independent acupuncture boards. Look at DE and Nevada where the acupuncture boards/councils (corrected) have actively worked for the benefit of board members and against widening the availability of acupuncture in the state.
In any case, this is Part I — the background of the NCCAOM. Part II will be specific comments on the code and guidelines. I’m not sure I asked for any feedback here, just trying to inform.
And there is always hope, however small, that when the profession realizes the proper role for these types of groups, and can see how they function in other professions, we could actually improve our systems and develop groups that would work according to their role. That would be an improvement to continuing the the current practices.
I like the ANF and trust they work for all LAcs, rather than just their certification holders.
Elaine – By my count there are about another half dozen acu advisory committees under a Medical Board. There are just as may odd locations for acu governance including Vermont Office of Pro Reg, Rhode Island Dept Health and Maine Dept of Financial and Pro Reg. In Missouri the acu advisory comm is under the Chiro Board. In CA disciplinary cases are public. Can you produce any case in VA where the NCCAOM is the disciplinary agent or NCCAOM code is cited as the violation source? I agree that the profession is no more aware of how regulation or licensing or discipline works than it is of what are KSAs. IMO you are tilting at the wrong windmills. The regulatory boards and the accreditation body are virtually powerless. Exposing the gaps in the NCCAOM code of ethics does not advance the discussion on how this profession can acquire any power. Who makes the money in this profession? Not the licensees. The group I work with has effected change in our state. The Calif Acu Board is aggressively pursuing the schools in CA for being out of compliance. Sidebar: the schools are not the moneymakers, either. The CAB impact which is right-minded will be tiny compared to what is on the horizon for all for-profit schools (not just AOM) given the arrival of Gainful Employment Guidelines. You would elevate the discussion if you broadened the scope include regulatory roles and the goals of GE Guidelines. Respectfully yours.
Steve — The NCCAOM has recently issued a call for comments on their Code and Guidelines for Discipline. I am alerting professional acupuncturists to this call for comments and to the things they may wish to consider when crafting their response. If you are a working acupuncturist (or want to be one) the regulatory boards and accreditation bodies are the opposite of powerless. They have direct control over if or where you can practice. I’ve posted many times on the regulatory roles, and have, and will again, write about Gainful Employment. (GE will have little direct or immediate impact on acupuncturists unless they make their living teaching.) Neither of these is timely this week, and I don’t know why educating practitioners about a current issue is considered tilting at windmills at all.
I can tell you that I know of at least one case in which the NCCAOM demanded corrective actions of a practitioner far beyond what the state (not Virginia) had required. Because the individual did not wish to comply with the demands (after what had been a frustrating process with the NCCAOM marked by poor communication) their certification is on probation. This is not an issue in a state which does not require active certification but would prevent them from moving to a jurisdiction which does. And regardless of how many times this has happened, it is absolutely possible that the current system would allow for such circumstances.