September 30th is the deadline to submit feedback on the NCCAOM’s proposed(?) policy changes. These changes will impact the profession and may impact you. Don’t be taken by surprise and don’t let the profession change without your input. Weigh in! (Why the question mark after the word proposed? Because according to the latest NCCAOM spotlight, the criminal background check is already in effect.)
There are Four Proposed(?) Policy Changes. As you prepare your feedback you will benefit from reading the NCCAOM’s Summer Newsletter for information on the NCCAOM’s role in the profession (which I will write more about soon) and for details of the proposed(?) criminal background check policy.
Here is my input to the NCCAOM (my email bounced back, so I’m sending via snail mail) —
As an NCCAOM Diplomate in Acupuncture, a member of the Virginia Advisory Board on Acupuncture, and a past board member of the Acupuncture Society of Virginia and the AAAOM, I share the following input on your proposed policy changes (which reflect my personal views and not the opinion of any board or organization)….
1) The public and the profession would benefit from requiring a reasonable degree of English proficiency of NCCAOM Diplomates. This goal is best met by requiring an intermediate score on the TOEFL or by other documentation of proficiency. The NCCAOM should continue to offer the credentialing exams in other languages. Many experts in this medicine were educated and trained in foreign languages. Many great scholarly works are not available in English and much is lost in translation. Continuing foreign language testing, while requiring documentation of English proficiency would ensure that NCCAOM Diplomates can communicate effectively with regulatory boards and the public, while also allowing the study of the medicine in the language which best serves the practitioner.
(Since writing this I realized that all of the language requirements fall outside the NCCAOM’s mission of determining competency. Language requirements should be left to the states.)
2) Based on the Summer NCCAOM News, input regarding criminal background checks for applicants is being requested after the policy change has been implemented. That is unfortunate. Reporting that the “appropriate” staff will review each case is not helpful. Who is the staff and what is their training? Is this policy change in response to specific failings of the current credentialing and licensing process, or is it a preemptive jump on the bandwagon? In the absence of evidence that harm has occurred that would have been avoided had the policy been in place it is unnecessarily invasive and potentially discriminatory and should not be implemented.
3) The PDA Provider Categories policy changes, especially the changes that seem to have been already established for 2015, will be detrimental to the profession and the public. While many professions trust licensees to obtain CEU’s useful to the needs of the practitioner, the NCCAOM’s increasingly restrictive policies seem designed to benefit only the coffers of the NCCAOM. I have not found NCCAOM PDA providers to offer a higher caliber of class or to provide the range of classes that would be most useful to my practice. I resent the degree of control the NCCAOM has over my continuing education through these changes and the hidden “tax” you will receive from every PDA point I earn.
These proposed changes contribute to my increasingly strong opinion that states should move away from requiring ongoing Diplomate status. (Since writing this I realized that because these policy changes impact who can sit the exams, getting away from the NCCAOM ongoing credentialing won’t address the issue. Until the NCCAOM ceases the standard inflation that has begun to feel like a shakedown, I’ll support states developing an alternate path to licensure that doesn’t depend upon the NCCAOM.) While I see the benefit in establishing a minimal level of education through the NCCAOM exams, your proposed policy changes work against the diversity that is an important part of Asian Medicine. Tightening the stranglehold on acupuncturists benefits neither the profession nor the public as increasing numbers seek our services.
Elaine Wolf Komarow, LAc, NCCAOM 005020
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