NCCAOM Issues – Here’s a Real-Life Example.

Last week’s post generated lots of feedback – in the comments and elsewhere. Several people reached  out to me with stories about how their professional success was negatively impacted by NCCAOM policies or procedures.

An individual trained to be an acupuncturist wrote:

I graduated from an acupuncture school outside the country in November 2017. The NCCAOM requires that those trained outside the US must have their documents evaluated by a third party in order to apply and sit for the NCCAOM exams. As of November 2017 the NCCAOM only accepts documents evaluated by the International Consultants of Delaware (ICD).

In December 2017 I began my long ordeal with this organization. After 8 months of emails and phone calls going unanswered or minimally responded to with a form letter, I contacted NCCAOM to inform them that the company they were requiring me and others to use had appalling business practices that were preventing me from taking the NCCAOM exams, applying for a state license and starting a job that was being held for me.

Happily, I did get immediate help from the contact at NCCAOM. They intervened on my behalf and took my educational documents for their own review. However, I was then notified that I still needed ICD evaluation as the NCCAOM could not approve a “non-traditional” transcript. They also said they were not familiar with the school.

The school I attended has been graduating American students for over 15 years, and many have returned, successfully sat for the NCCAOM exams, and obtained licensure in the US. However, now it seems that the format of the provided transcripts are unacceptable; nothing has changed from the school’s perspective.  The only suggestions offered by the NCCAOM are not feasible, such as giving them the names and other personal information of past American students in order to compare what would be identical transcripts, my completing a 2 year apprenticeship (not acceptable for licensure in my state), or the school rewriting their program.

It has now been 18 months since I started this process and am no closer to being allowed to even apply for the NCCAOM exams. It seems incredible to me, and many others, that the format of transcripts, paperwork really, is all that is keeping me from fulfilling my dream. The NCCAOM has nothing to lose by allowing me to take the exams only the gain of my $1500. If I fail, then that is on me.

P.K.

 

The LAc who wants to hire P.K. wrote:

Dear NCCAOM,

As a licensed acupuncturist in practice since 1995, I have been saddened to watch the new generation of acupuncturists struggle with ballooning student loan debt and escalating practice requirements. The combination is eating away at our numbers. This acutely affects the public, our clinics, and those of us hoping to retire some day and pass our clinics on.

As an employer, I am immensely frustrated, because your practices are blocking me from hiring.

P. K. has been my clinic’s office manager, front desk staffer and clinical assistant for more than 3 1/2 years.  She is bright, committed, compassionate and skilled.  She excelled in her three years as a student at a well regarded European acupuncture school.  She comes highly recommended by the school’s president. She has been a delight and a pleasure to work with, continually exceeding my expectations, and our patients are very fond of her.

Meanwhile, I am busy, frequently over booked, and have been looking to add to my clinical staff, with no luck, for quite some time. There is a shortage of licensed acupuncturists in my area interested in a high volume, low fee, community style of practice. I offered P. a position as a community acupuncturist in early 2018, contingent on her obtaining a Massachusetts acupuncture license, and she accepted. Since then, I have been waiting, watching as she does what she can to obtain licensure, while the NCCAOM has been a roadblock in that process.

P. has spelled out in her own narrative the details of her efforts to get approved to take your exam.  When I reached out to you on this matter, we were asked to provide information on previous grads of her school who have sat for the NCCAOM exam — information that neither of us has any access to, but which no doubt, resides in your own files.

Consequently, P. has been left in limbo, with no path forward to practice in the US.  My clinic remains understaffed, and I have no ability to hire the person I’ve chosen, who is best prepared to succeed in this position.  Our state is unable to add a skilled acupuncturist to our numbers. It is all very frustrating, and sad.

A final thought — the whole idea of a licensing exam is to evaluate whether or not a graduate is prepared to enter the field.  If you trust your exam’s ability to function as it was designed, blocking graduates from taking the exam makes no sense.

D. D., Lic Acupuncturist

 

I (The Acupuncture Observer) do believe that requiring a combination of education and examination is the best way to increase the odds that a licensee will be a safe and effective practitioner. Folks with good study skills and an ability to memorize can pass exams without being able to apply what they know in practice. The NCCAOM exams can’t test whether a candidate can identify the signs used in diagnosis, for example. And, the schools have an incentive to say all of their students know enough to be practitioners.

I acknowledge that, for better or worse, the NCCAOM currently requires graduation from an ACAOM-accredited school, or an overseas equivalent. And that means they have to have some method of determining equivalence.

And, yet, is there no solution here? Is it really better for the public, or the profession, that a business and a community goes without the help it needs, while a well-educated and well-trained individual who wants to fill that need is sidelined, with an expensive education wasted?

I think the NCCAOM can and should do better. If they can’t, we need to allow another path to licensure.

 

Updates: Education, Dry Needling, Professional Organizations and Associations

Tri-State College of Acupuncture has lost accreditation and closed. Founder Mark Seem was unwilling or unable to save the program.

It’s a loss for the students, and for all practitioners and patients.

In the early development of the U.S. acupuncture profession the modern TCM lineage was primed to dominate. Mark Seem at Tri-State, and Bob Duggan and Diane Connelly at The Traditional Acupuncture Institute fought to maintain acupuncture diversity and the strong curriculum at those two schools enabled other traditions to gain a foothold.

Now Tri-State is closed and the school formerly known as The Traditional Acupuncture Institute (The Maryland University of Integrative Health) has little in common with its earlier iteration. The NCCAOM is increasingly powerful. Their TCM-focused exam controls entry to the profession. The outlook for non-TCM traditions is not good.

On December 7th the North Carolina Supreme Court affirmed the legality of the Board of Physical Therapy’s decision that dry needling falls within the scope of physical therapy in the state.

If you believe that our future success depends upon what other professions do with filiform needles, it’s bad news. It’s also bad news for the NCALB, which previously reported legal debt of $150,000. And it’s terrible news for those named in the antitrust suit Henry vs. NCALB, which was on hold awaiting this decision. The odds are not in their favor.

If you’re committed to continuing the fight with PT’s, please read the ruling.

A recent letter from the Utah Association of Acupuncture and Oriental Medicine reports that the group has no paying members and has been “permanently dissolved until further notice.”

Perhaps the association’s 2018 effort to require the NCCAOM Herb credential for new graduates who wish to practice in Utah was not a big membership motivator? If not, why did they pursue the change? At the time, the NCCAOM cited practitioner support as the driving factor in their participation.

(The NCCAOM now insists they took no position on this issue. Yet they have refused to disavow the letter they distributed showing their support.)

In the “dissolution letter” we read, “There is important work to done and we have the full support of the NCCAOM in our effort.” Who is the we if there are no paid members? What does the NCCAOM support (and why)?

Pay attention! I don’t believe the plan is to make entry into the profession easier or less expensive.

In early 2019 I’ll be writing about Modern Acupuncture, developments at the NCCAOM, and trends in the profession. Until then, I wish you all a peaceful and restful holiday season.

Safety: Dry Needling and Acupuncture

We worry about the public’s well-being.

The excellent safety record of Licensed Acupuncturists is part of our “brand” and has been a focus in the fight against the use of filiform needles by those without our extensive training.

Are we walking our talk?

At a recent professional gathering a representative of a malpractice insurance company recited a terrifying list of problems that turned into insurance claims against acupuncturists: a double pneumothorax, infections from needles manufactured in unsterile conditions, broken bones from tui na, burns from heat lamps. The message – Buy Malpractice Insurance!

On Facebook, Acupuncturists regularly look for support after a patient reports a post-treatment issue.The equivocations quickly pour in: Is that really where you needled? Are they on medication? It’s a healing reaction. Did you have them sign a waiver? There is such a thing as a spontaneous pneumothorax….

Yes. Malpractice insurance is a good idea. And sometimes post-treatment issues aren’t treatment related. But the lack of concern about the problems, and the lack of interest in how they might be avoided, calls into question our supposed devotion to public safety. Not only are we advised to never admit responsibility to our patients, we’re encouraged to never admit it to ourselves.

In 1999 The Institute of Medicine released a report, To Err is Human: Building a Safer Health System.

“The committee’s approach was to emphasize that “error” that resulted in patient harm was not a property of health care professionals’ competence, good intentions, or hard work. Rather, the safety of care—defined as “freedom from accidental injury” (p. 16)—is a property of a system of care, whether a hospital, primary care clinic, nursing home, retail pharmacy, or home care, in which specific attention is given to ensuring that well-designed processes of care prevent, recognize, and quickly recover from errors so that patients are not harmed.”

Lisa Rohleder writes –

“It’s impossible to effectively promote safety when we don’t know where WE are going wrong. An important part of developing a culture of safety is to establish, as much as possible, a compassionate, neutral, and curious attitude toward safety errors and adverse events. Nobody wants to make an error (either large or small) or have a patient suffer an adverse event — and yet anybody who practices acupuncture for long enough will experience those things. Acupuncture is a practice that involves humans on both ends of the needle, which means sometimes, unfortunately, things will go wrong.”

“Acupuncture legislation and regulation are not the same as creating a culture of safety. Training cannot ensure that the people who receive it will never play a role in an adverse event. A culture of safety requires an active, ongoing, self-reflective, cooperative process.”

An adverse event does not necessarily mean that a mistake was made. It means that something didn’t turn out as we would have liked. It can happen when a practitioner does everything right. The more we know about what happened, the more we can confront and minimize the risks involved in treatment.

But we can’t know what happened without collecting the data. And we can’t collect the data if 1) there is no mechanism to report adverse events and 2) people are afraid to share about and discuss adverse events.

Until recently, no acupuncture organizations have been interested in collecting such data. Alarmingly, in the name of acupuncture safety, one shadowy acupuncture group has created what it calls an Adverse Event Reporting system for the sole purpose of weaponizing reports of adverse events related to dry needling. The data are not anonymous. (The board of the group collecting the data is.) The goal is not to improve the safety of a practice, but to attack competitors. It makes it more difficult to develop a culture of safety.

Finally, we have the opportunity to participate in a voluntary and anonymous database for reporting adverse events in acupuncture, developed with the goal of promoting safety.

Some questions and answers from POCA’s materials about the AERD they created –

Why Should All LAcs Voluntarily Report Adverse Events and Errors?

POCA created this AERD for ourselves but it is designed to be used by anyone who provides acupuncture services and anyone who is a consumer of acupuncture services. We are hoping that many L.Acs will participate, and that other acupuncture school clinics will want to join us in collecting safety data.

Using a voluntary and anonymous AERD is a way for the acupuncture profession to encourage a culture of safety. AERDs are standard in other healthcare professions and it is notable that the acupuncture profession has not had one; that’s a problem that needs to be fixed, especially in light of acupuncturists’ practicing in integrative medical settings.

 Why Did the POCA Cooperative Create an AERD?

POCA loves data, and collecting our own safety data has been a topic of discussion in the co-op for years. Having POCA Tech as a resource to manage an Adverse Events Reporting Database, along with getting support from Dr. Suzanne Morrissey (medical anthropologist and professor of anthropology at Whitman College), allowed us to make an AERD a reality.

Why Voluntary and Anonymous?

Research suggests that it’s possible to collect better safety data, and thus do a better job of improving safety practices, when reporting adverse events and errors is voluntary and anonymous. Nonconfidential and mandatory reporting systems may discourage practitioners from disclosing adverse events and errors.

The goal is to focus on safety practices and systems, not on errors made by individuals.

Here’s the place to report adverse events.

Additionally, membership in POCA provides many excellent perks, whether you provide community acupuncture or not. I encourage you to check it out. Thank you, POCA, for establishing the AERD, and Lisa Rohleder, for starting this discussion. This post borrows heavily from her writing. Any errors, however, are mine alone.

 

 

Third Night – Lowering Standards!?

In recent conversations with colleagues I’ve heard a few exclaim “we won’t agree to lower our standards!” and “we aren’t going to go backwards on our education!”

I haven’t heard anyone suggesting that we lower our standards or go backwards, so I was baffled.

Only momentarily, though, because then I remembered -The Acupuncture Revisions Proposal from the POCA Tech BOD to “revise acupuncture education and testing standards so as to benefit current and future (1) acupuncture students, (2) acupuncture schools, (3) acupuncturists, and (4) the general public.”

They make clear that their proposed standards are based around students meeting all of the competencies required for ACAOM accreditation and preparing graduates to be safe and effective practitioners. (The proposal is concise, well-written, and worth reading. Please do.)

Unfortunately, “high standards” in this profession has come to mean number of hours spent in school. So any change in the number of hours is interpreted as a lowering of standards.

I understand how it happened. When we’ve fought for acceptance, we’ve stressed our hours of training to establish our worth. When clients mention that they got acupuncture from their Chiropractor, we talk about how much time we spent in acupuncture school compared to the D.C.’s short courses. Hours of education has been a battle cry in the dry needling fight. (Which has been mostly unpersuasive since the PT’s 1) deal in competencies, and 2) we use different rules when we count our hours and we count theirs.)

Actually, a standard is “a conspicuous object (such as a banner) formerly carried at the top of a pole and used to mark a rallying point especially in battle.” (Merriam-Webster).

So, hours has become our standard. But it’s such a meaningless standard. I’m sure I’m not the only person who’s been to three-day CEU classes that have been a complete waste of time while a one-hour class contains a transformative nugget. I’ve spoken to people who have taught at some acupuncture schools and the picture they paint is not of hour after hour of quality programming.

We’ve got a workforce that needs to grow. And levels of educational debt that are an impediment to professional success. Affording graduate school and repaying loans isn’t going to get easier.

Read the Acupuncture Revisions Proposal with an open mind.

Our banner should be more meaningful than a number.

 

 

Eight mini-Posts for Eight Nights! First Night – Acupuncturists, Weigh In!

The NCCAOM is looking for feedback on a possible Safe Compounding and Dispensing certificate program. I don’t work with herbs so I’m not considered a stakeholder, but please reply if you are eligible. My questions/concerns —

  1. Will the certificate be available to anyone or just those with an NCCAOM herbal credential? Practitioners often delegate herbal preparation to office staff, so staff might benefit the most from the training. Additionally, some excellent and well-trained practitioners aren’t able to sit the NCCAOM herbal exam due to the nature of their herbal education. Could they still obtain this certificate?
  2. Will this certificate result in restrictions on the practices of those without it? The NCCAOM has previously developed credentials promoted as optional, which have, in short order, become requirements.

There are many areas of practice in where some of us could use more knowledge and training. It’s nice to have a way to show that you’ve got some special training or skills. At the same time, we’ve got enough battles with other professions and within the profession, and too often new credentials lead to new fault lines and new tensions.

Share your thoughts with the NCCAOM if you’re a stakeholder. Let’s help them serve our needs and understand our concerns.

 

 

 

Proposal regarding Acupuncture Education

The POCA Tech Board of Directors has been studying what it takes to become an LAc and wondering whether there isn’t a better way. POCA Tech has been approved by ACAOM as a candidate for accreditation, and has graduates who are NCCAOM-credentialed, state-licensed and working in the field. The POCA Tech BOD is in a good position to know what works. Here’s what they propose –

Acupuncture Revisions Proposal

I’ve been around long enough to expect the proposal will be met with some outrage. We’ve been insisting that it is the hours of education we have that set us apart. And that almost 2000 hours of training only scratches the surface of what there is to know about Acupuncture and Asian Medicine.

I’ve also been around long enough to know that 1305 hours of training is enough to produce competent providers. That there are countless CEU programs and additional degree programs to help us deepen our knowledge. And that there is no clear evidence that our more extensive training leads to better outcomes.

People want acupuncture. We need more practitioners to meet the demand. And 100K in debt helps no one. I think the POCA Tech proposal makes a lot of sense. What do you think?

 

 

Happy AOM Day??

“Acupuncture is a safe and cost-effective treatment that could benefit so many. If only the medical establishment could see the benefits of what we do.”

That was our mantra decades ago.

So one might think, now that Acupuncture has become accepted and of increasing interest to the establishment, we’d be happy, thriving, and confident.

But that isn’t the prevailing feeling. We love our work and most of us couldn’t imagine doing anything else. And yet AOM Day 2017 finds us fearful and disheartened.

Many of us carry significant debt and are not earning enough to pay it down in a timely fashion. Many of us are limited in where and how we practice due to varying state rules. The hoped for benefits from insurance reimbursement came with significant administrative burden and limits on what will be covered. Increasingly acupuncture is being provided by non-acupuncturists. Meanwhile, the profession isn’t growing. Based on figures from Acupuncture Today, there are fewer LAcs now (24,612) than there were in November 2013 (24,707).

So it is not surprising that we aren’t hopeful. The public and the medical establishment see the value of acupuncture, but we aren’t thriving.

There are things we control that could change our trajectory.

Those of us who completed acupuncture training prior to 1990 (some of our most admired mentors and colleagues) probably got about 1000 hours of formal schooling. If you graduated in 2000 you likely had about 1725 hours of schooling, and if you completed your training after 2011 your program was at least 1905 hours.

You can see, here, how the Virginia regulations have changed over the years. The hourly requirements did not change in response to concerns about practitioner safety or skill, but to keep the regulations compatible with the ACAOM and NCCAOM requirements.

In 1988 tuition at The Traditional Acupuncture Institute (now MUIH) was $11,000 (about $23,000 in today’s dollars). When I started in 1992 it was about $18,540, ($32,616 in today’s dollars). By 2003 tuition had increased to $32,865 ($43,722 in 2017 dollars). And, if I wanted to begin at MUIH today, the program would take almost four years to complete with tuition of $75,924. For a Masters in Oriental Medicine, necessary to practice in Florida, California, and Nevada, I’d pay $99,604.

A student loan of $40,000 at 6.8% interest can be paid off in 10 years at $460/month – considered manageable with an annual salary of about 50K. A $100,000 loan will take over $1150/month and you’d need to make almost 140K/year to manage that.

So it’s not surprising that the profession isn’t growing and that acupuncturists are worried.

Sure, the NCCAOM can embark on a major public education campaign touting our training and credentials.(Well, touting their credential, actually). That’s fine. But with the downward pressure on health care spending in this country, and the impact of debt considerations on professional training, it’s going to take some damn fine PR to make a difference. (Big Pharma & Health Products spent about 245 million on lobbying in 2016.)

A far more direct way to help the profession grow, help future graduates make a living, and make Acupuncturists available to those who want acupuncture would be to address our training. If those who graduated in 1989 were safe with a 1000 hour $18,000 education, why do current students need at least 1905 hours and $75,000? Can we simplify the path and reduce the cost of becoming an Acupuncturist? (Yes, we can!)

If people want acupuncture they will find a way to get it. If we’re not there to provide it, someone else will be. We do have the power to change this, and it won’t take 245 million. In honor of AOM Day 2017, let’s agree that more Acupuncturists and less debt would be a very good thing.

 

 

We WANT to hear from Acupuncturists!

And, now, for something completely different — a group that wants “to get as accurate a picture of the acupuncture profession as possible!”

That shouldn’t be noteworthy, but it is. While some have been telling us the good of the profession depends on keeping our experiences to ourselves, POCA Tech wants “to gather data about what acupuncturists are doing in their day to day practices and how this compares to acupuncture school curriculums” and is “interested in learning about how acupuncturists feel about the cost and value of their education.”

POCA writes —

“If you practice a style of acupuncture that you feel is unrecognized by the profession as a whole, we particularly want to document it.

If you feel successful in your practice, we want to hear from you; if you feel frustrated in your practice, we want to hear from you.

If you are no longer practicing, your information is equally valuable!”

Complete the survey, which takes about twenty minutes, and you’ll get a coupon for a free 3 CEU online class.

The more we know, the more we can improve. Please, twenty minutes of your time, and in return, help us plan for a better future, and get some CEU’s.

Here’s the survey!

 

 

Continuous Improvement and Feedback

It’s difficult to make things better when you don’t know what’s wrong.

I’m glad when a client lets me know that something isn’t working. It gives me a chance to change things, or help them find something that better meets their needs. Things are better for both of us when we’re honest.

That’s why I’m having trouble moving on from a column that equates discussion about our problems with treason (“giving the other professions … the ammunition they need to diminish acupuncture”) and so many of the responses to the Gainful Employment regulations. (Here’s a selection — ACAOM gainful employment word, Acupuncture school response, and the ASA’s response.)

The cost of an acupuncture education, how that cost compares to future income, and the likelihood of that income being sufficient to pay off loans in a timely fashion while also sustaining oneself, are critical issues for the profession. Welcoming feedback from those who have “been there and done that” is necessary to guide improvement.

The Gainful Employment rules require transparency and accountability from for-profit career colleges. The regulations don’t close schools. They may, in time, keep students from receiving federal Title IV student aid to attend programs that don’t meet the accountability standards.

Although the impacted schools insist that the education they provide is a good value, they are correct to fear that, absent federal guarantees, students will have trouble coming up with enough money to attend.

Ideally, their concern would translate into concerted efforts to gather data about their graduates’ experiences and provide it to prospective students. They’d focus on what could be done to reduce expenses for students, and develop programs to ease those first few years post-graduation when they acknowledge income may be low. They’d make sure that all prospective students had an understanding of the economic realities of life as an LAc before collecting that first tuition payment.

Instead, when I read the responses from our schools and organizations, I hear, mainly, this isn’t fair, it’s not our fault, and it shouldn’t apply to us.

They argue that the responsibility is on prospective practitioners to educate themselves about the field and educational options, but also say that the data available doesn’t reflect the true picture. (And they fail to mention that before the Gainful Employment rules required it, they paid little to no attention to what happened to their students post-graduation.)

Try comparing the earnings of graduates from various programs, or finding out the percentage of graduates still in the field 5 years later. That data doesn’t exist. How will prospective students get a fair picture if practitioners who are share their struggles are told to keep quiet and say only nice things? If the concern is that some of the things being said are inaccurate or overly negative, take the opportunity to provide correct information and the other side of the story.

Working part-time, having employment structures that don’t accurately reflect all money earned as taxable income, and a lag in the time it takes to reach full earning potential are not unique to acupuncture school graduates.

Low student loan default rates aren’t evidence that all is well. Default carries significant and long-term harms and, luckily, acupuncturists are responsible enough to make payments and take advantage of options to defer or reduce payments when necessary. Of greater significance – do we earn enough to pay off our loans in a timely fashion while also supporting ourselves? Can we save for retirement and purchase disability and health insurance? Will we ever be able to buy a home, or build up a cushion in case of hard times? The overall financial health of the average graduate should be the focus of attention. The highly successful grads are the exception, not the rule.

I’m not surprised that the schools are fighting to avoid consequences for the struggles of their graduates. I am surprised that other organizations and voices are supporting their evasions.

There are more than sixty Acupuncture and Oriental Medicine Programs in the US. What’s a bigger threat to our future – that a few might close or that a significant number of graduates, burdened by debt, leave the profession before they can get established? How about the impact of student loan debt on the affordability of our services? Is that important?

Understanding and acknowledging our problems is the first step in making things better. We need more data and discussion, not less. More transparency and accountability, not less. A greater emphasis on making things better, not making excuses for why they aren’t. It’s time for us to own our challenges, not blame and deflect. Let’s get honest.

 

 

Ethical Questions

Our future requires a willingness to explore beyond our quick conclusions of what is “right” and what is “wrong.” How do we proceed when two “rights” are in conflict with each other, or when a good end might depend upon a questionable means (or vice versa)?

Providing safe, effective, and accessible treatment to everyone who wants/needs treatment while also supporting ourselves and our families requires us to face various ethical quandaries. Many ethics classes are short on teaching principles to guide ethical decision-making and are long on lists of rules like “don’t have sex with your patients.”

Marilyn Allen’s recent column on ethics demands our attention. She’s had a significant role in shaping the acupuncture profession, and she teaches ethics. She has power.

The column focused on a discussion about “gainful employment” that has since been removed from the AAAOM practitioner forum.

The forum included colleagues sharing concerns about their debt, and upset at schools that exaggerated the future acupuncture job market while glossing over the skills and financial backing needed for success.

Ms. Allen (who has given considerable funding to the AAAOM over the years) is angry that this discussion was permitted. She insists that it is in the best interest of the profession, and our future colleagues, to keep concerns to ourselves. Even a shared conversation in a practitioner forum is too risky. We “should have shown support for the schools,” she writes.

Ms. Allen proposes the Rotary’s Four-Way test in her column. It’s not my preferred guideline for ethical decision-making, but since she refers to it I’ll use it —

 

1) Is it true? Many graduates of acupuncture schools do struggle to pay off debt. Schools did use misleading data in promotional materials, leading to unrealistic career expectations. The proposed Gainful Employment regulations did raise concerns about acupuncture programs. The forum topic is no longer present to allow for a complete fact check, but my assessment is that much of the content was true.

2) Is it fair to all concerned? What do we mean by “fair.” Who is “all concerned?” And what is “it?” I could write a post on each question. When a topic is being explored by many people, in many settings, does each contribution need to reflect the views and feelings of each stakeholder? Is it unfair to share our personal experiences and opinions about a system in which we have little power and bear the consequences? Is it fair for a membership association to solicit the opinions of its members? My assessment – it was fair for the AAAOM to provide a forum and for practitioners to use it.

3) Will it build goodwill and better friendships? Humans do better when we know we are not alone. Sharing our concerns and our experiences is a way to build community and friendships, which support us in our sometimes isolated professional life. Knowing that other regulated fields share these concerns can also help build goodwill and understanding. If we feel that a friend (or, in this case, a system) is taking advantage of us, does it strengthen the friendship and build goodwill if we speak up, or stay quiet and suffer? Yes, the discussion had the potential to build friendships and goodwill. Ms. Allen’s column, by advocating denial and repression, does not.

4) Will it be beneficial to all concerned? My list of people who would benefit from the conversation, even if it escaped the private forum: current debt holders who feel alone and unheard, schools who care whether graduates are satisfied, potential students who may not have fully explored the economics of entering their dream career, and taxpayers who may not want to subsidize ineffective programs. The discussion isn’t beneficial for the schools that want to keep raking in loan money while avoiding responsibility. Should we be censored for their benefit?

Ms. Allen writes “It is sad when you read an article about the profession that contains negativity coming from inside the profession. Essentially, this is giving the other professions (those looking to treat acupuncture patients) the ammunition they need to diminish acupuncture and attain their own goals.

I say, it’s sad when those with the power to change things for the better instead advocate for a flawed status quo. It’s a danger sign when secrecy is demanded for the good of the group. The Catholic Church and the Penn State Football program are examples of the moral failure that comes with that argument.

Thank goodness we’re dealing with finances and not child abuse. Nonetheless, shutting down conversation and preaching secrecy is neither ethical nor effective. If Ms. Allen wants to uphold acupuncture as the place “where hope and healing meet” then we need to delve into our challenges, not hide them.