I know, three posts in two weeks is too many posts. I need a break as much as you do.
My post last week was an open letter to the NCCAOM, so I think it’s fair to share the response from the Chair of the NCCAOM Board of Commissioners.
It was nice to meet you at the CCAOM conference. Thank you for your concern and dedication to our profession. My apologies on the delayed reply and acknowledgement of your letter to the NCCAOM Board-I did not want to respond with only a cursory acknowledgement given the energy and effort of your letter. I will share your letter with the rest of the Board of Commissioners.
That said, I do want to address some of the points you made in the letter. I hope you will not take my comments as a dismissal of your concerns – I would simply like to clear up some misunderstandings. I am not able to address all of them in this moment, but I would like the opportunity to clarify in the future. A few points:
-The CEO is not responsible for setting up recertification criteria- that process is done by the Recertification committee(again within the parameters of maintaining our certification). Continuing education is a non-negotiable. That said, it has been noted and suggested that the process be more streamlined.
-Exam content is driven by a specific process dictated by NCCA standards; it is acknowledged that the end result is an exam that weighs heavily on TCM. That is a challenge that we continue to attempt to address. We are always looking for new suggestions – within the parameters that we must maintain to keep our certification. As was mentioned, there are budgetary considerations to developing additional psychometrically valid exams as well as the challenge of having enough practitioners to determine psychometric validity and objectivity.
-States that have added herbal certification to their licensing act have initiated that either through the professional association or the state regulatory board. We have not initiated this despite some of the rumors.
-With regards to stakeholder input: whenever possible and applicable, we do seek stakeholder input. There are times where stakeholder input does not weigh in on a decision – i.e. compliance with new requirements from NCCA, exam validity requirements, ; and issues where we actively sought stakeholder input – i.e. the revision of the code of ethics, the herbal safety certificate creation, etc.
Thank you again,
Afua Bromley, L.Ac., MSOM, Dipl.Ac. NCCAOM
Chair, NCCAOM Board of Commissioners
I fear my frustration at hearing the same old talking points resulted in a brusque response.
Thank you so much for taking the time to respond. I appreciate it.
Will you be at the ASA meetings this coming weekend? I’ll be participating. If you will be attending, perhaps we’d have a chance to talk through these issues in person? In the meantime, I’ll share some thoughts.
Perhaps I shouldn’t take it so literally, but I don’t think there are any misunderstandings here. Perhaps my comments at the CCAOM meetings, and in my blog, could not thoroughly illustrate my knowledge of these issues. I’m well aware of the complexities of the NCCAOM’s situation. We may certainly have some differences of opinion about what is possible, ideal, effective, or desirable, but I don’t think any misunderstanding is the issue.
Specifically, in response to your email –
- I understand that CEO’s generally defer to committees for policy proposals. And yet it would be unusual if the CEO did not influence, to some degree, the work of the committee and decisions about how to refine, implement, or adopt committee proposals. In any case, I hope my letter, and the input of the profession as a whole, will be considered by the recertification committee. I agree that continuing education is a standard aspect of ongoing certification for health professionals and others. But the degree of involvement the NCCAOM has in approving classes, and the level of reporting it requires of Diplomates, is outside of normal practices. Requiring providers to pay you to have their courses approved raises questions about your motivations. I look forward to seeing how the committee can better align the cost to the profession of your system of approvals and tracking, with the benefit to the profession of such an onerous system.
- I’ve heard, over the years, several versions of the “We realize the TCM focus of the exam is a problem, we share your concerns, we’d love to hear your proposals, but the NCCA guidelines, and budgetary constraints, mean we aren’t going to be able to do anything about it” response. If your understanding of the NCCA requirements you have been working under leave you seeing no path forward for a non-TCM based exam, wouldn’t it be more honest to acknowledge that? I can imagine several possible solutions – dropping the lineage based portions of the exam completely and leaving it to schools to verify that aspect of a student’s training, just as it currently defers to CCAOM for CNT testing, is one. I understand from those with more expertise than I, that the JTA used by the NCCAOM has significant flaws, so developing a new JTA would be another approach. Perhaps working with a group other than the NCCA would be helpful. I don’t believe there is no solution to this problem, but if those at the NCCAOM who are most familiar with the NCCA requirements don’t see any room for change, acknowledge that. Let’s not waste the time of others by pretending you’ll consider other options.
- I was tracking the NCCAOM participation in the original DE licensure law in real time, and have media reports [An Example]from the time, showing Mr. Taromina actively pushing for the herbal requirement for all licensees. The professional association reported being persuaded by Mr. Taromina that the herbal requirement would be the best path forward. In Utah [We Have Met the Enemy], any investigation would have shown that the position of the professional association (no longer functional, I believe) was taken in response to one individual’s desire to retaliate against graduates of a particular school. The NCCAOM made no attempt to assess the position of the many Diplomates in the state who were unaffiliated with the professional association. And the NCCAOM has yet to offer any correction of the letter, written by that association and distributed by the NCCAOM, saying that the NCCAOM agreed with the proposed change. Last, but not least, the NCCAOM says it supports all Diplomates. If so, the proper participation of the NCCAOM in response to proposed regulation that would eliminate licensure for Diplomates of Acupuncture would be a vehement renunciation of such efforts and a statement that it believes that Board Certification in Acupuncture is the only Certification that should be required for licensure.
- In a recent example, the NCCAOM announcement of changes to testing procedures was met with expression of concern from stakeholders. In response, the NCCAOM made adjustments so that the changes would be less onerous to those about to graduate. Checking in with schools prior to the initial announcement would have meant those changes could have been made proactively, and schools would have been prepared for their student’s concerns. Clearly, there was some room for adjustment. There is not such a bright line between where stakeholder input is possible and applicable, and where it isn’t, as the NCCAOM repeatedly states.
Perhaps you didn’t notice the wish in my letter — “that when concerns were brought to your attention you didn’t deny or evade or misrepresent what happened.” Your reply here contains all of the denials, evasions and misrepresentations I’ve heard before. As the saying goes, don’t micturate on my leg and tell me it’s raining. Don’t tell me that someone else is making you aim this way, or that budgetary constraints are to blame. It is possible for the NCCAOM to do better. The first step is owning the problem. I’m still waiting for that.
With hopes for a better future,
Elaine Wolf Komarow, LAc, Dipl. Ac.
The good news is that it looks like I will be able to talk with NCCAOM folks this weekend. I hope that gives me some good news to share. The bad news – it means there will be another blog post.