Who Speaks for You?

ACAOM’s letter to the Department of Education regarding the proposed gainful employment rules begins —

On behalf of the Commissioners of the Accreditation Commission for Acupuncture & Oriental Medicine (ACAOM), and in partnership with the Council of Colleges of Acupuncture & Oriental Medicine (CCAOM), the National Certification Commission for Acupuncture & Oriental Medicine (NCCAOM) and the American Association of Acupuncture & Oriental Medicine (AAAOM), we write to offer comments…. Collectively, we represent over 33,000 students and graduate acupuncturists in the United States, and 56 colleges of Acupuncture & Oriental Medicine.

Are there 33,000 students and graduate acupuncturists? Where did they get that number? Do they represent me? Reading the rest of the ACAOM gainful employment letter confirmed it – their letter doesn’t reflect my position on the proposed rules, or on the state of the profession.

ACAOM‘s existence depends on the schools and a steady flow of students, CCAOM represents the schools, and the NCCAOM‘s income depends primarily upon new graduates taking credentialing exams.  Once these groups get their money the future of acupuncture school grads is of little consequence to them.

Of course they would make the case for maintaining the status quo, but they should not be telling the DOE that they represent me.

I’ve just sent this email to the ED of ACAOM (mark.mckenzie@acaom.org) with CC’s to the leaders of NCCAOM, CCAOM, and AAAOM (kwardcook@thenccaom.org; executivedirector@ccaom.comcastbiz.net; DonLeelac@gmail.com), and to ashley.higgins@ed.gov (of the DOE) and bduran@mpamedia.com (of Acupuncture Today) —

 

ACAOM’s May 23rd letter to the DOE regarding the proposed gainful employment rules includes this phrase —

“Collectively, we represent over 33,000 students and graduate acupuncturists in the United States.”

Neither ACAOM nor any of the other organizations mentioned represents me.

The only organization listed that even pretends to serve graduate acupuncturists is the AAAOM. Their professional and student membership is a thousand or so, optimistically, and they were not in partnership with you for this letter.

I am not surprised that organizations that profit off students and new graduates would write a self-serving letter avoiding responsibility for the number of acupuncturists struggling to pay off huge educational debt.

I am not even surprised that you would claim to represent me. But I am angry that you did so.

Unless you can provide documentation that you do represent 33,000 students and graduate acupuncturists please retract your statement to the Department of Education and make clear that you are speaking on behalf of your organization, which depends on schools and a steady flow of students to survive.

Speaking for myself,

Elaine Wolf Komarow, LAc

In coming weeks I’ll explore more of the distortions and spin in the ACAOM letter. But for now I hope you agree that standing by while these organizations claim to speak for us is a mistake.

Borrow my text or use your own, but, let ACAOM and the other alphabets know they don’t represent you — and make sure the Department of Education knows that too.

Please support discrimination?!?

Another entry in our Hypocrites with Double Standards (HWDS) files?

I’ve been reading about the importance of Section 2706 of the Affordable Care Act for our profession. It wouldn’t be right for insurance companies to cover acupuncture only if performed by an MD, right? The concerns within our community, according to the press, are that the section might be undermined by the actions of the AMA (this makes us angry!) or not strongly enforced.

Okay, non-discrimination good.

Wait a second — AOMSM, the Massachusetts acupuncture association, is pushing legislation that discriminates.  Section 7 of S1107 and H2021 reads “The use of needles on trigger points, Ashi points, and/or for intramuscular needling for the treatment of myofascial pain will be considered the practice of acupuncture” (does it matter what type of needles?) and Section 8 reads “Only licensed acupuncturists or medical doctors shall be reimbursed for acupuncture services.” Is anyone surprised that “political agents for PTs in MA have taken measures to prevent “An Act Relative to the Practice of Acupuncture” from advancing”?

So — discrimination is good if it works in my favor, bad if it works against me?  How does this reflect on our profession and the future of integrated health? Not well, in my opinion.  What do you think?

Dry Needling, Herbs, and Scope — How to Regulate a Profession

A regulatory Board is contacted.  Your licensees are doing X, that isn’t (or, is that?) in your scope.

Ask a PT Board about Dry Needling and the answer usually goes something like this — We trust our licensees. Many learn this technique and it helps their clients. We find room in our regulation to include this in our scope.  We have a few concerns and suggest that those who want to utilize this technique have some additional training and take additional precautions. Our existing system for addressing unsafe practice is sufficient to address risk to the public.

Ask an Acupuncture Board or organization about herbs and the answer usually goes like this. We are being threatened again!  We’d better legislate, and fast! Help! Thanks NCCAOM and schools. We are so grateful for your efforts to ensure that any acupuncturist who wants to utilize this dangerous aspect of our medicine add your $20,000 education and your formal $800.00 seal of approval to their already extensive education and credentials. In fact, in the name of raising standards we should require that from all LAcs. It might prevent some of our most qualified practitioners from practice, but, hey, it is a step toward getting the respect we deserve.

Is something wrong with this picture?

It’s a radical idea, but how about we respect ourselves. Let’s recognize the safety of our medicine and the depth of our education.  Let’s trust our colleagues’ professional judgement and open doors rather than close them and let’s stop deferring to those who profit from our love of this medicine.

For additional reading, check out an example.  In this case, I agree with Dr. Morris when he wrote,

To avoid conflicts of interest, no individual who stands to profit from seminars should determine competencies and educational standards, nor should they testify in legislature on behalf of the common good.

(Of course, he was talking about the PT’s when he wrote it, so maybe in this case he doesn’t agree with himself.)

You have until Monday, 9/30, to comment on the NCCAOM’s “proposals.” Does the current CEU arrangement put the public at risk? Are the states incapable of effective regulation?

One more thing — during the great FPD debate, many expressed concern that once the degree was available the NCCAOM could, by fiat, require it for entry level practice. We were assured that would be impossible. Informed by history, it seems very possible indeed.

Who is a Word-Trickster?

Will Morris, in Acupuncture Today, writes — ” ‘Word-tricksters’ – as I like to call them – change language in order to gain personal advantage.”

I haven’t received much input on my questions about nomenclature, but in my conversations with practitioners around the country I haven’t found any agreement or clarity about where acupuncture begins or ends.

I do have a question for Dr. Morris and the others who have been so insistent that the other professions should use “acupuncture” rather than “dry needling” or any other term. Would folks be happy with an outcome in which all professions agreed to use the term acupuncture for anything that used a filiform needle, but in which the LAc community still had no say in the regulations, education requirements, and scope for those professions?

The acupuncture community would not see that as a win. I believe that the people arguing for the global use of the term acupuncture are doing so because they think it will give them control over the procedure — that is, to gain personal advantage.  Doesn’t that make us the Word Tricksters?

In the meantime, based on youtube videos and discussions on various list serves, my colleagues are very interested in being able to draw distinctions between how they use needles and how the PT’s and others use needles.  Wouldn’t insisting on the use of the term “Dry Needling” help?