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.


Copyright —

© Elaine Wolf Komarow and The Acupuncture Observer, 2013-2033. Unauthorized use and/or duplication of this material without express written permission from Elaine Wolf Komarow is prohibited. Excerpts and links are encouraged, provided that full and clear credit is given with specific direction to the original content.

5 thoughts on “Who Speaks for You?

  1. Dear Elaine,
    Thank you again and again for being the call to action. I have just sent the following letter.

    Dear Mr. McKenzie,
    As a licensed acupuncturist practicing in Charlottesville, Virginia, I want to raise my voice to say that you and the ACAOM do NOT represent me, or my opinion on the issues in your letter to the Department of Education.
    The arguments are specious. The cost of acupuncture school and the subsequent debt that burdens most new practitioners is a deep disservice to the very people your letter claims these rules will be helping: minorities, low-income and the underprivileged. Making it easier to incur excessive debt doesn’t serve anyone except the institutions that educate, the institutions that certify and examine, and the institutions that loan money. In the long run this does not make acupuncture more available as a treatment modality, or as a profession.
    Cali Gaston, RN, MAc, LAc

  2. Elaine, thank you for posting this. Here’s the letter I just sent…

    I am writing to add my voice to the concerns raised by Elaine Wolf Komarow in her letter sent to you regarding ACAOM’s May 23, 2014 letter to the Department of Education regarding proposed gainful employment rules. I am a Licensed Acupuncturist and have been in practice for nine years, and I strongly object to several statements made in the letter.

    The letter claims that ACAOM, CCAOM, NCCAOM and AAAOM represent 33,000 licensed acupuncturists and students in the United States. I do not know if there is any data to support this claim, but these organizations do not represent me, and the May 23 letter does not represent my position on proposed gainful employment rules.

    I strongly disagree with the following statement: The proposed rules do not account for the valid and much-needed choice of healthcare providers to deliver care to low-income populations. Actually, I believe the opposite is true. I believe that the proposed gainful employment rules could encourage more providers to deliver care to low-income populations if the rules help control skyrocketing tuition costs. I own a community acupuncture clinic that provides close to 20,000 low-cost acupuncture treatments per year. Time and again I have had qualified job applicants turn down salaried jobs with benefits at my clinic because they wouldn’t make enough money to meet their debt repayment obligations. Many practitioners entering the acupuncture field today are graduating with close to $100,000 in student loan debt. If proposed gainful employment rules could help reduce debt loads, this would encourage more practitioners, not fewer, to serve low-income populations.

    I also strongly disagree with the following statement: The proposed rules appear to disincentive minorities and low-income students from pursuing these medical careers, thereby restricting access to healthcare and education to wealthier students. Again, the logic here is completely flawed. It’s not the rules that discourage minorities and low-income students; it’s the tuition costs. If the rules could help control tuition costs, more minorities and low-income students would be encouraged to enter the field.

    Please provide documentation of the 33,000 licensed acupuncturists and students you claim to represent. Otherwise, please retract your statement, and make it clear to the Department of Education that you represent the interests of your organizations and not individual practitioners.

    Thank you,
    Alexa Hulsey, L.Ac.

    • Great letter, Alexa. Thanks for pointing out some of the more disturbing arguments made by ACAOM. The words “self-serving” come to mind when reading through ACAOM’s arguments.

      I’m hoping to get more into the weeds in future posts.

  3. Thanks for sharing your letter. It would be great if people who are sending comments to ACAOM could post them here — or at least let us know they weighed in.

  4. Thank you for posting this Elaine. I found it rather depressing that many of the claims made in the ACAOM letter we are now discussing are disingenuous if not outright misleading. I have been in practice for thirty five years now and have often been disappointed to see that the more things change–the more they stay the same (or even worsen). I believe this is an opportunity for all of us, individually, and collectively, to take a stand against the toxic distortions and misrepresentations of fact that have been purportedly made in our name and “for our benefit” over the years. It is now abundantly clear to me that only practitioners are capable of representing their interests and all too often groups acting in our name do not have our best interests at heart. This is one of those times. Neither ACAOM, NCCAOM, CCAOM, represent our interests. That is quite clear. I will be sending the letter below to all involved this afternoon. Please feel free to use it to assist in the compositions of your own letter–in your own words might be more effective.

    Joseph Ashley Wiper MA, MSc, Dipl. Ac. (NCCAOM)
    204 Milltown Road
    Wilmington DE, 19808

    Mark S. McKenzie, LAc MsOM DiplOM
    Executive Director
    Accreditation Commission for Acupuncture and Oriental Medicine (ACAOM)
    8941 Aztec Drive
    Eden Prairie, MN 55347

    Dear Mr. McKenzie

    I have been following the Acupuncture Observer blog for several months now and recently read comments directed to the USDOE re their Comments on the Notice of Proposed Rulemaking on Gainful Employment. I would like to add my voice to the concerns raised by Ms. Komarow in her letter sent to you and published on her blog. In your letter, written in your capacity as Executive Director of ACAOM, you claim to be speaking on behalf of the Council of Colleges of Acupuncture & Oriental Medicine (CCAOM), and the National Certification Commission for Acupuncture & Oriental Medicine (NCCAOM). I do not find it difficult to believe that there may well be a consensus among these organizations since all of them derive the majority of their income from activities associated with the training, certification, and recertification of practitioners as well as the accreditation of schools and colleges of acupuncture and Oriental Medicine.

    But when you also claim to represent the membership of the AAAOM and “over 33,000 students and graduate acupuncturists in the United States” you cross a line. ACAOM most certainly does not represent my interests as a practitioner—neither does CCAOM, nor NCCAOM. Perhaps this is as it should be. All of these agencies are have different roles and responsibilities and representing, or claiming to represent, practitioners, or their interests, is not among them. Further I would like to know how you arrived at the figure of 33,000 and whether or not we could be referred to a verifiable source of this data. I am respectfully requesting that you publicly retract the claim that you are representing 33,000 acupuncture practitioners in the United States. And even if you could justify this number I would like to ask how you know that all of these practitioners are actually working. This is anecdotal I realize but I personally know of a number of acupuncturists who hold licenses but have given up the idea of ever making a living in this field many years ago. The only reason many still hold licenses is to avert the expense and inconvenience of compliance with the ever evolving requirements of relicensing should they ever change their minds.

    So please never claim to represent me in your communications with DOE, please publicly retract this claim, and please refer me to a verifiable source of your claim to represent 33,000 practitioners. And while you are at it why not consider a properly conducted survey that would allow us to determine how many licensed practitioners have actually given up on trying to make a living and what the actual incomes (from practice only) of the ones who have pressed on might actually be. We do not yet have a truly honest assessment of what the state of the profession actually is. One other thing, please explain to us, given the current state of the profession how changes in proposed rules “disincentive minorities” in light of the fact that continuation of the status quo will apparently saddle each of them with insurmountable debt.

    Yours truly,
    Joseph Ashley Wiper

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