J,

In your document of October 9th, distributed at the Advisory Board meeting on behalf of ASVA, 
you wrote that during the regulatory review in February the Advisory Board reaffirmed NCCAOM 
certification as the standard for obtaining and maintaining the right to practice as a licensed 
acupuncturist.  This did not, in fact, occur.

At the February Advisory Board meeting the issue of requiring ongoing NCCAOM credentialing 
was discussed.  As reflected in the minutes, Stephanie Mills and Jennifer Nieman of NCCAOM 
spoke during the public comment period in support of maintaining the NCCAOM 
requirement.  During the meeting L. A. retracted her comments from the October 2012 
meeting and restated her support of the NCCAOM credentialing process, also reflected in the 
minutes.  To my best recollection, though not reflected in the minutes, Elaine Yeatts reported 
that as the issue of NCCAOM credentialing was controversial, it would not be suitable as part of 
the fast track regulatory review.  You will see in the minutes that the Advisory Board did not take 
any vote or take any formal position on the NCCAOM credentialing process.  (And, even if the 
Advisory Board had done so, it would in no way preclude addressing the issue again. There are 
few issues that have not been discussed repeatedly during my time on the Board.)

As an ASVA member, I am concerned that ASVA took such a strong position in support of the 
NCCAOM credential without having any information about any proposed alternatives.  Why did 
ASVA assume that an alternate path would lower standards? Is there any evidence that there 
has been harm to the profession or the public in states with alternate paths to licensure?  Last, 
but certainly not least, has ASVA made any attempt to poll the membership regarding their 
satisfaction with the NCCAOM process or their interest in any alternatives?

I do not have any agenda here beyond exploring whether what has served us well in the past is 
continuing to meet our needs in the present. I do not understand why ASVA is against even 
asking the question, why they are so sure they know the answer, and why they aren’t more 
interested in what their membership thinks about these issues.

In deep gratitude for your service,

Elaine