Follow Up to POCA’s Job Task Analysis

Our goal with the JTA was not just to accumulate, crunch, and share data — though we love doing those things — it was to look at how the data we gathered could contribute to positive change. Please see below an excerpt from a position paper that we hope to distribute widely. You can find the entire paper here. Or if you're not a POCA member, you can write to info@pocatech and we'll gladly send you a pdf.

Acupuncture Education and Examination Revisions Proposal

Objective : 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.

Background : POCA (the People’s Organization of Community Acupuncture) has been in the
process of completing the requirements necessary for the accreditation of POCA Tech, an
acupuncture school created in 2014. The process included an examination of existing standards
with respect to acupuncture academic curricula, educational requirements, testing standards
and competencies, current practices among practicing acupuncture professionals, as well as a
Job Task Analysis conducted in July 2017. Our synthesis of this information led us to offer this
proposal as a way to revise these interrelated components in a way that would provide a
sustainable future for acupuncture students, acupuncture schools, acupuncturists as a
profession, and the general public.

Overview of Observed Problems and Obstacles in Current System:
● High student-debt loads are incurred in obtaining acupuncture education and are
continuing to rise
● Gainful employment standards demonstrating discrepancy between cost of acupuncture
education versus amounts earned as acupuncturists
● Prevalence of pain, addiction, and PTSD in current society, with limited number of safe
and accessible modalities to treat
● Limited number of acupuncture schools, with trend of schools closing down and
● Insufficient number of practicing acupuncturists to meet demand
● Acupuncture clinics unable to fill vacancies for acupuncturists nationwide
● Acupuncturists unable to earn what they need to pay back large student loan debts
● Graduates unprepared for real-world practice

Overview of Proposed Path Forward
If we change educational requirements and revise the licensing test to focus on safety and
● acupuncture schools can reduce bloated curricula, such that
● students will incur lower debt in order to obtain master’s degrees and licensure, and thus
● with barriers to entry lowered, more students will attend acupuncture school, such that
● acupuncture schools can train more future acupuncturists, and
● these additional acupuncturists can help to address public health needs and ensure the
continuation of the practice of acupuncture in the United States

Accordingly, we recommend the following revisions to the current system:
A. Reduce number of educational hours needed for Master’s Degree/Master’s level certificate
● Most master’s programs are approximately 1200 hours (one to two years); an
acupuncture master’s degree is a minimum of 1900 hours (three to four years).
This increase in hours requires additional student loan debt and time out of the
workforce (meaning even more student loan debt for living expenses), without
any demonstrated benefit for acupuncturists or the public.
B. Revise the NCCAOM licensing examination to be one that is based on safety and ethics
● Practicing acupuncturists employ numerous types of acupuncture. No one type of
acupuncture has been proven to be more clinically effective than any other.
Without such evidence, it is arbitrary to require all acupuncture schools to teach
TCM (Traditional Chinese Medicine) and to require all acupuncture students to
learn TCM for the licensing examination. Further, there is no evidence that TCM
acupuncture is safer than any other approach.
● ACAOM’s new standards for Master’s-level competencies no longer require
acupuncture schools to teach TCM, and acupuncture credentialing standards
should keep pace with the current educational standards.
● Requiring arbitrary and extensive testing serves as another barrier, alongside the
high cost of education, to entry into the profession.
● The mission of NCCAOM is to focus on public safety, not theory. The licensing
test should reflect NCCAOM’s mission and should ensure that graduates know
how to safely and ethically treat their patients…

In summary, we recommend that (1) the number of educational hours needed for Master’s
Degree/Master’s level certificate be reduced to 1350, down from 1905 hours, and (2) the
NCCAOM licensing examination be revised so that it is based on safety and ethics, and no
longer focuses on non-universal acupuncture theories such as TCM. Both of these changes will
help the long-term stability of the acupuncture in the United States, in terms of attracting new
acupuncturists who will have manageable student-debt loads, reducing barriers to entry into the
profession for the benefit of patients who need access to acupuncture, and better serving the
safety and best interests of both acupuncturists and the general public.

This proposal is submitted on behalf of the POCA Tech Board of Directors. It was authored by
Sarah Evans, L.Ac; Michelle Rivers, L.Ac.; Christopher Rogers, L.Ac.; Lisa Rohleder, L.Ac.; and
Jacquelyn Rogers, J.D.

Author: lisafer

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  1. Thank you. Thank you to everyone who created the survey, compiled the data (still), and wrote the position paper.

    I wish I could be a fly on the wall when the NCCAOM read this. 5 tests, people. How many of us had to sit for 5 tests. When I started acu school, the senior students sat for 2 exams. That’s it. And then I sat for 5 tests because I was told that herbs will be required at some point so I should stay ahead of the game. I hardly practice herbs.

  2. We have formally submitted the paper to ACAOM and asked them to review their Standards with respect to program hours for the Master’s degree/Master’s level. As far as I know, that’s the only route for appeal to change educational hours and it will require a similar process of review and public comment that the FPD did. Reference:

    Quick question: John, did you also go through this process with ACAOM of formally asking them to change the Standards to lower educational hours? If so, what happened?

    With NCCAOM, it’s not clear how to appeal to make changes, so we’ve submitted the paper to them directly and asked them for guidance in how we would formally request changes to the test.

    Please share with us whatever action steps you took in the past and how they worked out, we’d love to learn anything we can.

  3. While the ideas here are good, I feel that they gloss over some stuff.

    Western Medical School is 3-4 years (pre-specialty decided by residency in next step training ) + 1-4 years residency length determined by specialty – dermatology 1 year – yes!

    Acupuncture schools teach Western Medicine (basic), and East Asian Medicine (acupuncture, herbal medicine, bodywork, and qi work (tai chi or Qi gong). An NO full time residency as in regular medical programs so we truncated it into a 700 hour ‘internship’ as part of the 3-4 year Acupuncture program.

    This is why Acupuncture education is so pricy, you just cannot do all that even in 4 years so that is why the programs are so very, very intensive making it difficult to work & go to school.

    Basic Western Medicine & Dx MUST be taught as in at least 1 state, California, Acupuncturists are primary medical care physicians so must be able to dx accurately and refer out when necessary.

    I can see an argument that we should divide up East Asian Medicine into units so that folks can go ‘a la carte’, learning only Acupuncture, only Herbal Medicine, only bodywork, etc….That could really make education less expensive, but would create another issue of confusion – what level East Asian Doc are you sort of thing, and then segmented licensing.

    Until we as a profession work all this out, I think we are stuck with having to learn the entire medicine.

    The good news is that some hospitals and VA are hiring acupuncturist and I do think this trend will grow. And then there is the ‘Advance Acupuncture’ company trying out a sort-of community acupuncture spa-like thingie too.

    It’s still the wild, wild west here folks.

    Just my thoughts.

  4. Hi Allyndreth,

    thanks for bringing up the “primary care” issue. That gets into a discussion of the new ACAOM competencies which needs its own separate post. It’s worth noting briefly, though, that there is a lot of glossing over happening with those words.

    According to, a primary care provider is “A physician (M.D. – Medical Doctor or D.O. – Doctor of Osteopathic Medicine), nurse practitioner, clinical nurse specialist or physician assistant, as allowed under state law, who provides, coordinates or helps a patient access a range of health care services.”

    In insurance parlance, it’s a physician who is chosen by or assigned to a patient and both provides primary care and acts as a gatekeeper to control access to other medical services.

    Contrast that to the description on this page of history about the California Acupuncture Board

    1978, AB 1291 (Torres) essentially established acupuncturists as “primary health care providers” (B&P Code, section 4926) by eliminating the requirement for “prior diagnosis or referral” by a doctor, dentist, podiatrist or chiropractor …Legislation that passed in 1988, (Chapter 1496) included acupuncturists as “physicians” only in the Workers’ Compensation system for purposes of treating injured workers.

    The language “primary healthcare providers” in the California legislation was very narrowly intended to mean that a member of the public was allowed to see an acupuncturist without first seeing another kind of provider, and the “physician” term only applies to the Workers Comp system.

    In any case, the hours and training that acupuncturists now have in no way prepare them to be the equivalent of, say, a physician’s assistant or a nurse practitioner. That would take a lot more than didactic hours of biomedicine classes in an acupuncture school. Another post coming soon with details about competencies —


  5. Thanks for clarifying CA Primary Care, yet we do still need basic Western Medicine Dx & red flags to appropriately refer to both MD’s or ER. So we cannot axe that part of our training although it does not need to be as ‘in-depth’ as other ancillary care practitioners (Respiratory Care, Nursing, etc).

    As for the other bits – perhaps having basic Acupuncture only to benefit community acupuncture clinics who do not practice herbal medicine could be a way to decrease the costs of our schooling. Or more schools like POCA Tech with a Licensed Acupuncture Technician vs. Licensed Acupuncturist or Licensed East Asian Medical Practitioner to differentiate someone who learned more than acupuncture only.

    It is a very worthwhile discussion.

  6. Allyndreth —

    Even back in the 1300 hours days we got plenty of red flags and western diagnostic training. That would always be included in core safety lessons, so no one is talking about getting rid of that.

    Many practitioners, working in all sorts of clinics, don’t use herbs, and many states don’t have specific herbal training requirements for LAcs (which makes sense given all other professionals can utilize herbs without additional training.)

    I don’t understand why we’d add more complication to the field by adding technicians. Many of our most experienced practitioners received 1300 hours (or less) of training when they were in school and went off to become successful LAcs. Why can’t we go back to those lower requirements and, as has always been the case, people will then use required CEU’s to deepen their study in those areas of particular interest?

  7. hi ewelfk,

    I was mentioning adding ‘technicians’ in the interest of ‘going back’ to teaching acupuncture only as a way of decreasing the length of time in a Masters Program and facilitating lowering costs. The original post pointed out that many graduate schools are only 1-2 years long. however, most of our programs are TCM oriented which includes learning East Asian Medicine and all those things mentioned above since that is TCM.
    To decrease hours, one has to cut out Something. One might be able to teach acupuncture only in 1 year, and certainly one can in 2, if that is all one is teaching.
    Yes, many acupuncturists do not prescribe medicinals either because they were not trained in herbalism, or by lack of desire. Hence, a good spot to delete to create a truncated program. Ditto body work, qi gong, tai qi, etc. etc.
    But, if someone only learns acupuncture in 1-2 years, there does need to be a way to differentiate between acupuncture only vs. East Asian Medicine which can be one, two, three, or 4 modality trainings. That is all. But it does add confusion for the public. However, states like Oregon include the ability to prescribe herbs in our ‘Acupuncture License’, so that would also need to be changed. Yes, one can learn in ‘continuing education’ but would that be the best way to go for the ‘basic herbal’ learning. As an herbalist, I really don’t think so. Best to get at least a modicum of training if it will be included in the license.
    We could decide to require acupuncture training only and then all other specialties do an apprenticeship or internship the way Medical Doctors are trained. If they want to be surgeons, they have to get into a Surgical Residency Program, if they want to be Dermatologists, they must get accepted into an Dermatology internship. No MD can start practicing medicine right out of graduate school. They MUST do a residency program of some sort. The shortest ones for dermatology is 1 year, longest I believe are surgical.
    We could make that the same for us if we wanted – keeping our education as low as possible for everyone, and only increasing by desired specialty. Herbalists would have to enter a separate Herbal Residency Program etc. etc.
    This is totally worthy of consideration as Acupuncture is pretty simple really, and could be taught rather inexpensively. I totally agree with Lisa that we don’t NEED to teach everyone TCM.

  8. I’m going to preface this comment with the fact that I went through acupuncture school (no longer practicing), and my wife is a Physician Assistant. While acu school was challenging it was nowhere near as intense as my wife’s trip through PA school. Its funny to note that her student loan total was similar (a bit higher) to the median student loan amount reported on the JTA($113,000).

    There is a fundamental difference between the tools at the disposal of an acupuncturist and that of the Western Medical Primary Care Provider (MD, DO, PA, NP).

    Acupuncture needles are pretty safe and just about anyone can quickly learn how to use them safely (Don’t stick them into peoples’ lungs or blood vessels). Herbs are a little more powerful.

    The main tools of Western Medicine, pharmaceuticals and surgical procedures can damage or kill people in a hurry. MD’s and DO’s have far more responsibility and potential for causing harm than acupuncturists do.

    However, some Western Medical Primary Care Providers do start practicing right out of school. PA’s (NP’s as well I believe) are out in the thick of it as soon as they have a license and a DEA number. PA’s have supervising physician, but it is not a residency and they on their own. The learning curve is steep. Most PA programs are just 2 years – one year of didactic education, one year of clinical rotations. Mid-level providers are the work horses of the modern medical practice and lots of quality care is provided by them. No need for 4 years + 3-7 years of residency, because you just need to be safe. The rest you can learn on the job or through ongoing CEUs

    Justifying padding out the acupuncture education to 4 years because some western medical providers go to school longer fails to take into account that the level of responsibly is no where near the same. Its just not an apples to apples comparison.

  9. Wadelp,

    I totally agree, acu needles are pretty safe and one can learn to use them effectively very inexpensively and safely.

    Herbs however, are not just a little more powerful, they can really screw someone up if not dx correctly and dosed correctly. You can even kill someone with the wrong formula, wrong dx, herb/drug interactions, etc. Really, it’s true.

    Yes, PAs & NPs are out ‘in the thick of it’ right out of school, but remember, they have a BS in Nursing or other ancillary degree such as RCP or other. (I was considering PA school but realized after my son was saved by acu & herbal medicine, that if I was considering being a doctor, I could choose whatever kind of doctor I wanted to be. Of course, East Asian Medicine won because it was so much more effective & I could not figure out why all our kids in the PICU were not on herbal formulas since they could get kid better 10x faster than Western Meds once off the ventilator.)

    Plus, folks eligible for PA & NP training have years of experience working in whichever specialty they were in so stands in for a lot of residency hours. which is a far cry from some of my colleagues in TCM school who were computer programers prior to enrolling, so ALL their medical experience was purely from acupuncture school and no prior medical experience required. Huge difference. So that extra year of Western Medical education is super important. Yes, PA & NP study for 2 years & 1 year residency, but they are counting on prior years of working in Western Medicine to make up the difference.

    Family Practice or other Primary Care Physicians (except PA or NP) must complete 1 year of residency after 4 year Medical School to get a license to practice in most states & to get reimbursed by 3rd party payers or admit patients to hospitals. Some states allow practice without residency, but not many, and not many such physicians can survive without being able to get insurance reimbursement.

    So please understand me, I am not about ‘padding’ acupuncture education to 4 years just because Western Medical providers go to school longer. I am suggesting that if one is learning not JUST acupuncture, but also herbal medicine, qi gong, tai qi, bodywork, and diet therapy, one CANNOT squish that into 1-2 years of graduate school and NO residency. But acupuncture alone CAN be. It is totally worth the discussion!

    As I see it, a large part of the problem here is that we have called the profession ‘Acupuncture’, rather like in England where, when you go to the doctor’s for a routine check up, you are going to ‘the surgery’. Barber/Surgeons were the medical providers and Surgery stuck. We call East Asian Medicine ‘Acupuncuture’ but that is only one small part of East Asian Medicine. We could have just as easily called it Chinese Herbalism…..

    So, the reason school is so long in TCM schools, is that they are teaching all of TCM, which includes all aspects of Chinese or East Asian Medicine, not just acupuncture. To make school cheaper, I really think it is worth while to offer acupuncture only and then it could naturally be shorter and less expensive. But since our licenses are currently defined differently state to state, we will have to clean up what we call folks for ease of the public knowing what their practitioner knows and what they don’t.

    I actually feel that if someone is truly going to practice East Asian Medicine and be a primary care practitioner, which I would love to see, we need more residencies after we graduate because it took me YEARS and tons MORE herbal education & mentorship to become a reliable and safe Herbalist. The acupuncture part was pretty easy and straightforward.

    Others may have other experiences and would love to hear other points of view too.

  10. This seems like a good time to revisit Elaine’s post about herbal regulations for acupuncturists:

    Herbs aren’t controlled substances, even if maybe some of them should be. You could say the same for many supplements. And qi gong, tai qi, diet therapy — you also don’t need a license to practice those. The acupuncture profession seems to be structured to make itself as economically un-competitive as possible, what’s up with that???

  11. The thing is that acupuncturists are not primary care providers.

    No additional amount of Tai Chi, or Qi Gong, or herbs study is going to make an acupuncturist a primary care provider or a safer acupuncturist. Additionally these practices and many other “TCM” modalities are totally unregulated. Want to use qi gong to heal someone? Go for it. The state says it’s legal and requires no license. Trying to say “I’m the same as a western primary care provider because I did a 1000 -2000 hours of study in Tai Chi/ Qi Gong/ Herbs” is just false. Trying to say that an acupuncturist is the same as western medical provider because that person completed a masters level OM program is also false. Using that line of reasoning to sell acupuncture education to potential acupuncture students is fraudulent and icky.

    Yes we need a baseline medical knowledge. Acupuncturists need to be able to recognize when to send a patient to a primary care provider. This is a baseline safety issue.

    Acupuncturists need to be safe. It is a relatively safe practice and safe practitioners (with all the bio med they would ever need to be safe and refer out appropriately) can be taught in a year.

    Entry level into the profession should be “a baseline of knowledge and safety”. Nothing that I learned in Tai Chi class helped me be a safer acupuncturist in the 10 years that I was one. I never used the bulk of my herbal education in that time either. Students should be able to elect to seek out knowledge of these additional modalities; schools and certifying agencies shouldn’t force it on them. Especially when the knowledge is not required for licensure.

    Don’t want to use herbs in your future practice? You shouldn’t need to pay to learn about them. If you do want to, thats fine too go get some education. It shouldn’t be required to graduate/ sit for the boards. It should be available if you want it.

    Students don’t need to force a ton of extraneous knowledge and resultant debt forced upon them under the guise of making them “safe” or “doctors”. Acupuncture IS safe, and acupuncturists AREN’T doctors(and don’t need to be).

  12. Oh dear,

    We seem to have drifted into confusion territory here. I must assume that I have been very unclear in my posts. I thought we were discussing how to make Acupuncture education more affordable and everything you have said above Walden & Lisa repeat this as if what I was saying was different somehow. Please help me understand where we are in disagreement.

    My suggestion was to delete whole portions of TCM education, paring it down to Acupuncture only as a way to make schooling more affordable. And yes, we all know that acupuncture can be quite safe and effective in well trained hands.

    Regarding East Asian Medicine Practitioners not being ‘doctors’, it depends on one’s definition of doctor doesn’t it? In China TCM is thoroughly integrated into the medical system and before Western Medicine was introduced to Asia, East Asian Medicine was the only medical system.

    The reason I decided to become an East Asian Medicine Practitioner as opposed to becoming a PA, was my disgust at how Western Medicine fails most patients. It is really only cures using 2 modalities: anti-biotics which cures infections, and surgery which cures traumatic damage by making physical repairs or restructuring internal issues that are beyond ‘natural healing’. I first realized this when my son recovered from status-asthmatics 10x faster than my other Respiratory patients using an East Asian Medicine Formula prescribed by a Korean Acupuncturist (who did not do acupuncture, he was an herbalist only). So, I started using Acupuncture & East Asian Medicine as our familie’s 1st line treatment for everything. Got rid of my digestive parasites, cured hypothyroidism, and cervical cancer, & finally, the HPV infestation causing the cancer. All without need for drugs or Western Medicine except testing modalities.

    Now, I know that acupuncture alone did not cure my parasites, cervical cancer, or HPV because I was getting regular acupuncture for years and was not taking herbal medicine except for when having a cold or flu because my herbalist had moved back to Korea and my new acupuncturist was extremely weak on herbs except for colds/flus.

    However, after meeting my herbal mentor while a student at OCOM & received my dx at that time, I was cancer free 3 months after starting the correct herbal formula. My Western MD was super excited and wanted to know all about our formulas and has referred patients with cancer ever since.

    So yes, I do think that we are equal to Western Doctors, but not the same. Both modalities have their strengths & weaknesses and should be used together for best advantage of each. Someday we will be integrated into ‘general medicine’ as I hope chiropractic and massage will be too. It is silly that we only consider Western Medicine as medicine.

    Can we make Acupuncture training less expensive? Absolutely, Lisa, you have made a great start with POCA Tech. As you have suggested, we need to do even better.

    In fact, our whole medical model sucks, is unjust, and throws good money after bad. I went to OCOM to learn East Asian Medicine and be able to offer it at affordable rates to everyone. Despite my ‘acupuncture mortgage’, I am still able to do that – even affordable herbal medicine. Will I die with my loans – for sure. Hopefully my son won’t have to pay them off. Should we make our profession affordable? Yes! Should we make Medical School affordable too? Yes! Should we overhaul our entire way of paying for medicine – you bet! But for us, we can start where we are.

  13. Allyndreth,

    I think this is a good discussion, and I think both Wade and I are responding to your initial statement that the position paper “glosses over” some points. If I understood you correctly, you said that the points we were glossing over had to do with acupuncturists being primary care providers (clarified) and TCM being “so much more than acupuncture” (more about that in another post; also Wade’s points are very relevant — the “more” of TCM is largely stuff you don’t need a license to do). You also wrote that until we as a profession work this out, everybody has to go to school to learn everything that TCM schools think they should learn, which they happen to define as “the entire medicine”. We respectfully disagree. The point of this position paper is that we don’t want to wait for the profession to work things out, or rather, we ARE the profession for better or worse and we are going to be involved in working this out. — Lisa

  14. Hi Lisa,

    Thank you for your clarifications and persisting here. We all have such different patterns of thought.

    Most of your summation is what I was trying to convey – except:

    I truly believe that TCM schools are trying to teach TCM as defined in China. We didn’t just make it up what should go in there. Some schools offer more, some less, and standardizing is a great idea – especially to control costs.

    Deciding which parts of TCM to offer is super. We are now, as a profession also discussing other types of East Asian Medicine as Chinese (Maoist) acupuncture has never ever been the only kid on the block and different styles of acupuncture, herbalism, bodywork and all the rest seem to be fine when it comes down to practice. (I actually believe that Chinese Acupuncture is the weakest of them all but hey, that’s just me.)

    While some of us don’t feel that studying Qi gong, shiatsu, or tuina assisted them in their acupuncture practices, for me, Qi gong & shiatsu vastly helped me develop and I do think shiatsu at least has helped me be a better Japanese Meridian Therapist – Toyohari style. And I do use diet therapy quite frequently as I treat LOTS of folks with diabetes, parasites, and GI disorders, and trying to loose 100s of pounds. Does one NEED that to be an acupuncture only person? Maybe not, but again, it is worth the discussion. M.D.s have such a poor education in diet and we are in such a great position to help folks in desperate need of help in this area. I know a lot of community acupuncture clinics don’t even go to diet & lifestyle, but I have not yet had a patient that I could turn around their diabetes without that discussion. Maybe I’m just not a very good acupuncturist.

    It also seems from what I read, that you feel that herbal medicine, because some states do not require testing in herbal knowledge to actually include herbalism in the license, can safely be booted out of our education and only those who want to learn it need to pay more for that. I agree that we can do that, but, If we do not change the regulations to reflect that if one has had acupuncture only training one CANNOT prescribe herbal medicine, some folks will decide that they can treat our formulas the way they are done in grocery stores and ‘natural herb shops’. Meaning, folks read on the label of a patent of Yin Qiao San that it is for cough, cold, snuffied nose, sore throat – and think that they can take it when they have any cold or flu, instead of a wind heat or wind cold formula depending on what they actually have or a xiao yang formula if that is what is going on.

    This is the down side of our profession deciding herbs should be classified as a food supplement so they would not have to go to the time & expense of FDA double blind studies when they have been safely prescribed with good clinical outcomes for 2000+ years. This is one of the glossing over I was referring to in my 1st comment.

    In addition, I am not advocating waiting around for some undefined ‘other folk’ who are the profession to make changes and I am very sorry if you thought my comment implied that. I totally agree, we are the profession and we will work it out. Through discussions just like this. There will be lots of worthy discussion
    along the way as we thrash it out.

    I was simply trying to state that if we are going to make East Asian Medical School (TCM schools) shorter to decrease expense, we should also consider different types of licensure to reflect this. For Acupuncture only graduates & license – perhaps Acupuncture Technician, or if we decide on East Asian Medicine as our professional name, then it might be Acupuncturist vs. East Asian Medicine Practitioner. Right now our degrees differentiate this, but not our licenses.

    I don’t see this as being in disagreement really, just in exploring possibilities and how to avoid confusion at this point since we have called everyone Acupuncturists regardless of how they practice.