Position Paper Part 3: Retaliation

Last week on January 4th, the Utah Acupuncture Licensing Board posted its agenda for an electronic meeting on the following Tuesday, January 9th. There were two discussion items on the agenda, described only as 1) Letter of Concern, and 2) Rule Change Amendment.  There was no indication why any member of the public might want to attend this meeting.

The Letter of Concern and the Rule Change Amendment were posted as public notices on Tuesday after the meeting.

The Letter of Concern, directed to the NCCAOM, starts out with this paragraph: “we write to you with concern regarding a lower standard of training for qualification and entry into the AOM profession requested by POCA (People’s Organization of Community Acupuncture). Their request to lower the standard to become a Diplomat of Acupuncture or a Diplomat of Oriental Medicine causes deep concern for the ongoing quality and integrity of the profession in addition to the safety of the public.”

And the Rule Change Amendment?

It would change the requirements for acupuncture licensure in Utah by adding a new requirement: NCCAOM certification in Chinese Herbology. As Chris Rogers of Wasatch Community Acupuncture (formerly QiWorks) wrote, “this rule change would effectively shut down anyone from Utah from being able to attend POCA Tech and then practice in Utah.”

Which was — obviously — the intent of the Rule Change Amendment and the purpose of the electronic meeting.

Fortunately, Jax Rogers of Wasatch subscribes to the licensing board meeting minutes and immediately called the Division of Occupational and Professional Licensing (DOPL). Based on what she found out, DOPL did not receive any reports of public safety problems or adverse events regarding Chinese herbs that prompted this proposed rule change. Importantly, the DOPL representative stated that the public would be able to attend the next meeting (on February 20th) to discuss the issue, and that the public could submit written comments and concerns in advance of the meeting. Notably, he explained that DOPL's objectives are to (1) protect public safety and (2) encourage commerce.

If you don’t follow POCA Tech fairly closely, you might not know that:

1) There are currently 4 students from Utah enrolled in the program — about 10% of our student body.
2) Both POCA clinics in Salt Lake City are monthly sustaining donors of POCA Tech.
2) One of the POCA Tech students, Laura, is on track to graduate this summer. She’s been commuting to Portland for 3 years and temporarily moved here last fall to complete her internship. She has a full-time job waiting for her at Wasatch where they desperately need her (because like many POCA clinics, they’re understaffed).
Here’s a quote from the blog post that Laura wrote for our most recent POCA membership drive about her trajectory from patient to volunteer to employee of Wasatch/QiWorks:

I liked the feel of QiWorks, so I decided to help out at the front desk once a week… the biggest perk was feeling like I was a part of a community, like I was beginning to weave myself into their family-like web. I wasn’t just helping out a small business, I was getting to be a part of the healing QiWorks team. I got to interact with patients, the vast majority of them were friendly and super grateful for what QiWorks offered, and by extension, grateful to me and the role that I played at the front desk…I began trying on the idea of what my life might look life if I went to POCA Tech to become a community acupuncturist and weave myself into the POCA web further…I was drawn to a profession that offered a way to support people in social justice oriented manner, that was not only effective at easing the suffering of so many people, but that it was also outside of the typical capitalist system in some ways.  I saw a future for myself in which I could earn a living by genuinely helping people and creating a large change in the world. For many years, I had felt overwhelmed by the suffering of the world, by the lack of justice, connection, and awareness, and by not knowing how to best make a difference.  I felt stuck and daunted by trying to find “the right way” to apply myself to try to make a positive impact.  By choosing to become tangled in the QiWorks Community Web I was healing on a personal level and was creating ties with a community that was effecting change for lots of people. Wanting to continue to deepen that feeling of connection and power to do something meaningful was what reassured me enough to dive into applying at POCA Tech.  I saw what the end of the road could look like for me after graduating from acupuncture school, and diving in as a well-trained punk at QiWorks.

Does anybody else feel like they were punched in the gut, or is it just me?

POCA Tech’s mission is to recruit students from the patient populations that POCA co-op clinics serve and then train them to provide acupuncture to underserved communities through POCA. Laura’s relationship with Wasatch/QiWorks is emblematic of how our mission works. The only way for many (most?) POCA clinics to continue to care for so many people is to recruit acupuncturists from the same communities they serve. By and large, graduates from conventional acupuncture schools don’t want to work in our clinics or serve our patients.

POCA Tech’s whole purpose is to un-limit a market and provide access and choice for consumers who otherwise wouldn't have any.

An acupuncture licensing board wants to stop us from doing that. In a state with 117 acupuncturists available to serve a population of 3 million, POCA Tech graduates are explicitly unwelcome.

Who can I write to, to convey my deep concern for the quality and integrity of the acupuncture profession? Because what kind of a profession would do something like this, retaliate against a cooperative with 1200+ patient members by covertly acting to limit their school's graduates from practicing in an underserved area, thereby limiting the citizens of their own state from access to affordable healthcare? What kind of a profession would try to wipe out Laura’s and Wasatch’s investment in her education, months before she was planning to graduate? 

It’s important to point out that anyone without an acupuncture license—anyone at all–can buy, sell, and distribute Chinese herbs. In fact, they are sold in numerous Asian grocery stores as well as just down the street from Wasatch at a vitamin shop. The only function of requiring NCCAOM certification in Chinese herbology for an acupuncture license is to limit who can practice acupuncture in a state. Certification, being used as a weapon.

I guess I’m naive. When we published our position paper, I expected a backlash, but I didn’t expect that anybody would try to punish POCA Tech’s students for what we wrote, or the clinics who want to hire them, or the patients who are waiting for affordable pain relief.

After all these years, acupuncture profession, you can still surprise me.

POCA members who want to participate in organizing in Utah against this proposed rule, please sign this petition and then distribute it as widely as you can. Our comrades in Utah and all the patients who depend on them need our help and they need it NOW.


Author: lisafer

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  1. POCA needs a better dialogue with the Licensed Acupuncture and Master’s Degree level practitioners.

    Your “Job analysis” and the subsequent “analysis” of our profession was very biased. It came along with a strong push by POCA to lower the amount of education that represents a Master’s Degree. In essence, you were attacking the current and past training standards that thousands of acupuncturists have invested time, sweat, tears and much money into.

    You are an idealistic group. Very noble in your mission and you will find a lot of support for community acupuncture and care amongst current NCCAOM diplomates and Master/Doctoral practitioners. But, you will suffer severe backlash if you try to attack our credentialing.
    I think your process of changing the ACAOM credentialing is very good and it seems from your previous posts that those changes are helping to grow POCA Tech and other CA training programs.

    I understand your POV that you want to lessen the educational hours and financial burden on those who want to learn the basics of acupuncture to serve their community. This would be the equivalent of a Bachelor’s degree in counseling or nursing, versus the higher MS. That would be an excellent idea. But neither of those degrees allow independent practice. They are supervised degrees.

    Your most serious problem is the NCCAOM. If they grant your lower education program an equivalency to the MS programs for a Diplomate of Acupuncture, then the ACAOM colleges and current Diplomates will be damaged. The value of their education will be significantly reduced.

    Now, your idealistic mission might view this as a proper cost for offering more Acupuncture to a larger population. However, it will forever cost you the cooperation of a majority of the current Acupuncture profession.

    It seems that the reaction of the Utah Acupuncture Board is a result of this conflict.

    Roppie will attest that many of the ASA representatives find fault in the restrictions placed by the Utah board, but most for the reason that there are many styles of acupunctue practice without any need for herbal medicine. None of them were against this change because they want to lower the amount of education to become an acupuncturist.

    In summary, POCA will find allies in the Acupuncture profession. But not by attacking or trying to weaken our educational requirements. If you want to find a method to tier the profession and create a Bachealor or other degree that can properly train acupuncturists, lets work together. It will be a tricky and lengthy process to enlist the NCCAOM, ACAOM and CCAOM and work to change individual state laws/rules. But the opiod crisis might allow some chances for this.

    Peace and with deep respect.

  2. Hi William,

    thank you for your comment.

    There is something I’m not understanding here (well, a couple of things), and I would like your help in sorting it out. Can we start with your conviction that fewer hours equal a less rigorous education? I’m the Director of POCA Tech, and I have overseen POCA Tech’s self-study process which is intended to be a self-critical process for our school to identify areas in which we could improve our program. It is clear to us that we can meet ACAOM standards for Master’s level education with fewer classroom hours. Your comment makes it sound like we have no knowledge of acupuncture education and we are “attacking” “your” educational standards from the outside. From my perspective we are attempting to improve our OWN educational program, very much from the inside. Quality acupuncture education is not simply a matter of hours spent in school, it’s an issue of competencies. We are not training acupuncturists to do anything “less” than other schools, anymore than a 5 Element school is “less” than a TCM education. I graduated from OCOM in 1994 with an M.Ac.OM. I don’t remember the exact number of educational hours, but it was definitely substantially less than any program in existence today, and yet my degree is equal to any other OCOM alum. Standards change, technologies improve, I believe, based on my experience, that POCA Tech’s program offers training better than what I received and the program could be condensed into fewer hours. Our faculty feels the same. Can you help me clear up this misunderstanding? thanks, Lisa

  3. William —

    I am also wondering about the “strong push” you mention. As far as I know, POCA Tech identified a disconnect between the training hours required by ACAOM and the actual competencies required by ACAOM and asked ACAOM and NCCAOM to consider focusing on the competencies and providing some flexibility on the hours. As far as I know, NCCAOM has already indicated they would not consider such a change. So, a request was made, and it was not granted.

    But setting that aside, there is no good reason for a licensing board to, proactively INCREASE the requirements for education, in the absence of any risk to the public or even a request being made to decrease the hours required (which did not include lowering standards). Wouldn’t maintaining the current requirements avoid any issues?

  4. Echoing a theme above: I think it’s curious that so many of the longest-practicing providers graduated with substantially less hours and less specific standards and we revere them for being successful and laying the groundwork for the profession itself. They have been practicing safely and effectively for years, and are often lauded as “leaders in the field.” Yet similarly refined programs proposed now to offset the arbitrarily expanded programs that have crept in over the years (ie not based on any research of needing to raise levels of safety or effectiveness in practice, not to mention the direct uptick in program length/cost around the time of student loan availability) are denigrated as somehow “degrading the current education.”

    Are those “leaders in the field” degrading the current education with all their many thousands of successful treatments, happy patients and shared wisdom?

  5. janisx —

    I don’t know the specific history in Utah, but I can say 1) The Acupuncture Board has no control over what Chiropractors do. If the Chiropractic Board has found that 100 hours of training is sufficient, they can maintain that standard. And the history of safe practice with 100 hours is a good argument against the increase proposed by the Acupuncture Board.
    2) In many states, regulations about Acupuncture practice for DC’s and MD’s pre-dated licensure for Acupuncturists.

  6. Enjoying Lisa’s posts and all the comments.

    Here is my comment on the change.org petition which I’ll also send to Larry Marx. 🙂

    I was president of the Utah Acupuncture Association (UAAOM) from 2008-2013. I am also a Community Acupuncture practitioner (licensed in both Utah and Oregon) who has never formally studied herbs. During my tenure as president a majority of members of our association felt it was necessary to fight against members of other professions who were seeking to include acupuncture in their scopes of practice. What I learned from participating in those “turf wars” was that they were ultimately fruitless. Because they weren’t actually about patient safety but about insulating acupuncturists from competition. And insulating oneself from competition doesn’t work in any business or sector. Building excellence is the only way to create job security.

    I’ve been away from Utah for almost 4 years now, and I see, with sadness that the officers of the association are now training their sights on Community Acupuncturists and other acupuncturists without degrees in herbology (my original training in 5-element acupuncture also did not include herbs). I understand the scarcity/competition mentality behind this move. It can be frustrating and difficult to make a living as an acupuncturist. But this mindset of conflict and competition seems to me misguided and counter-productive. Practitioners without herb training—and especially those graduating from the recently opened Community Acupuncture school in Portland, OR—have all the tools and training they need to give tremendous help to a large segment of the population, many of whom would NEVER be able to afford acupuncture in the way that it’s practiced by the majority of acupuncturists in the U.S. And they do so just as safely as any other practitioner.

    This appears to me to be another turf war, internal to the profession this time.
    If those practitioners with herbal training want to sponsor the creation of a formal category of practice for those who prescribe herbs I see no reason why they shouldn’t distinguish themselves from those who don’t. But, both historically and in terms of efficacy of treatment, they have no grounds upon which to insist that those of us who don’t prescribe should be forced to. From what I’ve heard I, as a licensed practitioner, would be grandfathered into the amendment. But I know of 4 acupuncture students planning to practice in Utah who would be unable to practice there after they graduate if this proposal is adopted. In a state with 3 million people and only 117 active practitioners this makes no sense to me at all.
    Thanks for reading.


  7. Hi William,
    I don’t want to derail the conversation here, but I’ve got a side question. What do feel like was “biased” about our Job Task Analysis and the subsequent analysis of the responses?

  8. Yes, I also wondered what was biased about the JTA and subsequent analysis.

    And, once we have an idea of what that might be, it could be interesting to look at other JTAs and see what biases might be lurking there.

  9. Here is my two cents, from my own personal vantage point:

    I am an acupuncturist with a masters degree, and a lot of debt as a result. I do not feel that the value of my education is reduced by anything that POCA does or promotes.

    I’m grateful to POCA for being the one light on the acupuncture horizon that inspires me. Were it not for POCA, this would have been my last month as an acupuncturist. Because of POCA’s vision, I am renewing my NCCAOM credentials and am envisioning a future with CA.

    I have some backstory to share.
    I am a physical therapist also. I graduated with a Bachelors Degree in Physical Therapy over a quarter century ago. Soon after, the same program became a Masters Program, and now all PT programs are entry level doctoral.

    You know what? It has been common knowledge among clinical nursing staff and physicians over the past 20 years since these advanced degrees started showing up, that the therapists with the higher level degrees generally tend to be worse clinicians. If they are individually willing to learn once out of school, then they become good clinicians.

    I let go of my participation in the APTA and my state PT association long ago due to their aggressive turf battles, as well as their promotion of higher entry level degrees for the profession.

    I let go of my participation in state and national acupuncture organizations within a year of becoming a licensed acu, for pretty much the same reasons.

    Higher entry level degrees have degraded the on-the-ground practice of physical therapy, while producing clinically ill-prepared new practitioners with unfathomable debt.

    I am grateful that there is a voice of sanity in the acupuncture world. That would be POCA.