Apprenticeship Proposal Report #2

Currently, new acupuncture practitioners must meet the following 2 primary requirements in order to receive an Oregon acupuncture license:

(1) Have graduated from an acupuncture program that satisfies the standards of the Accreditation Commission for Acupuncture and Oriental Medicine (A.C.A.O.M.), or its successor organization, or an equivalent accreditation body that are in effect at the time of the applicant's graduation. An acupuncture program may be established as having satisfied those standards by demonstration of one of the following:

(a) Accreditation, or candidacy for accreditation by ACAOM at the time of graduation from the acupuncture program; or

(b) Approval by a foreign government’s Ministry of Education, or Ministry of Health, or equivalent foreign government agency at the time of graduation from the acupuncture program. Each applicant must submit their documents to a foreign credential equivalency service, which is approved by the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) for the purpose of establishing equivalency to the ACAOM accreditation standard. Acupuncture programs that wish to be considered equivalent to an ACAOM accredited program must also meet the curricular requirements of ACAOM in effect at the time of graduation.

(2) Current certification in acupuncture by the National Certification Commission for Acupuncture and Oriental Medicine (N.C.C.A.O.M.). An applicant shall be deemed certified by the N.C.C.A.O.M. in Acupuncture if the applicant has passed the N.C.C.A.O.M. Acupuncture Certification Examinations, or has been certified through the N.C.C.A.O.M. Credentials Documentation Examination. The applicant has no more than four attempts to pass the NCCAOM Acupuncture Certification Examinations. If the applicant does not pass the NCCAOM Certification Examinations within four attempts, the applicant is not eligible for licensure.[1]

We propose a two-part change to the above requirements:

1. Allowing for U.S.-educated applicants to have the same ability as foreign-educated applicants to demonstrate curricular equivalency to ACAOM standards.  We suggest this be accomplished via recognition of educational institutions that are accredited by one of the eight regional accrediting bodies recognized by the U.S. Department of Education and the Council for Higher Education; and
2. Recognizing a combined program of 4,000 hours of clinical apprenticeship and 800 hours of didactic training provided by a regionally accredited institution as equivalent to an ACAOM-accredited acupuncture training program.   A 4,000 hour apprenticeship will qualify applicants for NCCAOM certification pending the passage of relevant NCCAOM exams.  In addition to the clinical training provided as part of the apprenticeship, we suggest the following standards for the didactic portion of an equivalent program:
3. 260 hours of Chinese Medicine Theory
4. 450 hours of Biomedicine
5. 90 hours of Counseling, Communication, Ethics and Practice Management

The Biomedicine and Counseling, Communication, Ethics and Practice Management components of this proposal equally match the curricular requirements of the ACAOM.  The reduced number of hours for the Chinese Medicine Theory component as compared to ACAOM standards reflects two assumptions:  1) Theory is so central to the practice of acupuncture that we expect it to be a major element of the 4,000 hour clinical apprenticeship; and 2) Students choosing this more self-directed and challenging route to licensure will have to be highly motivated.  Independent study will be a requirement for success for this route, ensuring that sufficient out-of-class attention is given to the study of Chinese Medicine Theory.

ACAOM’s Curricular Requirements

The following is an excerpt from the ACAOM Accreditation Manual:  Structure, Scope, Process, Eligibility Requirements and Standards:

The minimum length of the professional acupuncture curriculum must be at least three academic years (a minimum of 105 semester credits or 1905 hours). This must be composed of at least:

   47 semester credits (705 hours) in Oriental medical theory, diagnosis and treatment techniques in acupuncture and related studies,

   22 semester credits (660 hours) in clinical training, and

   30 semester credits (450 hours) in biomedical clinical sciences.

   6 semester credits (90 hours) in counseling, communication, ethics and practice management.[2]

Comparison of the ACAOM Requirements

to Proposed Path Requirements

Statement from PCC/CLIMB for Health Professionals

My name is Sheila Meserschmidt, Director of CLIMB for Health Professionals at Portland Community College (PCC).  CLIMB is involved with this proposal as we are the continuing education arm of PCC, designed to lead innovative and entrepreneurial thinking toward solving unmet education needs, and charged with improving the region’s economy by creating sustainable jobs.  As a patient of acupuncture I recognize and support its benefits as a viable and affordable modality of healing.   When held up to the current condition of health care and the challenges faced by the broader medical provider environment, its attributes are compounded.

Background on CLIMB for Health Professionals Involvement

In April, 2011, while in Florida, I made a special trip to meet the Director of the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM^®).  At that time, CLIMB was exploring the creation of a three-year, entry level, acupuncture program.  In an effort to ensure that our graduates could sit for the NCCAOM certifying exam, I posed questions leading to any reason why PCC, as a nationally accredited college, could not implement such a program, satisfying NCCAOM’s eligibility requirements. 

At that time, NCCAOM offered three eligibility routes:  

1. Formal education: graduate or pre-graduate from an ACAOM accredited program: US applicants only

2. Formal education: international applicants

3. Apprenticeship: US and international applicants”

Our request was that they include one more:

Formal education: graduate or pre-graduate from an ACAOM-equivalent, regionally accredited program, US applicants only.

Our program would be ACAOMequivalent, an acupuncture-only training program, and graduates could sit for the NCCAOM exam.

The short response to that meeting by NCCAOM’s Director was “no”.   Their follow up recommendation was that PCC go through the process of applying to ACAOM and become accredited through them.  However, this appeared to be an unnecessary and fiscally unreasonable expectation considering we already meet a far more rigorous authority through the Northwest Commission on Colleges and Universities (NWCCU).  Further, we later received a document whereby the U.S. Department of Education Staff Report to the Senior Department Official on Recognition Compliance Issues – ACAOM final analysis, raised a number of concerns about ACAOM’s status.  Since PCC is regularly under review due to regulatory compliance requirements, such a number of seemingly significant concerns voiced by the US Department of Education was troubling, and gave additional pause to considering going to ACOAM for accreditation.  The NCCAOM Director’s response when I asked about this report was “I do know that there have been a number of important leadership transitions with ACAOM this past year (a new Board Chair and a new Executive Director and Assistant Executive Director). I believe ACAOM is actively working on all these compliance issues most aggressively this year.”

As a result CLIMB is interested in supporting the pursuit of the Apprenticeship Route, which is acceptable to NCCAOM, via a supplementary educational program.   If supported by the Oregon Board of Medical Examiners, CLIMB for Health Professionals (PCC) would design an innovative national model of acupuncture training, the concept founded in Oregon, which would maximize the ever growing professional preference for blended learning to include:

1. didactic in an interactive online format;
2. intensive skill-based training in a face-to-face classroom environment, and
3. apprenticeship resulting in sitting for the NCCAOM board certification exam.

This approach would not only train individuals with no health background wanting to enter the field of acupuncture, but would also provide cross-training opportunities for professionals already in healthcare, ensuring the highest standards of education. 

The program of study would be ACAOM equivalent and include 260 hours of Chinese medical theory, 90 hours of counseling/communication/ethics/practice management, and 450 hours of biomedicine. While CLIMB/PCC would often be the institution of choice for meeting these academic expectations, these requirements could be acquired at any community college or university.

CLIMB will also develop a course for preceptors.  This course will include topics such as effective instruction methods and supervision skills, and evaluating the readiness of apprentices to increase levels of patient interaction.   Additional tools and resources for preceptors will also be developed such as clinical workbooks for the associated didactic coursework.

Regional Accreditation through Northwest Commission on Colleges and Universities (NWCCU) 

Following is language from the Northwest Commission on Colleges and Universities (NWCCU) illustrating Portland Community Colleges’ strength through regional accreditation:

Northwest Commission on Colleges and Universities (NWCCU) Overview

Regional accreditation is a process of recognizing educational institutions for performance, integrity, and quality that entitles them to the confidence of the educational community and the public. In the United States this recognition is extended largely through nongovernmental, voluntary membership associations that establish accreditation criteria, evaluate institutions against that criteria, and approving institutions that meet the criteria.

Institutions accredited or pre-accredited by the Northwest Commission on Colleges and Universities are required to examine their own missions, goals, operations, and achievements. It then provides expert analysis by peer evaluators, and, later, commendations for accomplishments and recommendations for improvement from the accrediting body. Since the accreditation status of an institution is reviewed periodically, institutions are encouraged toward continued self-study and improvement.

While accreditation criteria and procedures of regional accrediting agencies differ from region to region, the principles underlying eligibility and levels of expectation are similar in their intent to:

• foster excellence through the development of criteria and guidelines for assessing educational quality and institutional effectiveness;
• encourage institutional improvement through continuous self-study and evaluation;
• ensure the educational community, the general public, and other organizations that an institution has clearly defined and appropriate educational objectives, has established conditions under which their achievement can reasonably be expected, appears in fact to be substantially accomplishing them, and is so organized, staffed, and supported that it can be expected to continue to do so; and
• provide counsel and assistance to established and developing institutions.

When granted, accreditation by the Northwest Commission on Colleges and Universities is not partial. It applies to the entire institution in operation at the time of the most recent comprehensive evaluation. It indicates that the institution as a whole is substantially achieving its mission and that it meets the Commission's expectations for compliance with the accreditation criteria.[4]

Justification for Training Through Blended Learning

There are those, particularly in healthcare, who are skeptical of using distance learning for healthcare training.  Legitimately, there are areas where it certainly does not have a place.  Teaching skills, such as how to insert needles for IV Therapy, is one obvious example.  However, as the physician population knows well, innumerable valuable and high quality continuing education offerings are available for CME via online.  Not surprisingly this is equally true of CEU instruction for other healthcare professionals.

CLIMB for Health Professionals has considerable experience in this area and we are assertively expanding the number of courses we provide online.  With only one exception, all CLIMB for HP’s online courses are implemented via Collaborate (similar to Go to Meeting).  This tool allows students from all over the world, literally, to participate at one time in a course with both “chat” and voice-to-voice conversations with the instructor (via $25 headset microphones), full access to power point, video, white boards, breakout rooms for small group discussion and projects, polling for learning assessment, quiz taking, etc.  We currently have students from across the United States as well as other countries registered in our classes. 

Our approach is to develop courses that are dynamic, engaging, and highly interactive.  They can be recorded in the rare instances that students have to miss a session and accessed at a later date.  Additionally, instructors regularly have “office hours” online where they can respond to student questions, students may arrange for online study groups, and professional networking has produced rewarding outcomes.  The participant response and requests for more of our courses to be in this format has been such that any course that can be logistically done well online is moving in that direction.

For example, Spring Term, 2012, we will offer 30 hours of the 90 hours required for the International Board Certified Lactation Consultant (IBCLC) training online.  The other 60 hours will be condensed into two, 4-day, intensives on site: one session in April and one in May.  This means that individuals from across the United States can take one third of their training on Collaborate with our certified instructors, and travel to Portland for the remaining days, completing their coursework in a most efficient manner.  Using online learning, as this example illustrates, allows for

1) training up the workforce,

2) maintaining present employment,

3) expanding job capacity,

4) reduction in professional/personal upheaval,

5) pursuit of a certification which is not easy to access and acquire, and

6) bringing economic value to the Portland region.

We believe that acupuncture didactic is perfect for this method of transferring knowledge.  With input from master instructors in the field, determination for what is appropriate for distance learning and what is not will be made and implemented.

CLIMB for Health Professionals Training Toward Certifications

CLIMB for Health Professionals provides CEU training for almost all health professionals, not including those with Physician standing.  We provide training toward certification in the following areas:

Nursing specialty areas

Lactation Management (IBLCE)

Paramedic National Registry Recertification

American Heart Association Provider and Update/Renewal (CLIMB is the largest Training Center in Oregon)

Pharmacy Technician (PTCB)

Phlebotomy Route 2 (ASCP)

CNA 1 & 2, OSBN approved

Professional Medical Coding (AAPC)

Summary

As directed by PCC’s President, Dr. Preston Pulliams, CLIMB has an institutional goal of strengthening the College’s innovation and effectiveness with improved planning, instruction, student services and decision making.  Part of that directive is to overcome constraints associated with limitations relative to size, location and cost of education for our students through assertive development of distance learning and other technological strategies.  We are committed to:

1. expanding access to education through online course delivery;
2. enriching our student’s learning experience through diversity of students and faculty by eliminating geographic restrictions;
3. ensuring quality education through continuous evaluation and innovation in each course we construct;
4. positioning students for success by removing geographic learning barriers;
5. contributing as partners in training toward local, national and global economic, educational and workforce demands;
6. effectively utilizing college and community resources in order to contribute to the social, financial and environmental well-being of all we serve.

We believe that CLIMB for Health Professionals, through Portland Community College, will create and implement an unrivaled program for training future acupuncturists, impact the sustainability of the profession, and generate economic benefit to the Portland region.

Apprenticeship by State

PLEASE NOTE:  The following information was gathered through internet research and should not be relied upon as a sole source of information about which states allow apprenticeship.  Be sure to check with your state's regulating organization before making any plans to pursue apprenticeship.

Four states explicitly allow apprenticeships:  California, South Carolina, West Virginia and Washington, D.C.  Of these, only California has structured requirements for how the apprenticeship (called the acupuncture tutorial program) is conducted.  South Carolina, West Virginia and Washington, D.C. do not have formal requirements past the number of hours, reporting formats and supervisor requirements, however, each of them do require passage of the relevant NCCAOM exams.

Eight additional states require NCCAOM certification as the minimum requirement for acupuncture licensure:  Alaska, Delaware, Maryland, Minnesota, Missouri, Ohio, Pennsylvania, Utah.  A 4,000 hour apprenticeship is one of three routes to NCCAOM certification.

Six states in addition to Oregon (Colorado, Georgia, Hawaii, Illinois, New Hampshire and Washington) have license requirements that may allow for apprenticeships in the future if the issue of ACAOM-equivalency is satisfactorily addressed on a state-by-state basis. 

Combined Apprenticeship and Didactic Education—

Affordability

Cost estimates from CLIMB are being developed and will be available by the time of the December 2, 2011 meeting of the Acupuncture Advisory Committee.  It is expected that the cost will be a fraction of the cost of obtaining a degree from any existing acupuncture school in the U.S., both in terms of direct costs for the program and indirect costs as the flexibility of the proposed program will permit participants to work during their acupuncture training.

Addressing Underserved Areas

Acupuncture schools are typically located in and around urban centers so as to be centrally located for as many people as possible.  This reality contributes to a disproportionate number of practitioners choosing to practice in these same urban areas, whether because new graduates do not wish to relocate or because the cost and inconvenience of relocating keep potential students from rural or distant suburban areas from attending acupuncture school. 

We see this dynamic occurring in Oregon.  Of the approximately 1100 licensed acupuncturists in Oregon, 800 or 73% practice in the Portland metro area[5].   Our proposal would provide an opportunity for potential practitioners in rural and suburban areas to study acupuncture without having to relocate to Portland. 

Additionally, as a result of this program, successful acupuncturists in rural and suburban areas may have new possibilities for passing on their practices to other qualified acupuncturists in the event of their retirement, disability or relocation. 

A Leader in Our Profession

Oregon has the opportunity to be a leader on the issue of reducing student loan debt for those studying acupuncture by creating an affordable and flexible path to licensure.  The importance of such a move should not be understated.  The future of our profession depends, in part, on the ability of those who practice it to make a living doing so.  Without affordable paths to licensure, crushing debt will (and does) force acupuncturists out of the profession and into jobs in other fields.

We expect future acupuncturists in other states that allow apprenticeships will be interested in the innovative educational option we are proposing to create.   The didactic program will aid any apprentice, regardless of location, in studying for the NCCAOM exams.  Additionally, potential apprentices and preceptors who may have considered an apprenticeship arrangement but felt overwhelmed by a lack of structure and support may welcome a formal educational component and the resources that will be developed to help them succeed.  We also expect apprentices in other states will appreciate the assistance this proposed program will offer them in terms of preparing for the NCCAOM exams. 

Statement from Nancy Sutton, MSW, L.Ac.

I am co-owner of Salem Community Acupuncture LLC, a growing acupuncture practice in Salem, OR.  My co-owner, Nancy Arntson, RN, L.Ac. and I need to hire another acupuncturist in order to meet our current patient demand and to proceed to our long-term goal of hiring three to four full-time acupuncturists in addition to ourselves.

I have some serious concerns about attracting new graduates to live and work in Salem.  Those students who choose to relocate to Portland for graduate school often choose to build their practice in this or other hip urban centers.   For those individuals who, like me, are committed to Salem as a community, the commute and/or expense of relocating to Portland for 3-7 years of acupuncture school is often untenable.  It is my guess that this situation repeats itself all across Oregon where potentially excellent candidates for acupuncture education are unable to access educational opportunities due to location.

I know of at least one Salem resident who would make an excellent acupuncturist and would be interested in pursuing acupuncture licensure if an apprenticeship path were available.  Leyna Jensen, L.Ac. in Corvallis, OR has also indicated that she is in touch with someone interested in an apprenticeship option.  I am confident there are others throughout the state. 

Aside from the cost-savings that an apprenticeship option would offer, I know that residents of rural and suburban Oregon would benefit from increased numbers of acupuncturists practicing in their hometowns.   I also anticipate that acupuncturists currently practicing in rural and suburban areas who have built thriving practices would benefit from having well-qualified practitioners to pass their practices onto in the event of retirement, disability, or the need for relocation.