Please accept this formal complaint regarding the February 2010 ACAOM Decision On First Professional Doctoral Standards.
This complaint has three parts, and we ask that the Commission consider and address each complaint separately according to its normal policies and procedures.
1. In its Resolution on First Professional Doctoral Standards issued February 9th, 2008, ACAOM stated “…there is currently insufficient evidence of consensus within the acupuncture and Oriental communities of interest…to warrant implementing a first-professional doctorate as entry-level into the profession”. The resolution went on to state “Be it resolved that once consensus is reached within the profession, the Commission will renew its efforts to develop and subsequently pilot standards, policies and procedures for first-professional doctoral programs in AOM as entry-level into the profession.” Regarding this decision, ACAOM declared in ACAOM Second Resolution on First-Professional Doctoral Standards issued in August of 2009, “the Commission voted to place the further development of FPD standards on hold pending stronger evidence of consensus among the profession’s stakeholders for accrediting FPD programs”. It goes on to state “Based on comments received from a number of stakeholders in response to the Commission-adopted resolution, ACAOM adopted a motion at its summer 2009 meeting to continue the comment period for seeking information and consensus regarding the first professional doctorate until January 15th, 2010.”
- Specifically, what comments and from which stakeholders constituted “stronger evidence of consensus” for ACAOM to reopen the comment period as declared in ACAOM Second Resolution on First-Professional Doctoral Standards?
- In a comment issued by Dort Bigg on January 4th, 2010 on the AOM Google group created as a discussion forum for stakeholders regarding the FPD, Mr. Bigg stated “…the Commission passed the second resolution on the doctorate based on communications received from other AOM professional organization such as AAAOM and from other constituencies, including educational institutions.” How did ACAOM deem these “communications” as sufficient and what were these communications? Specifically, what evidence did AAAOM present? On what basis did ACAOM deem these “communications” as sufficient to reopen the FPD comment period? What new evidence was presented?
- The Commission correctly charged the AOM profession to “…continue to seek consensus by whatever means deemed appropriate regarding the issue of a first-professional doctorate as entry-level into the profession” in its 2008 resolution. However, what evidence is there that this happened, leading ACAOM to reopen the comment period?
In our view, ACAOM’s decision to reopen the comment period in August of 2009 action requires an official explanation.
2. The second part of our complaint regards ACAOM’s overturning of its own February 2008 resolution:
“Be it resolved that once consensus is reached within the profession, the Commission will renew its efforts to develop…standards.” After the comment period was re-opened without explanation and without any visible process to achieve consensus within the profession, the ACAOM declared in February 2010 that it “is satisfied that there is sufficient support to justify the further development of first-professional doctoral standards.” The ACAOM does not claim to have found consensus or to be consistent with its own resolution; it has simply abandoned its previous standards entirely. Reaching consensus is an utterly different process than establishing sufficient support. The first implies a concern at least to address and to mitigate the concerns of all parties, which is appropriate to an agency which has the trust of the profession. By overturning the 2008 resolution in the middle of the doctoral standards process and without explanation, ACAOM violates the public trust. Either the 2008 resolution was not reliable or in 2010, ACAOM moved the goalposts. Taking our summation as correct, we’d like to know why.
3. The third part of our complaint regards the nature of the data ACAOM received during the comment period following the ACAOM Second Resolution on First-Professional Doctoral Standards. The February 2010 ACAOM Decision On First Professional Doctoral Standards states “The Commission received approximately 3000 letters and petition signatures on the subject(of the FPD), including from individual practitioners, students and patients, the Presidents of state and national AOM organizations such as the Council of Colleges of Acupuncture and Oriental Medicine (CCAOM), the American Association of Acupuncture and Oriental Medicine (AAAOM), a significant number of state AOM professional organizations, an AOM organization promoting a unique business model for professional practice, and from virtually all of the Asian AOM organizations in the US. Collectively, the organizations that submitted commentary represent the AOM educational community and a significant percentage of all AOM practitioners in the US.”
- We challenge the notion that the information gathered during the comment period constitutes a “significant percentage of all AOM practitioners in the US” and demand that ACAOM defend this assertion. We want to see the numbers broken down, relative to the nearly 30,000 practitioners currently licensed in the US.
- Which organizations commented, how many practitioners do they claim to represent and how do they substantiate this membership? CAN is aware of at least four AOM organizations (including our own) with a combined membership of greater than 3,700 practitioners and students who submitted official letters of objection to the continued development of standards for the FPD.
- How many individual practitioner letters were received and what was the breakdown of support versus dissent for the FPD?
- How many patient petition signatures were received and how did this breakdown?
- As an organization, the Community Acupuncture Network (CAN) has verified copies of 152 practitioner letters, 171 active and/or prospective AOM students and 1,700 patient signatures.
Accordingly, we would appreciate the opportunity to see the numbers broken down and be informed of ACAOM’s method of weighing stakeholder comment, if any.
Thank you for accepting our complaint. We look forward to your response.
President, Board of Directors
Community Acupuncture Network