FPD and ACAOM for the gold!

In the new Olympic sport of Moving the Goalposts. Or is it Gaslighting? Hard to define, but it’s clear we have a winner! In this blog post, a recap of a groundbreaking performance, along with some commentary from this thoroughly embittered viewer.

Let’s go back to 2003, with a quote from the CCAOM Entry Level Standards Committee, History and Findings: “The Council of Colleges of Acupuncture and Oriental Medicine’s Entry-Level Standards Committee was formed in May 2003 and charged with the task of gathering information on potential changes in entry-level educational standards. The intent in creating the committee was to create an open process to gather feedback on possible changes to entry-level standards and to fulfill our vision by taking actions that would be open, transparent, welcoming, and without a preconceived agenda.” This seems to be where the public process officially started. That document also contains gems like this: “While concurrent Master’s and doctoral programs may co-exist in some states, most states pointed out that once a higher level of entry education is defined, the lower level is phased out.

You think you know what’s going on here, don’t you. Therein lies the subtle beauty of this performance! Let’s move on to 2005, when the ACAOM Doctoral Task Force issues their final report, and announces the first public comment period. “ACAOM has established a Doctoral Committee, consisting of the Executive Director and several
commissioners, to consider the public comment on the Task Force report as it works to develop
proposed accreditation standards for first-professional doctoral programs in AOM.
” And here is a quote from that Doctoral Task Force:

ACAOM Doctoral Task Force Guiding Principles
We undertake to help facilitate this process should it occur according to the following six principles:
1. Above all else, we will endeavor to do no harm.
2. We will endeavor to bring all communities of interest and voices in the AOM community into
this process and through it together without eliminating or excluding anyone.
3. We will respect all voices in the field and all traditions in the field.
4. We will provide clear communication about our discussions and the processes we propose to the
entire community throughout our discussions.
5. We recognize that our current curriculum leading to the professional degree in AOM and the
competencies that they represent support a valid First Professional Degree at both the current
masters and the proposed doctoral degree level.
6. We recognize that content of curricula will continue to evolve, as it always has, based upon the
need to support new professional roles which emerge for practitioners of AOM

Sounds pretty good, doesn’t it? Do no harm, bring everyone into the process, respect all voices, provide clear communication about our discussions and the processes we propose. A flawless set-up.

And now, the comment period. Other than the public meetings, the only way comments could be submitted during this period was through the ACAOM’s website. An extraordinarily bureaucratic, user-unfriendly website. My first clue that this process was not going to be “open, transparent, and welcoming” was when one of my patients, who was 77 at the time, got frustrated with the website and called the ACAOM to try to register her opinion. She said that she had trouble with computers, being 77 years old, and she wanted to give her comment; the Executive Director hung up on her. Loudly. Not accidentally. Nonetheless,  apparently enough comments got through, from enough young, computer-literate, nondisabled and otherwise privileged people, that in February 2008 the ACAOM adopted a “Resolution on First Professional Doctoral Standards”.

This part is very, very important. This is how Dictionary.com defines “resolution”:



aformal expression of opinion or intention made, usually after voting,by a formal organization, a legislature, a club, orother group.Compare concurrent resolution, joint resolution.

a resolve or determination: to make a firm resolution to do something.

the act of resolving or determining upon an action or course of action, method, procedure, etc.

the mental state or quality of being resolved or resolute; firmness of purpose.

Sounds firm, formal, authoritative and clear, doesn’t it? It sounds like something you might actually believe if you read it. Your belief is key to the spectacular athletic feat that is coming up. And here is the resolution:

In the collective and unanimous judgment of the Commission, there is currently insufficient evi‐ dence of consensus within the acupuncture and Oriental medicine communities of interest, which in‐ cludes state regulators and legislators, educators, and the practitioner community, to warrant imple‐ menting a first‐professional doctorate as entry‐level into the profession. Absent such consensus, the Commission lacks authority to make decisions on whether or when first‐professional doctoral standards, policies and procedures are adopted for purposes of entry into the profession.
Be it resolved that the Commission urges the acupuncture and Oriental medicine communities of inter‐ est, as the primary conveners, to continue to seek consensus by whatever means deemed appropriate regarding the issue of a first‐professional doctorate as entry‐level into the profession.
Be it resolved that once consensus is reached within the profession, the Commission will renew its ef‐ forts to develop and subsequently pilot standards, policies and procedures for first‐professional doctoral programs in AOM as entry‐level into the profession.

My next clue that this process was not “open, transparent and welcoming” came with an anonymous phone call, the gist of which was that there were not going to be any efforts at consensus-building; instead the “public comment period” had been mysteriously re-opened, with no effort to notify those who had made comments before — at least those of us who opposed the FPD. “They’re hoping to get a different answer than they got before,” said my source, who happens to be inside the CCAOM, the ones who got this Olympic snowball rolling in the first place. 

And yet, I couldn’t really believe it. That’s what makes this performance world-class. I’ve been in the profession fifteen years, and even I didn’t really think this was possible. In fact, my partner called the Executive Director of the ACAOM to confirm that we were going to be submitting our comments correctly. He was adamant that there should be no phone calls, no emails, only letters and faxes. OK, we said; the rules sound clear, we can play by them. 

And then, suddenly, emails were allowed. A few weeks later, the ACAOM explained that the “FPD” was NOT ACTUALLY AN FPD, merely a “PD”, a “professional doctorate”. All this concern about a potential change in entry level standards? So silly, when “the question of a ‘Professional Doctorate’ vs. ‘a First Professional Doctorate” is not a distinction that is important from the perspective of accrediting agencies” (Dort Bigg, email, Jan 4, 2010). What is everyone so hysterical about? This has nothing to do with changing entry-level standards!

Quick, look back up at the top of this post, so that you can experience the vertigo as the goal posts are moved! Do you doubt your own sanity, just a little? That’s good, you are experiencing the Olympic-level mastery of confusion to which many bureaucrats aspire, but which so very few achieve! Before you get your bearings, listen to this: “the Commission has purposely not designated or adopted a specific “definition” for determining consensus for purposes of its review of the professional doctorate.   The Commission has many communities of interest including educators/educational institutions, practitioners and practitioner orgs, state regulators and members of the public, among others and need to take the views of all communities of interest” (Dort Bigg, email Jan 4). 

The true beauty of this is that the word “consensus” DOES have a definition. A very simple, specific definition, actually. Here it is, according to Merriam Webster online:

1 a : general agreement : unanimity b : the judgment arrived at by most of those concerned
2 : group solidarity in sentiment and belief

Let’s translate that email out of bureaucratese into English: if you purposely don’t adopt a specific definition of consensus, it means you are not using the definition of consensus that everyone else is using, the one that’s in the dictionary. It means that you don’t mean consensus at all. It means you have moved the goalposts. Be it resolved…oh, never mind. Resolutions are so inconvenient.

And now for the finale! Let’s look at the February 2010 ACAOM Decision on First Professional Doctoral Standards:

“The Commission received approximately 3000 letters and petition signatures on the subject…”

2039 of those represented opposition to the FPD. We know, because we counted them. We photographed their delivery (there’s another story there).

“Based on this review the Commission, in its exercise of professional judgment, is satisfied that there is
sufficient support to justify the further development of first-professional doctoral standards.”

Let that sink in for a minute. Sufficient support. So much for consensus, so much for do-no-harm, so much for transparency. So much for resolutions and respect and clear communication.

You win, ACAOM. You win, AAAOM. You write the rules however you want, and you win. You’ve moved me deeply; I didn’t know I could feel appalled anymore, but I can. Your victory brings tears to my eyes. Really. John Weeks nailed it when he wrote that this is essentially all about the conflict between service to patients and status for the profession. The people who want to be called “Doctor” just want it. They’ll never stop wanting it. They don’t care what happens to anyone else. Because you know, a good way to do harm to a profession is to lie to the people in it. Set them up. Gaslight them. 

You know, the one thing I wonder? Why you ever asked for input in the first place. No, don’t tell me; I’ll never believe a word you say.

Author: lisafer

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Conference Keynote: Breaking the Ceiling

The theme for this conference is “Breaking Barriers”. You know, there are so many barriers to break in acupuncture that it was really hard to choose which ones to talk about for this speech. But since I’ve spent so much time talking about classism as a barrier, I thought it might be fun to shift gears a little and talk about numbers.


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  1. Lying liars and the lie that consensus need not be defined…

    I feel utterly sick about this….


    It seems clear to me that consensus was reached the first time around — a consensus to NOT CHANGE ANYTHING about the entry level standards.


    “open, transparent, welcoming, and without a pre-conceived agenda”…..   so long as we can just do whatever the hell we want when it is all through.



  2. Wow

    I really appreciate your clear thinking on this issue and taking the time to penetrate to the heart of the matter, I guess some people can’t take no for an answer! 

  3. interesting wording

    “…once consensus is reached within the profession, the Commission will renew its ef‐ forts to develop and subsequently pilot standards, policies and procedures for first‐professional doctoral programs in AOM as entry‐level into the profession.”

    *Once* consensus is reached, the Commission *will* develop FPD standards.  Sounds like there was only one “consensus” decision that they were willing to accept. 

  4. Double thumbs up for prevarication

    double thumbs down for consensus.

    It really sucks to not be heard.  Anyone thing we should visit our friends in Maryland? 

  5. Wow

    That’s pretty horrific.
    Meanwhile, what the field really needs is an entry level Acupuncturist technician degree where people can learn some of the basic and be able to practice in some capacity in less than 4 years for less than $80k for school.

  6. That’s because you want to bring them flowers, right, Tess?

    This page and the FPD page are public forums. Discussions of angry mobs, padlocks on doors, and unannounced visits are upsetting to some people. Everyone, please keep that in mind.

    Isn’t it remarkable that on the one hand, individual acupuncturists – who are worried primarily about their patients’ access to care — and who are venting about it,  may have their words taken absolutely literally (ZOMG angry mobs!), while on the other hand, an official body who at least theoretically has the public trust, may define a word like “consensus” any way it wants?

  7. and yet

    if you have trained in anything else so wholy unrelated to Oriental Medicine such as chiropractic or physical therapy, in my state you need 100 or 46 hours respectively to practice acupuncture, or “dry needling”.  yet we may need doctorates.  

  8. Council of Colleges for the Silver and Bronze?

    Well the training for this event has been going on for a long time.

    Heck, look at this training document: https://www.ccaom.org/downloads/ELSCHistoryFindings2003-2005.pdf 

     Notice training commenced with Task 1.  This involved obtaining Position Papers. 

    In 2004 these were solicited from the larger community and here’s what came back:

    The committee received 116 papers.  Of these, 109 opposed a change in entry-level standards and, of these, 26 supported an optional doctorate. Four papers described a transitional approach to honor current degrees while transitioning to a higher degree, and three responses favored a change in entry-level standards. Descriptions of the reasoning in support of the positions were also reported. 


    Summary: of 116 papers recieved 109 opposed a change in entry-level standards and only 24% even supported the optional FPD.  But we are not a profession of quitters.  In fact the document also states:


    It was recognized that few papers were received from those who have been favoring a change. The committee extended the deadline to continue to receive papers, but additional papers were not submitted.  


     A good reminder that when at first you don’t succeed–try, try again!  Hey that was back in 2004… 6 years later and we’re still spending lots of time, money and energy on team FPD.  And now we practically have *consensus*  Miracolo!


    If you’re wondering what the position papers said (from the ELSC report):


     In brief summary, those who did not favor 

    a change in entry-level standards believed: 


    • Current safe practice did does not support need for change 

    • Current level of practice is affordable 

    • Status of primary care required more training than is being proposed to be truly safe 

    • Change will not honor diversity in profession 

    • Change would increase the cost of education, insurance, and malpractice claims 


    In brief summary, those papers supporting a transition to or change in entry levels felt: 


    • A Doctorate is an extension of continued improvement 

    • Increased level of degree can exist with current level until profession can transition 

    • Recognition by insurance companies would make acupuncture services more 

    affordable to people who no longer have to pay out of pocket.  



     Same old plays on the field… one team trying to keep the playing field open, more level,

    recognizing the fans in the stands are why we’re all even here… the other team running after the vanity of stardom,  and vague “improvement” and “legitimacy”, with the paltry reassurance not to worry “you won’t be drafted to another team.”


    Another exciting season of sport in the big leagues. 






  9. I’m still confused

    at the way they put “definition” in quotes up there.  ????  Do they not believe in definitions at all, generally, or just for themselves?

  10. Ugh.

    Thanks for the history lessons, Cris and Lisa (both recent and less recent).  It seems that, even knowing it, we are doomed to repeat it (at least, if we continue this bad romance), because they only want our (figurative and literal) buy-in, not our reasonable objections or constructive criticism.  That is, they want our acquiescense but not our love, love, love – not when “justice is what love looks like in public,” (to quote Cornell West).

    It *is* somehow comforting to know that the majority of acupuncturists (at least, of those who could be bothered to write letters) have, in the not-so-distant past, cared about the same things we care about today.

    “But we are not a profession of quitters” also made me laugh a bitter LOL (I knew you were joking, because of course statistics show otherwise).

  11. Consensus or reasonable support?

    The writing was on the wall when Mr. Biggs of ACAOM started using the term “reasonable support” instead of the previous “consensus” in his correspondence with the FPD google group.

  12. Especially since

    The real issue to go forward shouldn’t be based on consensus or even reasonable support but if the proposal can be shown to benefit the profession. That is what the ACAOM is charged to do and they’ve avoided doing that completely. 

  13. Wow.


     I guess I need to come out a bit and say that I’ve been pretty naive- it was my hope that maybe a common solution could be reached, that everyone could get what they wanted, that there could be both a technician-level degree and a doctorate degree, that we could all co-exist happily. And I admit that sometimes I’ve been put off by my perception of posts here as being snarky, or deliberately baiting, or wondered why the tone had to be so defensive.


    But now reading through this, I see that I was just really unwilling to admit how bad things were and how deeply dishonest the established leadership of our profession has become. I’m really disappointed and saddened that this is so. And I have a lot of respect for you all who have been working for real consensus against this kind of shiftiness.


    That line about the Commission exercising their “professional judgement” in justifying further moves- UGH. 


  14. Thank You!

    I think that is what bothers me the most, where is there evidence that shows those who get a doctorate have better clinical results vs. acupuncturists with a lowly masters. We have all been in classes or read books that sound really nice and the theory presented is intellectually interesting, but of little to no use in the clinic.

    Why not examine what we already have in place and look at what is working and what is not instead of piling on more clinically irrelevant B.S. If acupuncturists feel unprepared and ineffective coming out of school (raises hand) what good does it do to slap “perfume” on a bottle of cat piss.

    Chad Powell, L.Ac. and lives with two cats and knows that cat piss really stinks.

    Haven Community Acupuncture

  15. Maybe it’s time to take this public.

    It’s a small issue that doesn’t interest most of the population, but if there is a way to publicly expose these nefarious actions so that their web of deceit can be displayed in an accessible place, somewhere under the topic of Affordable Health Care, these deluded souls can be shamed into ceasing their efforts to gain money, power and fame at the expense of the all-suffering American patient.   Additionally, once this information (thanks to untiring efforts of our Lisa) is disseminated far and wide, those folks leading the ACAOM and AAAOM will lose a lot of their support from lower down in the ranks. 

    The big question is:  what forum can we target and cultivate?

    I do not think “they” have won.  They win according to the old rules of communication.  Who are we?  We have other tools we can use, more powerful than those they know.  They’re just a little unorthodox, but certainly legitimate and more loving.  This is just a comment.  I hope it stimulates thought.  I certainly don’t have much of a banner myself, but together, with all the enormous talent in this organization, I think something can be done. 


    “Justice is what love looks like in public”  Cornel West

  16. The FPD could also be represented

    by the make-believe horse (doesn’t get you anywhere any faster, etc.)…the possibilities are endless…

    But then again, what do I know?  I thought we were an autonomous collective.

  17. Don’t get me started, Nora.

    Once I let my mind go down THAT road, things go deteriorate very quickly. Like the NCCAOM exam for FPD graduates. “What is your name?, What is your quest?, What is the airspeed velocity of an overeducated acupuncturist?………….

  18. Thanks Lisa

    For the update. I had e-mailed jessica when i first heard about ACAOM’s “consensus” as i was confused because of the numbers of letters dropped off by Jessica versus the numbers tallied.

    My thought was that they treated those letters like a “pettition” where either an unregistered voter or a duplicate signature nullifies a whole page of signatures. So they may have viewed those letters as “duplicates.” (not defending them or their actions in any way shape or form).

    The question is, where to go/what to do now? Does someone go to the DOE? We have to be willing to risk whatever consequences that may bring as it would be, in the long run, for the best. Look at what’s happening to chiropractic (Life University in particular, and I think there is possible litigation against CCE and Life, not to mention various student loan borrowers in default).

    In one of your earlier posts, you mentioned the rising cost of AOM education. Here’s my take: If we looked back prior to Title IV, I will bet that tuition at various AOM schools was manageable. Once Title IV financial aid became available to AOM schools, I’ll bet tuition skyrocketed (much like it did with chiropractic colleges).

    Granted, what I am about to say will be very unpopular, but perhaps the next steps would be to not only address the possible unethical decision making by the ACAOM, but also address Title IV (specifically, move to have it unavailable to schools of AOM). In order to do this, one would need default statistics of AOM grads along with practice longevity stats and income stats. I have put together a rough survey that I presented to my state AOM association, but they’re doing nothing with it (and I’m not a member). I’m thinking it would be a robust online survey with rule-in, rule-outs, where responses to various questions will lead to different paths. All respondents would be able to participate regardless of whether or not they are still in practice. The only problem is how do we get the 27000 current practitioners to participate and how do we find those that have left the profession?

    That would be some really good information, versus just speculating (as AAAOM, ACAOM, CCAOM have done. AAAOM’s survey kicked you out if you practiced less than a certain amount of hours–I’m back in grad school, so I’m not able to practice, so I went back and fudged it). it would seem nobody really wants to know. Lastly, I discovered that the ACAOM, in their standards, stated something to the effect that schools are required to inform their students that credits from nationally accredited schools (of which the majority of AOM programs are) won’t always transfer into regionally accredited schools. Anybody remember hearing this from their respective schools? Has anybody’s respective AOM “alma mater” violated ACAOMs standards?

  19. On another note…

    reading some of your comments on the AOM google groups, i was tempted to respond there but didn’t b/c well, they would not have liked it.

    As some in the inner city would say:


  20. “Phantasmagoria”

    Word of the Day for Wednesday, March 10, 2010

    phantasmagoria fan-taz-muh-GOR-ee-uh, noun:

    1. A shifting series or succession of things seen or imagined, as in a dream.2. Any constantly changing scene.

    My WOTD totally reminded me of ACAOM and their goalposts…