Below is the body copy of POCA's letter to ACAOM. The ACAOM website only allows a small amount of space in their public comments field, so an abbreviated version was filed there and this full statement was sent along via snail mail:
The People’s Organization of Community Acupuncture stands in solid opposition to the First Professional Doctorate. It’s true that the new revised standards include many refinements designed to expand graduate preparation for work in integrative care settings and communication with professionals in other disciplines. However, the very fact that the FPD is being considered yet again by ACAOM, even in the face of a clear lack of consensus among stakeholders, reflects a failure to deal meaningfully with the central objection put forward during the last round by those of us in opposition, and that objection is that the doctoral level is an inappropriate entry point to the profession, regardless of how much quality material gets packed into a program.
Let us be absolutely clear. POCA has no objection whatever to the development of a rigorous and appropriate doctoral pathway for advanced practitioners of Chinese medicine. Although the primary emphasis of POCA’s work lies in other areas, we support the growth and sustainability of the profession in a diversity of forms. Our objection lies solely in the insistence on making the doctoral level a pathway for entry into the profession instead of a mark of advanced academic achievement undertaken after significant experience in the real clinical world.
The disastrous economic numbers put forward in recent years by the NCCAOM and others make it more than clear that our practitioners, taken as a group, are not doing well. Mainstream healthcare institutions, despite their growing interest in acupuncture, are not looking to us, but rather are showing an increasing inclination to train their own people to incorporate acupuncture in ways that fit their own needs. We realize that the FPD is sincerely regarded by some proponents as an attempt to address this issue, but the argument that the simple addition of a year of extra didactic training will make graduates more acceptable to mainstream healthcare seems at this point to represent the unfortunate triumph of hope and enthusiasm over dreary experience. Our graduates are already leaving school with crushing student loan debt and almost no options for work in the field besides private practice. And yet, certain forces among the schools see adding even more schooling, and hence more cost, as the way out of the dilemma, even though there is no demonstrably greater demand in the marketplace for acupuncturists entering the field with “doctor” in front of their names than there is for the existing body of practitioners. The FPD could well be of benefit to the schools who offer such programs, but there is little solid evidence that it will be of any increased benefit to the practitioners who need places to practice, and more importantly, to the huge percentage of patients who need our services and can’t afford them.
POCA has yet to be convinced that there is anything viable about the FPD for patients, practitioners or future students, and is firmly opposed to any further exploration of the FPD as a viable pathway for advancing the profession.