Last week, some of our comrades in Utah received this letter from the Utah Association of Acupuncture and Oriental Medicine, courtesy of the NCCAOM:
Dear Utah Licensed Practitioner,
Recently the Utah Acupuncture Licensing Board voted on a rule proposal that would clarify existing statute, and would further require the passage of all four components of the NCCAOM exams for licensure for new licensure applicants. This would add the NCCAOM herbal examination as a requirement for all new license applicants, enhancing educational requirements and ensuring public safety. Since the use of Chinese medicinal herbs currently falls within our scope of practice, it was felt that knowledge of the use of and principles related to herbal medicine would result in the creation of better practitioners. Even those not currently using herbs in their practices would benefit from the increased knowledge and public safety would be increased.
The proposal would grandfather in all existing licensees, and further allow those already licensed in other states only in acupuncture prior to the rule taking effect to practice here in Utah. In fairness to candidates anticipating 2018 graduation, the change would be rolled out over a reasonable period of time(yet to be determined by DOPL but perhaps about one year), to allow ample time for the adjustment. This rule change was initiated to insure the highest standards of educational requirements in order to further ensure public safety and that citizens of our state were getting the highest quality of care. There are a number of other states who have taken similar steps to ensure public safety and it appears to be a growing trend in the profession as it further protects our scope to practice Chinese herbs.
The Acupuncture Licensure Board of the Division of Professional Licensing, as well as the Board of Directors of the Utah Association of Acupuncture and Oriental Medicine voted by majority to move forward with this proposal to the next meeting scheduled for February 20. The NCCAOM also supports the proposed rule change.
Chinese herbal medicine and acupuncture have always been inextricably linked, and this rule would further ensure the competence of even those acupuncturists not necessarily practicing herbs, by increasing educational requirements and knowledge. As you are well aware, improper use of medicinal herbs can have potentially dangerous consequences if not used by trained professionals. Our aim is for increased public safety through higher educational and examination requirements.
That being said, we would like to reiterate that we are not insisting or even encouraging that other practitioners use Chinese herbs, only that new licensees are able to demonstrate the knowledge base necessary to ensure Public Safety.
As Chinese herbal medicine becomes more popular in consumer use, it is important for licensed acupuncturists to educate and inform the public that our training and credentials ensure that we are the most qualified to practice Chinese herbs. We are seeking your support of this rule change. We will be developing a fact sheet with answers to questions shortly.
I'm hoping that the upcoming fact sheet will include the following facts:
There are 61 acupuncture schools in the United States. Of those, 23 schools offer a Master of Acupuncture option (which does not require herbal training), as well as a Master of Oriental Medicine option. Eight other schools offer only a Master of Acupuncture (no Master of Oriental Medicine). Thus, 31 schools–over half of the schools in the country–offer an acupuncture-only degree as an option for students.
Only six states require the NCCAOM Chinese Herbology exam of all practitioners. Five other states require the Chinese Herbology exam only if the practitioner wishes to practice herbal medicine; those states have created acupuncture-only licensure option, with Chinese herbology being a second option. The vast majority of states do not require the Chinese Herbology exam at all. The NCCAOM's 2016 annual report (see page 14) indicates that the number of Chinese Herbology exams being administered is less than half of the number of the other modules.
Neither requiring the NCCAOM Chinese Herbology exam, nor requiring students to study Chinese Herbology as part of their acupuncture education (which in turn is required in order to sit for the NCCAOM exam) is a growing trend in the profession. If anything, it's the other way around: more acupuncture schools are creating opportunities for students to study acupuncture alone, in order to decrease the overwhelming student loan burden that most graduates face.
And as for the idea that Chinese herbal medicine and acupuncture have always been inextricably linked…the facts are that it's a lot more complicated than that.
In his book What is Medicine? Western and Eastern Approaches to Healing, Paul Unschuld writes,
“Most Westerners today consider acupuncture to be a core aspect of Chinese medicine — though this is historically not entirely correct. Acupuncture was, in antiquity and for a thousand years up to the twelfth or thirteenth century, the only therapeutic procedure in Chinese medicine. Pharmaceutics (herbs) remained a nonmedical therapeutics, free of theory. Beginning in the twelfth or thirteenth century, pharmacy was included in medical therapeutics — and competed with acupuncture.” (pg 145-146)
By 1754, Unschuld adds, a renowned acupuncture physician, Xu Dachun, was complaining that acupuncture was being forgotten and no longer practiced; by 1822, acupuncture was banned in China. (pg 148). (Herbs weren't.)
In his thesis and ethnography, American Chinese Medicine (pgs 191-192), Tyler Phan Ph.D. writes,
“…it was not until systematization of TCM in the 1950s when acupuncture and herbs were combined, especially through the construction of Outlines of Chinese Medicine (Scheid,2002, p. 217). Giovanni Maciocia also explains,
One thing I would say is the fact that acupuncturists [in California] have to study herbal medicine and as you know in China, you don’t have to. You don’t have to and there is no reason whatsoever why as an acupuncturist. And of course every acupuncturist knows the main picked remedies. They would know . . . But you don’t need to know a detailed study of herbal medicine if you want to be an acupuncturist (G. Maciocia, Personal communication, July 15, 2015)”
Tyler goes on to point out that JR Worsley, founder of Five Element Acupuncture, was actively opposed to the use of herbal medicine (pg 210, ACM) and many Five Element acupuncturists still don't use Chinese herbs.
There’s also the fact that Chinese herbal medicine can be bought, sold, and provided by any layperson, because unlike acupuncture, it isn’t subject to any kind of regulation. I would like to see some facts in the form of documentation of adverse Chinese herbal events as the result of prescriptions from licensed acupuncturists, to justify regulating them further. In the absence of data about negative effects on public safety, requiring the NCCAOM Chinese Herbology exam in order to get an acupuncture license is a purely anti-competitive maneuver. It's designed not to increase public safety but to restrict consumer access and choice, in the form of limiting the number of licensed acupuncturists available to provide treatment, and restricting the type of education for prospective acupuncture students to a more expensive kind.
Comrades? Any other helpful facts you’d like to add?