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Finding and Recommendation 3

Little Hover Commission 2004

Regulation of Acupuncture: A Complementary Therapy Framework

Finding 3:

The steadily increasing educational requirements for new entrants into the acupuncture profession potentially creates different levels of competency, and could confuse or mislead the public regarding the knowledge, skills and ability of those previously licensed.

Acupuncture Board regulations require practitioners to take 30 hours of continuing education every two years.4 However, when the new 3,000-hour standard goes into effect, many practicing acupuncturists will have been licensed with only 1,350 hours of training, and were licensed prior to the time that acupuncturists could practice independently of M.D.s and were allowed to make diagnoses. In addition, many of the approximately 900 acupuncturists who were initially licensed in the mid­1970s, who were "grandfathered" into licensure with no examination and undefined education requirements, will be practicing under the same scope of practice, presumably with even less formalized training.

Many of the professional organizations that advocated for higher educational standards have asserted that existing practitioners have gained, through experience or continuing education, the knowledge that will now be required before licensure. But in many professions, there is persistent concern that continuing educational regimes do not ensure that practitioners actually learn the latest knowledge, skills and abilities needed to practice safely and competently.

The University of California identified several options to address the unevenness in the education levels among practicing professionals, among them: "catch up" programs to enable practitioners to gain required competencies; test-out options that enable practitioners to demonstrate knowledge or skills in required competency areas; and, grace periods for completing a schedule of supplemental education or examinations. UCSF researchers also suggested the option of implementing differential levels of titling in licensing to reflect formal educational and career experiences.

From a public safety perspective, it is difficult to accept that new students should receive additional training on issues directed at improving patient safety without requiring current licensees to receive at least some of that training in a meaningful way. It is incumbent upon regulators to ensure that patient safety material is incorporated into the clinical practices of long-standing practitioners as well.

Recommendation 3:

The Governor and the Legislature should reallocate - and consider increasing the number of - continuing education hours required of currently licensed practitioners as a mechanism to update patient safety requirements. The law should:

  • Specify courses. The Acupuncture Board should identify the coursework necessary to keep practitioners current on "red flag" conditions, emergency procedures, emerging infectious diseases that require referral, exclusive use of single-use disposable needles, other patient safety issues, such as cancer treatment, and how to communicate effectively with Western practitioners.
  • Require examination. The State should require testing for material related to patient safety.


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