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Arguments For Going Beyond 3,000 Hours

Little Hover Commission 2004

Regulation of Acupuncture: A Complementary Therapy Framework

In raising the educational standard to 3,000 hours, the Legislature also opened the door to an even higher standard by asking the Commission to assess the need for 4,000 hours for acupuncturists to "fully and effectively provide health services under their scope of practice."

Some proponents argue that an even greater increase in training is necessitated by patient safety issues, including lack of knowledge of "red flag" medical conditions, first-aid and CPR, herb-drug interactions and communicating with Western providers.72

But the persistent argument for raising the standards to 4,000 hours is based more on the comparison with biomedical practitioners than what is needed to safely practice acupuncture. The Acupuncture Board told the Commission: "The board's goal is to ensure an acupuncturist possesses a level of education that is consistent with levels of education for other primary health care professions in the United States."73

However, the goal of parity in terms of educational standards assumes that the skills, knowledge and abilities of being a medical doctor require the same "hours" of education as the skills, knowledge and abilities of being a chiropractor, a podiatrist or an acupuncturist. As established earlier, education requirements are one tool to prepare practitioners to serve at an entry-level capacity within their own scope of practice. The purpose of educational standards, from a regulatory standpoint, should not be to enhance professional standing.

A former deputy director of the Department of Consumer Affairs and former executive officer of the Acupuncture Committee told the Commission: "State regulation and a rise in educational hours should be mandated only when there is a need to protect consumers."74

Still, some professional organizations assert that educational standards should be raised as a way to elevate the profession's standing in the health care world. For example, the president of the Council of Acupuncture and Oriental Medicine Associations wrote: "The professionals in the field of Chinese medicine proposed AB 1943 to increase the education level to 4,000 hours and a doctoral entry level of Oriental medicine. It is hoped that the professional level of acupuncturists can be elevated through the establishment of doctoral degree education which will meet the public demand, to confirm the primary care provider status, so that we can apply our skills in gaining acceptance by the insurance industry and serve the people of California."75

In responding to a questionnaire from the Commission, a number of professional advocates expressed that the 3,000-hour requirement would resolve many of the preparation-related concerns. Still, they advocated for higher requirements.76

Some professionals seeking to use the title "doctor" said the additional hours would justify that privilege. Others suggested a need to increase hours to create programs equivalent to education in China. A University of Arizona analysis of the Chinese traditional medicine programs, however, states that the average number of education hours for traditional-Oriental-medicine-only is 1,775 didactic and 1,008 supervised clinical hours, totaling 2,783.77 The education and regulation in other countries is discussed more fully later in this section.

In addition to the parity goal, acupuncturists assert that new practitioners are not prepared to run businesses and some have suggested those skills should be included in an expanded curriculum. While those skills may be desirable for those intending to practice independently, they are not related to the health and safety of patients and so should not be required by regulation.

Finally, the board stated: "The profession of acupuncture and Oriental medicine must be able to adapt its educational standards to the ever-changing dynamics of science and technology applicable to the practice." But this standard also is difficult and likely inappropriate for preparing practitioners to practice a healing art that is not based in Western science.



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