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Policy Considerations

Little Hover Commission 2004

Regulation of Acupuncture: A Complementary Therapy Framework

Whether California should continue to have a unique examination has been a contentious issue. Among the concerns:

Profession-wide standards. Many professionals advocate for establishing one standard examination used nationwide, which like other health professions, allows for reciprocity within the United States. But some California acupuncture associations, especially those advocating for blending the practices of Western and Eastern medicine, are opposed to national standards and testing. To the degree that the NCCAOM exam does not test Western science and practices, the California professional organizations are concerned that it does not comport with the direction that they are attempting to move the profession.

Certification vs. Licensing. Some have stated that using the NCCAOM examination would be a lower standard because it is a certification, not a licensing examination. While licensing examinations test minimum skills, knowledge and abilities, certification examinations are often used by professions to indicate advanced specialized knowledge, skills and abilities. The independent analysis pointed out that many respected professions, such as Certified Public Accountants, have adopted this approach. Within professions, building expertise can be indicated by receiving advanced certificates of achievement on specific topic areas.

Modularity. NCCAOM's modular approach to examination of acupuncture, herbs and body work, accommodates variation among state regulations but is objectionable to those in California who believe these modalities should not be practiced separately. They assert that the modular approach is inconsistent with the idea that practitioners should be comprehensive providers. However, NCCAOM is instituting an additional examination of traditional Oriental medicine that may allay those concerns. In addition, the independent analysis notes that the national examination for medicine uses a phased, modular approach, and that "must-pass" modules are particularly useful for matters of health, safety and ethics.

Costs. The fees for taking the NCCAOM examinations are higher than for taking the California examination. It is estimated that 50 percent of California practitioners voluntarily take both examinations to have the option to practice nationally. Some have questioned why the modules of the national examination cost approximately $2,000, while the California exam fee is significantly less, at $550. Whether the California fees cover the full cost of the examination, or whether the lower cost of the California examination is subsidized by detracting from funds available for other board activities, such as enforcement, should be determined. If there is a subsidy, the California fee should be raised.



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