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I jotted some answers to these questions for comment before my submission.

I moved the entire scope of practice to the bottom of the page for

anyone who needs to reference it. My answers are all preceded by my name.

 

 

> Should you not have access to email, please fax your responses and send

> them to the CSOMA office. Our fax number is: 916.455.0356.

>

 

>

> Advisory Committee and Expert Questionnaire

>

> General

>

> 1. What should the State's primary concerns be in terms of protecting

> consumers of acupuncture services?

 

: public safety, definitely. Is efficacy in practice also the role

of the board. if so, they could start dictating style of practice.

medical boards have long restricted certain practices in some states, such

as herbology or " unproven " remedies. Many have lost their licenses or

have been told to cease and desist. I think the board has the right

(perhaps even responsibility) to educate consumers about what has been

proven with modern research and what hasn't. But should they be dictating

so-called " standards of care " (SOC)?

 

Is the State adequately providing the

> protection, and if not what else should be done?

 

: The state appears to be protecting safety adequately. We know

little about efficacy. I wonder if the medical board would sanction an MD

who used a treatment for a patient when another had been proven more safe

and effective?

 

>

> 2. What do you see as the most difficult acupuncture regulation policy

> issues in California today?

: herb availability for professional dispensing

 

 

>

> 6. How does the current practice of acupuncture in California affect

> access to health care by consumers?

: acupuncture remains an elite service for those who can afford to pay

 

 

>

> 7. Do you think the current legal scope of practice (see bottom of page)

for California acupuncturists is appropriate for licensed acupuncturists?

 

: What is the legal scope of practice? I gather ther eis some

dispute over the nature of our primary care status which the board needs

to clarify. Can we make western diagnoses and use the full range of

diagnosstic techniques available for this purpose (ordering MRIs, etc.) or

is our role more limited than that. I believe CSOMA believes the former

is true while CCAOM believes the latter. In fact this is one reason for

the split between this groups over the entry level DAOM and the levels of

western medical training needed to practice.

 

>

> 9. Do you believe that the current legal scope of practice is too broad?

: Many rights are apparently granted because people do these things

in their practice, yet for which there is still no formal standardized

training at most schools, such as electroacupuncture, magnet therapy,

western nutrition, use of western herbs and other dietary supplements,

ordering of lab tests, etc. I am not sure this protects public safety,

thus it goes against the most important role of the board. Either more

educational focus should be put on these subjects or they need to be

removed from the scope. I say pull them from the 2400 hour L.Ac. and

reserve such powers for the 4000 hour DAOM. Win-win. different scopes

for different folks. Hey, that could be a CHA bumper sticker. :-)

>

> 14. Do you believe that there should be graduated levels of licensure,

> for instance to have acupuncture technicians or assistants, licensed

> acupuncturists, master acupuncturists, and/or acupuncturist-M.D.s?

 

: yes indeed. It makes the most economic sense for patients and

students and schools

 

>

> 15. Please describe various levels of licensure that you believe would

> be logical and beneficial to California patients.

 

:

L.Ac. - 3 year program - no herbs

M.TCM. - 4 year program - herbs emphasized

D.6 year program with 1 full year of paid residency included

 

>

> Educational requirements generally

>

> 16. Do you believe that the current curriculum and training requirements

> for L.Ac.'s are adequate for new entrants into the field of acupuncture?

> Too narrow? Too broad?

: too much to practice effective acupuncture. too little to practice

effective herbology

 

 

>

> 17. Aside from changing the number of curriculum hours, do you have

> suggestions for changing the education and training requirements of

> acupuncturists to better serve the consumers of California?

 

: mandate the study of medical chinese for the M.Ac., if not the L.Ac.

?

 

 

>

> 18. The minimum number of curriculum hours to become a licensed

> acupuncturist has just been raised to 3000. If you believe that the

> hours should be increased further, what level do you recommend and what

> is your reasoning? What should the content of any additional hours of

> classroom or practical training include?

>

> 19. What is in the L.Ac. legal scope of practice that cannot be taught

> under the 3000-hour scheme?

: Western diagnosis. Western nutrition. use of herbs and

supplements other than chinese herbs

 

>

> 20. What could be taught to L.Ac.s with additional hours of education

> (above 3000) that would be reasonable, important and beneficial to the

> health and safety of California patients/clients?

: depends on the intepretation of the scope. I would think public

safety warranted the full scope being available only to those who can

document adequate training in each area they practice.

 

>

> Education or other requirements for already licensed acupuncturists not

> subject to new regulations for 3000 hour curriculum.

>

> 23. Is there a need to require already-licensed acupuncturists to

> demonstrate additional knowledge or competency that was not required or

> tested when they were originally licensed, but is now required for newly

> graduating students?

: only if they will be awarded a higher title like DAOM.

 

>

> 26. Do you believe that periodic re-testing or other recertification in

> which continued competence is demonstrated should be required to ensure

> quality practices throughout an acupuncturist's career?

: no, ones malpractice and complaint record should speak to that

 

>

> Examination of practitioners

>

> 27. What are the major advantages of the California exam relative to the

> national exam?

 

: it's difficulty

 

>

> 28. What are the major advantages of the national exam relative to the

> California exam?

 

: it is more fair in the acupuncture portion. the CA exam is quite

idiosyncratic

 

>

> 29. What would be the advantages of using a combination of the national

> and California exams?

 

: none

 

 

>

> 30. What would be the disadvantages of using a combination of the

> national and California exams?

 

: I have no idea what purpose this would serve except to impoverish

us all. Besides the CA board needs our money now more than ever. the

NCCAOM can get theirs elsewhere.

 

>

> 35. Which exam did you think is the better measure of the knowledge,

> skills, and abilities that an acupuncturist should have?

: they are both highly flawed. the national was way too easy, though

I heard this has changed. the CA exam is just unpredictable

>

> Accreditation

>

> 38. What are the advantages and disadvantages of continuing to use

> California's approval of school process instead of national

> accreditation of schools?

 

: blocks many out of staters from practicing here even though they

are probably quite competent. protects economic turf, but public safety

is arguable. could constitute restraint of trade if push came to shove.

 

>

> 39. What are the advantages and disadvantages of relying on national

> accreditation of schools instead of California's approval of school

process?

: the feds suck. local is always better in CA because we are more

progressive. however if you live in oklahoma, you might feel different.

 

>

> Scope of Practice

>

> The following legal scope of practice --which has been further defined

> by legal memoranda, opinions and regulation-- is contained in California

> Business & Professions Code sections 4927 and 4937:

>

> 4927. (d) " Acupuncture " means the stimulation of a certain point or

> points on or near the surface of the body by the insertion of needles to

> prevent or modify the perception of pain or to normalize physiological

> functions, including pain control, for the treatment of certain diseases

> or dysfunctions of the body and includes techniques of

> electroacupuncture, cupping and moxibustion.

>

> 4937. An acupuncturist's license authorizes the holder thereof:

> (a) To engage in the practice of acupuncture.

> (b) To perform or prescribe the use of oriental massage, acupressure,

> breathing techniques, exercise, heat, cold, magnets, nutrition, diet,

> herbs, plant, animal, and mineral products, and dietary supplements to

> promote, maintain, and restore health. Nothing in this section prohibits

> any person who does not possess an acupuncturist's license or another

> license as a healing arts practitioner from performing, or prescribing

> the use of any modality listed in this subdivision.

> © For purposes of this section, a " magnet " means a mineral or metal

> that produces a magnetic field without the application of an electric

> current.

> (d) For purposes of this section, " plant, animal, and mineral products "

> means naturally occurring substances of plant, animal, or mineral

> origin, except that it does not include synthetic compounds, controlled

> substances or dangerous drugs as defined in Sections 4021 and 4022, or a

> controlled substance listed in Chapter 2 (commencing with Section 11053)

> of Division 10 of the Health and Safety Code.

> (e) For purposes of this section, " dietary supplement " has the same

> meaning as defined in subsection (ff) of Section 321 of Title 21 of the

> United States Code, except that dietary supplement does not include

controlled substances or dangerous drugs as defined in Section 4021 or

> 4022, or a controlled substance listed in Chapter 2 (commencing with

Section 11053) of Division 10 of the Health and Safety Code.

 

 

 

Chinese Herbs

 

 

" Great spirits have always found violent opposition from mediocre

minds " -- Albert Einstein

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4927. (d) "Acupuncture" means the stimulation of a certain point or > points on or near the surface of the body

>>>>>This definition sucks. What about deep insertion

Alon

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Todd -

 

This is a serious governmental agency in the world's fifth largest economy. Do you think this form of communication enhances the perception of our professionalism? I can dig it for the colloquial nature of this forum and assume a twist of humor.

 

Will

 

: the feds suck. local is always better in CA because we are more progressive. however if you live in oklahoma, you might feel different.

 

 

William R. Morris, OMD

Secretary, AAOM

Academic Dean

Emperor's College of TOM

310-453-8383

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, WMorris116@A... wrote:

-

>

> This is a serious governmental agency in the world's fifth largest economy.

> Do you think this form of communication enhances the perception of our

> professionalism? I can dig it for the colloquial nature of this forum and

assume a

> twist of humor.

 

This was only sent to CHA as I stated in the post and if you have seen my

previous communications to boards and agencies, you know what you are

saying is not how I operate. My formal submissions are always written in a

polite tone, as you well know.

 

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