A new accrediting organization for the Oriental medicine profession was announced at the annual meeting of the Council of Acupuncture and Oriental Medicine Associations in Las Vegas, Nevada on December 8, 2002.
Led by Ted Priebe, LAc, OMD, the National Oriental Medicine Accreditation Agency (NOMAA) will take on the task of accrediting educational institutions that offer entry-level, professional doctoral degree programs in Oriental medicine, acupuncture and herbal medicine.
According to Dr. Priebe, the NOMAA began in the early-to-mid 1990s, based in part on the successful establishment of the National Board of Acupuncture Orthopedics in 1989. It adopted the NOMAA moniker in 1999, and was formally incorporated as a non-profit, public-benefit corporation in California in May 2002.
Although the NOMAA has been in existence for less than a year, it has already made great strides toward strengthening the profession. The agency completed an accreditation handbook for doctor of Oriental medicine programs last year, and has requested further participation and support from the profession. It is also in the process of applying for national recognition by the U.S. Department of Education (DoE). Once recognized by the DoE, NOMAA-accredited institutions will be eligible to participate in federal programs, including student loan programs.
What effect will a second accrediting agency have on the profession? To learn more about the organization, Acupuncture Today contacted Dr. Priebe at his office in Torrance, California.
Acupuncture Today (AT): Good morning, Dr. Priebe. Tell us a little bit about NOMAA. What is its relationship to ACAOM?
Ted Priebe (TP): NOMAA started as an ad-hoc accreditation committee. It changed its name to the National Oriental Medicine Accreditation Agency in 1999, and the members of the then newly-formed National Guild for Acupuncture and Oriental Medicine AFL-CIO took on the role of working with institutions and the profession to establish institutional and programmatic criteria for a professional doctor of Oriental medicine (OMD) degree. These degrees were offered by institutions and approved by the Bureau of Private Postsecondary and Vocational Education (BPPVE) in California prior to any accrediting organization being recognized for acupuncture and Oriental medicine.
To this date, an accredited OMD degree has not been developed or offered by the Accreditation Commission for Acupuncture and Oriental Medicine (ACAOM) or the Council of Colleges of Acupuncture and Oriental Medicine (CCAOM) to meet the needs of current law, or public safety and welfare in states where acupuncturists are primary care providers, or independent providers such as California, Florida, New Mexico, etc. NOMAA's mission is to provide accreditation for educational institutions that will offer entry-level, doctoral degree programs in Oriental medicine - and acupuncture and herbal medicine - designed to prepare students for professional, independent and primary care practice within the scope of each state's scope of practice regulations.
NOMAA was incorporated last May. We are preparing and intend to apply for recognition by the U.S. Secretary of Education in compliance with the Criteria for Secretarial Recognition (34 CFR Part 602); there is no approval process for curriculum. I'm not at liberty to name which institutions are in process due to confidentiality agreements, but specific key representatives of the profession and government were notified of our mission and purposes several months ago.
AT: The accreditation commission has already approved doctoral degree programs at Bastyr University and the Oregon College of Oriental Medicine. How and why will schools want to use NOMAA's program and accreditation?
TP: NOMAA does not seek to compete unfairly with other accrediting organizations, particularly other accrediting agencies for acupuncture and Oriental medicine, or regional agencies. It is a prerogative of the educational process for an institution to voluntarily select the inherent quality control and consumer protection processes provided via accrediting.
Institutions may be accredited by more than one agency. For example, an institution may be accredited by the NOMAA for the programmatic criteria for the professional OMD degree, while at the same time having institutional accreditation by the Western Association of Schools and Colleges (WASC) Accrediting Commission for Senior Colleges and Universities. Other institutions may be accredited by another acupuncture and Oriental medicine accrediting commission for a master's level degree, but seek NOMAA accreditation for a professional OMD degree.
NOMAA's accreditation standards were developed in collaboration with potential candidate institutions with critical input from the profession to address the growing public need for higher standards of practice for a physiologically-based program in Oriental medicine, which have not previously been adequately addressed. These standards provide training that is consistent with the known physiological basis of Oriental and Western medicine with evidence-based teaching methodologies. Resultant competencies will allow entry-level practitioners to work in private practice, or to work collaboratively within the established Western medical system. The range of specific emphasis on standards and professional development ultimately enables the patient, the forgotten stakeholder, to have broader choice. In that spirit, NOMAA has been formed.
AT: How does NOMAA's program differ from what is currently taught in most acupuncture schools?
TP: The following will describe the fundamental difference in NOMAA's educational mission of integrating Oriental medicine into the Western medical mainstream. The authentic theories and practices of Chinese medicine are consistent with the present understanding of human physiology. "Oriental medicine" is used to describe the primary care medicine practiced in China, Korea, and Japan over the past three millennia to treat every known disease affecting the human population, and has been a major part of world medicine longer than any other continuous medical practice. Oriental medicine meets fundamental, scientific requirements for medicine in that it is evidence-based; is explainable via physiological mechanisms; and has a clinical practice consistent with its historic, theoretical, physiological, and experimental foundations.
Concepts of acupuncture and Oriental medicine are often taught in the U.S. and Europe as being based on energy circulation through meridians. The French energetic meridian theory was developed and promoted by Soulie de Morant in the 1930s, who taught acupuncture to physicians and lay people in France. He promoted the idea that Chinese medicine did not require an understanding of anatomy and physiology. He translated the Chinese character "qi" (vital air) as "energy," an incorrect and incomplete translation of Chinese medical text. This view characterizes Oriental medicine as metaphysical qi cultivation and energetics instead of being science-based, provoking criticism over the years by the established scientific and Oriental and Western medical professions.
AT: How will this difference benefit practitioners and students?
TP: NOMAA offers accreditation for a professional OMD degree to meet the needs of current law, public safety and welfare in 28 states where acupuncturists are considered primary care providers or independent providers.
AT: Why would an acupuncturist go back to school when he or she could practice with the current master's entry license or certification in most states?
TP: NOMAA's mission is to provide requirements, standards, programmatic criteria, and processes for the accreditation of qualified institutions to enable these institutions to establish eligibility to participate in programs administered by the U.S. Secretary of Education or by other federal agencies. Graduation from a NOMAA-accredited institution serves as qualification for national OMD licensing examination by successful completion of steps one and two of the National Oriental Medical Licensing Examination (NOMLE) administered by the National Oriental Medical Examination Agency (NOMEA), an independent agency currently being developed by the profession.
In states that do not license Oriental medicine practice, approval will be sought to accept the NOMLE to permit such practice. NOMLE test scores and supporting verification of training will be provided to these states as well. Each institution that receives NOMAA accreditation or preaccreditation becomes a member of the National Oriental Medical College Association (NOMCA). The purpose of this organization is to preserve and promote the primary care education standards for training in Oriental medicine and the OMD degree. The NOMCA also maintains awareness of the growing public health care needs, and to promote the development and implementation of Oriental medical programs, research, and health care delivery to address those needs.
AT: How will currently licensed or certified practitioners be able to obtain the OMD degree?
TP: Graduates with a master's degree in acupuncture and Oriental medicine with less than five years experience need to have a minimum of 2,800 hours training, including herbal medicine and biomedical courses, and will be required to complete a full one-year clerkship program (1,200 hours) to sit for the step two NOMLE. Previous graduates and licensed practitioners with more than five years experience who completed their "makeup" classes, including herbal medicine and biomedical courses, need to have a minimum of 2,800 hours, including a maximum credit of 20 percent of the makeup hours for continuing education courses and advanced courses taught. This category of licensed practitioner then needs to complete a 600-hour minimum comprehensive clerkship program to verify clinical skills and competencies to qualify for taking the step two NOMLE.
AT: Are there any options for practitioners to be "grandfathered" to get a degree based on experience?
TP: There is no provision for grandfathering an accredited degree. However, some states have granted "titles" to provide transitional uniformity as attrition occurs. Practitioners who currently have OMD degrees may apply and sit for the NOMLE exam. However, they will not be conferred a degree upon successfully passing. Only those students graduating from an accredited institutional program would receive a degree.
AT: Some providers might not agree with this approach. What would be your response to those people?
TP: Although a postsecondary institution must be well managed and remain solvent, education is not primarily a business or an industry. Colleges and universities are established to serve society. They're not political institutions. It's not a religion or a church. An educational institution has as a first concern knowledge, evidence, and truth. This concern should not be undermined by particular judgments of institutional benefactors, public or social pressure groups, or religious or political groups, except in the case of religious institutions or seminaries.
It has become very clear that there is a distinct and compelling difference in understanding the authentic history and role that Chinese medicine and Chinese medicine practitioners play in integrating this medical model into Western culture. The difference in the explanation and language between these two medical models (Chinese and Western) created a problem not only in interpretation of Chinese physiology and pathology, but utilization and appropriate referral. In those states where acupuncturists are licensed as primary health care providers without the need for prior diagnosis or referral, the urgency to communicate added a larger dimension of responsibility. Disease conditions and processes must be expressed in common and biomedical terms to improve communication with patients, other Oriental medical practitioners, Western medical practitioners, researchers, and the public, to promote the general understanding and acceptance of Oriental medicine.
This addition to education promotes scholarship and research into the historic bases of Oriental medicine and modern biomedical research, including clinical outcomes studies, to improve the application of Oriental medicine, in order to assure greater public access to competently trained practitioners of Oriental medicine, and improve the overall medical care system of the United States.
AT: You mentioned medical care in your last comment. What of the people reading this who may think NOMAA is trying to turn acupuncturists into medical doctors?
TP: Let me use California law as an example of what we think the role of a licensed primary care acupuncturist should be.
Section 4926 of the California Business & Profession Code states, in part, "The purpose of this article is to encourage the more effective utilization of the skills of acupuncturists by California citizens during a holistic approach to health and to remove the existing legal restraints, which are an unnecessary hindrance to the more effective provision of health care services. Also, as it affects the public health, safety, and welfare, there is a necessity that individuals practicing acupuncture be subject to regulation and control as a primary health care profession."
Section 3209.3 of the California Labor Code, meanwhile, says that all providers listed as "physicians" - including acupuncturists - must provide "complete, accurate, uniform, and replicable evaluations, the procedures shall require an evaluation of anatomical loss, functional loss, and the presence of physical complaints to be supported, to the extent feasible, by medical findings based on standardized examinations and testing techniques generally accepted by the medical community."
In November 1999, the California Department of Consumer Affairs published a memorandum regarding primary health care. The memorandum stated, "Primary care provider means a person responsible for coordinating and providing primary care to members, within the scope of their license to practice, for initiating referrals and for maintaining continuity of care."
These laws and regulations require licensed acupuncturists to evaluate patients using professionally recognized standards and medically-based criteria, such as physical exams, consultations, rendering a Western-based diagnosis, and performing x-rays and lab tests, necessary for diagnosis and referral. They also provide clearly-defined roles and responsibilities regarding patient evaluation and referral, and application of treatment modalities authorized within the scope of practice of a licensed acupuncturist. This in no way infringes on the role and responsibility of medical doctors, no does it authorize the prescription of drugs or surgery by licensed acupuncturists.
This and other evidence has led us to conclude that ACAOM and CCAOM have declined to pursue authentic Chinese medicine primary care educational standards as required by law, and have opted for a French energetic theory as referenced in their eligibility requirements for accreditation. This has resulted in a division of modalities that created master's degree technicians for states that do not designate acupuncturists as primary care providers or independent providers.
AT: Any last comments you'd like to share?
TP: For example, take a state such as Illinois, where acupuncturists may practice if they pass the NCCAOM's certification exam (which is not recognized for primary care licensure in California) and only treat a patient if that patient is previously diagnosed and referred by a medical doctor who also directs the type and duration of treatment. I could discuss these issues at further length, but I think I've covered everything for now.
AT: Thank you, Dr. Priebe.
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