Since the publication of those letters, the AAOM has issued a followup response that reasserts its stance toward NOMAA and the reasons it has decided not to support the agency.
January 26, 2004
Ted Priebe, LAc, OMD CEO, NOMAA
Dear Dr. Priebe:
AAOM has reviewed your January 20, 2004 letter in response to AAOM's position urging that the profession withhold support for the National Oriental Medicine Accrediting Agency ("NOMAA"). Based on that review, we find no reason to change our public position on NOMAA's request for support.
Although your letter asserts that AAOM's positions with respect to NOMAA "seem mean-spirited," we see nothing "mean-spirited" about responding to NOMAA's request of AAOM to render an honest and factual opinion on NOMAA's intent to establish itself as a national accreditation agency for acupuncture and Oriental medicine. As the largest and most well-established national professional organization in the U.S. representing the interests of practitioners, it is AAOM's responsibility to speak out and provide leadership for the profession when we reasonably believe that a major initiative is not in the best interests of the profession at large.
There are several reasons why we continue to believe that the profession should not support NOMAA.
1. NOMAA has apparently developed its accreditation process in secret, without permitting the vast majority of the profession's various stakeholders to provide input into NOMAA's development. Although in your April 2003 interview with Acupuncture Today, you asserted that "NOMAA's accreditation standards were developed in collaboration with potential candidate institutions with critical input from the profession," in fact, few if any state professional organizations, national organizations, practitioners, educators, students or regulatory boards were provided any opportunity to provide input as NOMAA's standards and accreditation processes were developed. While your letter states that "NOMAA does not operate behind closed doors," and that NOMAA has held a "series of public meetings" with the profession and school representatives on NOMAA's development, to the best of our knowledge these meetings where actual standards and policies were discussed were not, in fact, public. As best we can determine, the profession received no public calls for comment from NOMAA, and no appropriate publicly noticed hearings on NOMAA's development were held.
At CAOMA's board meeting in December 2002, three AAOM board members were in fact present when you made your "announcement" and gave a brief report on NOMAA. At no time during that meeting did you either discuss NOMAA's standards and procedures, or distribute copies of the same for review by those in attendance. You also state that "Michelle Lau, one of the AAOM's vice presidents, has continued to attend a series of public meetings we have held with the profession and school representatives." By this and other statements, you imply that AAOM had previous knowledge and in some way gave approval to NOMAA. This implication is false. What you fail to mention is that Michele Lau did this as an individual, and in no way as a member of the AAOM Board of Directors nor as a representative of the AAOM. You also fail to mention that Michelle Lau has signed one of NOMAA's confidentiality agreements, so she does not have the liberty to discuss any of her private conversations regarding NOMAA with anyone outside the NOMAA secret circle.
It is this kind of misrepresentation of facts that we find in your correspondences which further discourages us from any kind of support for NOMAA. We can only conclude that NOMAA preselected those who would attend meetings on NOMAA's development, and denied all of the profession's many other stakeholders an opportunity to provide input.
2. To date, NOMAA has concealed its standards, policies and procedures from most within the profession, and has refused to make those materials public. Contrary to well-established accreditation practices, NOMAA has inappropriately required individuals and groups who wish to review NOMAA materials to sign "confidentiality agreements." While your letter asserts that AAOM could have signed a confidentiality agreement to receive NOMAA materials, your response to AAOM's requests for information had consistently been that NOMAA material "is not available for [AAOM] review." So your assertion that this "confidentiality" agreement is and was available to AAOM is not true. NOMAA has never, to date, sent AAOM a "confidentiality agreement."
NOMAA finally did submit NOMAA's materials, only after AAOM forwarded its letter to you outlining our position to withhold support of NOMAA, and what we received were not complete accreditation standards, policies and procedures at all. Rather, what we received were NOMAA's mission, a general accreditation process outline, and a very rough curriculum outline (described further in point #3 of this letter), which provide, in our opinion, an inadequate basis for assessing whether the profession should endorse and support NOMAA. We want to be clear about the issue of NOMAA developing its standards, policies and procedures in secret, and how the profession views this. Even if the standards were complete (which, to date, they are not), the fact that NOMAA developed them in private is reason alone for the profession to reject NOMAA.
3. Complete accreditation standards still have not been made public. Although your letter states that NOMAA's accreditation standards are now published on its Web site, we have reviewed that site, and what you assert are "accreditation standards" are not, in fact, complete accreditation standards. Rather, they represent a rough curriculum outline of topics in Oriental medicine, with a list of hours required under those topics, with nothing more. No standards were provided for appropriate institutional structures (e.g., governance, administration, legal organization), learning resources including library requirements, faculty requirements, student services, financial resources, facilities, etc., and the program standards themselves are incomplete. AAOM believes that the accreditation standards published on NOMAA's Web site provide neither an appropriate nor credible basis for evaluating quality education and training in our field of medicine.
4. Your letter asserts that "there have been long-standing concerns about the appearances of conflicts of interest and inappropriate sharing of resources ... between accrediting agencies [ACAOM] and their member college organizations." The AAOM has confirmed that the U.S. Department of Education has fully evaluated ACAOM relative to its recognition standards governing conflicts of interest and has found no actual or apparent conflicts of interest on the part of that agency with respect to any other organizations in the field. Since NOMAA's Web site hosting and office administrative support are apparently provided through the Council of Acupuncture and Oriental Medicine Associations (CAOMA), a California-based umbrella organization of California practitioner associations, if conflicts of interest are a concern with respect to ACAOM, then conflicts of interest must also be a concern with respect to NOMAA's Web hosting and administrative support arrangements with CAOMA.
5. In your letter, you make the assertion that ACAOM has engaged in "foot-dragging" relative to its decision to develop standards for first-professional doctoral programs. In your letter, you stated that "... shortly after we publicly announced our formation and intentions to develop and implement first-professional doctorate standards, another accrediting agency quickly proposed to do the same thing after years of foot-dragging." The AAOM has in its possession documents that verify that as early as the summer of 1999, ACAOM's standards for postgraduate doctoral programs explicitly included a footnote reflecting ACAOM's intent to develop standards for first-professional doctoral programs. This is included in ACAOM's 1999 summer newsletter. ACAOM then formally adopted this position in the spring of 2000. So your statement in this regard is inaccurate.
6. Several inconsistencies in NOMAA materials and public statements mean that AAOM and the profession have no idea as to what NOMAA's actual standards, policies and procedures are. For example, these inconsistencies include, but are not limited to, whether admission to a NOMAA-accredited program requires two vs. three years of undergraduate education; whether the length of NOMAA-accredited programs must be 4,000 hours or 3,600 hours, etc. NOMAA's standards, policies and procedures appear to us to be a "moving target," and the lack of consistency in what little information that NOMAA has chosen to provide to the profession about its standards, policies and procedures has left AAOM and the profession unable to determine what exactly are NOMAA's requirements for accrediting doctoral programs in Oriental medicine.
For these and many other reasons, we must conclude that the secret, inappropriate and confusing process by which NOMAA was developed and continues to operate is so fatally flawed that the AAOM simply cannot support or endorse NOMAA's accreditation process. Accordingly, we must reiterate our strong recommendation that the profession and all its stakeholders, including educators, practitioners, professional organizations, regulators and others, also withhold support for NOMAA.
Gene Bruno, LAc, OMD