The letter, submitted by CAN board member Andy Wegman, reads, in part:
1. In its Resolution on First Professional Doctoral Standards issued February 9th, 2008, ACAOM stated "...there is currently insufficient evidence of consensus within the acupuncture and Oriental communities of interest...to warrant implementing a first-professional doctorate as entry-level into the profession". The resolution went on to state "Be it resolved that once consensus is reached within the profession, the Commission will renew its efforts to develop and subsequently pilot standards, policies and procedures for first-professional doctoral programs in AOM as entry-level into the profession." Regarding this decision, ACAOM declared in ACAOM Second Resolution on First-Professional Doctoral Standards issued in August of 2009, "the Commission voted to place the further development of FPD standards on hold pending stronger evidence of consensus among the profession's stakeholders for accrediting FPD programs." It goes on to state "Based on comments received from a number of stakeholders in response to the Commission-adopted resolution, ACAOM adopted a motion at its summer 2009 meeting to continue the comment period for seeking information and consensus regarding the first professional doctorate until January 15th, 2010."
Specifically, what comments and from which stakeholders constituted "stronger evidence of consensus" for ACAOM to reopen the comment period as declared in ACAOM Second Resolution on First-Professional Doctoral Standards? ... How did ACAOM deem these "communications" as sufficient and what were these communications? Specifically, what evidence did AAAOM present? On what basis did ACAOM deem these "communications" as sufficient to reopen the FPD comment period? What new evidence was presented? ...
2. The second part of our complaint regards ACAOM's overturning of its own February 2008 resolution: "Be it resolved that once consensus is reached within the profession, the Commission will renew its efforts to develop...standards." After the comment period was re-opened without explanation and without any visible process to achieve consensus within the profession, the ACAOM declared in February 2010 that it "is satisfied that there is sufficient support to justify the further development of first-professional doctoral standards." The ACAOM does not claim to have found consensus or to be consistent with its own resolution; it has simply abandoned its previous standards entirely. ... By overturning the 2008 resolution in the middle of the doctoral standards process and without explanation, ACAOM violates the public trust. Either the 2008 resolution was not reliable or in 2010, ACAOM moved the goalposts. Taking our summation as correct, we'd like to know why.
3. The third part of our complaint regards the nature of the data ACAOM received during the comment period following the ACAOM Second Resolution on First-Professional Doctoral Standards. ... We challenge the notion that the information gathered during the comment period constitutes a "significant percentage of all AOM practitioners in the US" and demand that ACAOM defend this assertion. We want to see the numbers broken down, relative to the nearly 30,000 practitioners currently licensed in the US. ...
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