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Acupuncture Today – September, 2006, Vol. 07, Issue 09

USDE Report Stalls NOMAA Approval Process

Numerous Violations Cause Organization to Postpone Review Hearing

By Stephane Babcock

Since being established as a nonprofit organization in May 2002, the National Oriental Medicine Accreditation Agency (NOMAA) has worked toward developing institutional and programmatic criteria for a professional doctor of Oriental medicine (OMD) degree.1 However, after receiving a 70-page staff analysis from the U.S.

Department of Education (USDE) outlining noncompliancy issues, NOMAA delayed its June 6 hearing with the National Advisory Committee on Institutional Quality and Integrity (NACIQI) for review for initial recognition.

"NOMAA withdrew its initial petition for recognition on June 6, 2006," stated Ted Priebe, LAc, OMD, chief executive officer of the NOMAA. "Specific 602 Criteria cited by the Department relate to compliance issues with organizational structure, financing, documentation and conflict-of-interest policies which need to be addressed prior to resubmitting."

A page on the NOMAA Web site as of June 6 stated, "NOMAA has, with the recommendation of the U.S. Department of Education, postponed review by the National Advisory Committee on Institutional Quality and Integrity for initial recognition on June 6, 2006. ... The decision was due to unavailability of Staff support from the U.S. Department of Education in completing criteria supporting NOMAA's petition, as five Staff members left the Agency over the past year." While researching this article, Acupuncture Today received a copy of the Web page in question, which has since been removed from the organization's Web site.

"Department staff advised representatives of NOMAA that there remained a number of areas of non-compliance in their petition and it would be impossible to go forward with a positive staff recommendation for recognition until additional corrections were implemented," stated John Barth, USDE director, accreditation and state liaison. "Based on this discussion, NOMAA requested that its petition be removed from the agenda for consideration at the June 2006 NACIQI meeting. During a meeting with NOMAA representatives, Department staff informed them that we were aware of the Web page statement and felt that it was misleading. NOMAA agreed to remove the statement from its Web page."

The USDE report listed 46 violations that must be corrected before NOMAA can meet the requirements for recognition. "It is not unusual for an agency seeking initial recognition to have a number of problems or areas of noncompliance," said Barth. "The agency, working with Department staff, is usually able to correct these issues over time."

Some of the compliance issues listed in the report included a need to demonstrate adequate funding, an explanation in regards to the conflict of interest concerns noted, more organization when it comes to the filing system used and sufficient policies and procedures in place for the maintenance of accreditation files, as well as evidence that the curriculum standards are the result of consultation and input from the broader profession in the U.S., and they are based on accepted methods within the Oriental medicine profession.2

National acupuncture organizations, such as the American Association of Oriental Medicine (AAOM) and the Council of Acupuncture and Oriental Medicine Associations (CAOMA), are divided on their support for NOMAA.

"The AAOM does not support the NOMAA application," responded AAOM President Will Morris, OMD, MSEd, LAc, in a recent e-mail interview with Acupuncture Today. "Having two accrediting agencies is a waste of resources and potentially very confusing for the public. Those professions who do maintain more than one accrediting body often have trouble achieving legislative goals due to the confusion. No school can be accredited by ACAOM and also be accredited by another accrediting agency for acupuncture and oriental medicine."

But, according to the USDE, dual accreditation of an institution is only prohibited by the regulations governing the Federal Student Aid program, which also has an exception. "If the institution provides the Secretary with an acceptable good-cause justification for dual accreditation, the Secretary may find it acceptable," stated Barth.

Once recognized by the USDE as an accrediting agency, NOMAA-accredited institutions will be able to participate in the Federal loan programs and can more easily maintain certification to participate in the Student Exchange and Visitor Information System (SEVIS) programs.2

In a letter to the USDE dated June 29, 2005, CAOMA Executive Director Brian Fennen endorsed NOMAA and its mission to set standards for its OMD degree program. "The NOMAA doctorate program is the only Oriental medicine training program developed from the expert recommendations and opinions of professional teachers and clinicians ... [and] has incorporated the highest existing standards of education in our field, as set by the states of California and Nevada, to assure that their program would easily meet and exceed the training standards set by every state in the United States."3

According to Dr. Priebe, the 4,000-hour doctorate program would take a different approach to the study of acupuncture and Oriental medicine. "NOMAA is the first accreditation body to offer programmatic criteria that is anatomically and physiologically based consistent with the historic foundations, theory, and practice of Chinese/Oriental medicine," said Priebe. "This seems to be a dramatic paradigm shift from the popular but impossible idea of Chinese medicine being based on energy and blood circulating by means of invisible meridians. Chinese/Oriental medicine represents a totally rational system that can be clearly articulated in modern physiological and biomedical terms."

Some feel NOMAA has been reluctant to open its accrediting process for review, one of the reasons AAOM President Emeritus, Gene Bruno, chose not to give NOMAA the AAOM's support in a response letter sent to Ted Priebe on Jan. 26, 2004. "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," stated Bruno in the letter.4

"The AAOM is committed to the development of the first professional doctorate standards," said Morris. "As such, we believe that we are engaged in a fully transparent process with ACAOM to achieve that goal."

NOMAA currently is working closely with the USDE to rectify the noncompliancy issues for the next scheduled hearing with the NACIQI in December of this year. According to the USDE, NOMAA has continued to provide additional information and amendments to its petition. Acupuncture Today will report on developments in NOMAA's recognition process as they occur.


  1. "New Accrediting Body Formed." Acupuncture Today, April 2003.
  2. U.S. Department of Education Staff Report to the National Advisory Committee on Institutional Quality and Integrity, 2006.
  3. Letter from CAOMA Executive Director Brian Fennen to U.S. Department of Education, June 29, 2005.
  4. Letter from Gene Bruno to Ted Priebe, Jan. 26, 2004.
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