The following letters, submitted to Acupuncture Today over the course of the past few months, detail the National Oriental Medicine Accreditation Agency's (NOMAA) attempts to gain support for its organization from the American Association of Oriental Medicine (AAOM), and the AAOM's decision to withhold such support. The letters (and the replies thereto) were written by AAOM President Gene Bruno, LAc, OMD, and NOMAA chief executive officer Ted Priebe, LAc, OMD, and were provided to Acupuncture Today for examination by all members of the acupuncture and Oriental medicine profession. The background text was also written by Dr. Bruno.
Early in 2003, Ted Priebe, LAc, chief executive officer of the National Oriental Medicine Accreditation Agency (NOMAA), contacted me and asked for the AAOM's support of NOMAA. I asked him to submit NOMAA's standards, policies and procedures to the AAOM, with a formal request so that the board of directors could give his proposal the proper evaluation and consideration needed in order to provide a reply to his request. Mr. Priebe told me he could send the information within two weeks, but the information the AAOM requested was never received.
On Oct. 6, 2003, several AAOM directors received a letter by e-mail that described NOMAA's intention to provide accreditation for educational institutions that will offer entry-level doctoral degrees in Oriental medicine. In the letter, NOMAA briefly described its mission, objectives and curriculum outline. NOMAA specifically requested letters of support for NOMAA by educators and educational institutions, licensing bodies, practitioners, etc. NOMAA did not enclose its accreditation standards, policies or procedures with its request for letters of support. In an interview with Mr. Priebe published in the April 2003 issue of Acupuncture Today, Mr. Priebe stated that the NOMAA had developed its standards for the accreditation of colleges of Oriental medicine to issue entry-level doctoral degrees in Oriental medicine. To date, no copies of any accreditation standards, policies or procedures have ever been presented to the AAOM or to the vast majority of key stakeholders in the field.
I wrote Mr. Priebe again, requesting NOMAA's standards, policies and procedures. Eventually, he replied with the following letter:
Re: NOMAA Standards and Policies
Dear Gene Bruno,
The material that you have requested is not available for review. Confidentiality and non-disclosure agreements protect NOMAA's (and the institutions that NOMAA accredits) standards, policies and procedures, and any breach of those agreements NOMAA will vigorously enforce the provisions of those agreements.
NOMAA recognizes the U.S. Department of Education §602.14 Purpose and organization
"Separate and independent" requirement in §602.14(b), as well as the related requirements of §602.14(c). The related, associated, or affiliated trade association or membership organization plays no role in making or ratifying either the accrediting or policy decisions of the agency;
The NOMAA is organized exclusively for educational or scientific purposes within the meaning of Section 501 (c)(3) of the Internal Revenue Code.
NOMAA will make every effort to provide adequate answers to AAOM's questions concerning development of methods for evaluating Chinese/Oriental medical education and continuing medical education, particularly in its relationship to patient care and the continuum of medical education.
Thank you for your support.
Ted Priebe, LAc, OMD
In reply to NOMAA, AAOM sent the following letter:
December 10, 2003
Ted Priebe, LAc
Dear Ted Priebe:
I received your letter dated November 23, 2003, wherein in response to the AAOM's request for NOMAA's standards, policies and procedures, you replied, "The material that you have requested is not available for review." You go on to explain, "Confidentiality and non-disclosure agreements protect NOMAA's (and the institutions that NOMAA accredits) standards, policies and procedures."
However, you do not explain why NOMAA is trying to protect information that must be made public if NOMAA is to even apply for Department of Education recognition. At the same time, you state, "NOMAA will make every effort to provide adequate answers to AAOM's questions concerning development of methods of evaluating Chinese/Oriental medical education and continuing medical education, particularly in its relationship to patient care and the continuum of medical education." The lack of transparency we have encountered by your refusal to answer any of our questions, or to provide any of the information we have requested, is in contradiction to this statement.
In your letter, you quote the following Department of Education (USDE) regulation [§602.14(c)] governing one section of USDE's separate and independent requirement: "The related, associated, or affiliated trade association or membership organization plays no role in making or ratifying either the accrediting or policy decisions of the agency." Although your letter asserts this provision was quoted from §602.14(c), the quote is in fact from §602.14(d)2. You imply to us that this means the AAOM cannot have any input, period, but this section you quoted was taken completely out of context. This section actually permits accrediting agencies seeking to permit the students of their accredited programs to be eligible for Title IV federal financial aid to seek a waiver of the USDE's "separate and independent" requirements if they meet all of the criteria set forth in §602.14(d), including the provision which you quoted out of context in your letter.
Absent a waiver under §602.14(d), the agency would need to meet the definition of "separate and independent" under §602.14(b), which requires: independence from related trade associations and membership organizations in electing the members of an accreditation agency's board and in establishing the agency's budget; that the agency's dues and fees be paid separately from dues paid to affiliated membership organizations; that a specific number of public members be appointed to the agency's board; and that the agency adopt conflict-of-interest guidelines governing its board members.
So, this section you quoted in your letter, as if to tell us that our input was against USDE regulations, is not about input from other organizations at all, but rather focuses on the requirements for seeking a waiver from the USDE's "separate and independent" requirement for agencies that wish to permit the students of their accredited programs to be eligible for Title IV federal financial aid. I spoke directly with Cathy Sheffield, administrative assistant of the DOE's Department of Accreditation, and spoke with the head of the Department of Accreditation, John Barth. Mr. Barth confirmed my interpretation that you were taking section 602.14 out of context. He further stated that public and professional input on the initial and ongoing development of any accrediting agency that applies to the DOE is a normal process.
We strongly believe that any accrediting agency that seeks support from the profession must conduct its processes in the open, where all key stakeholders have been provided a full opportunity to provide input. In contrast to NOMAA, ACAOM is one such organization that is conducting its standards development process in the open, and demonstrates to willingness to work with AAOM and members of the profession.
Even if there were no existing accrediting agency for acupuncture and Oriental medicine, the AAOM would expect that the agency that undertook this responsibility would allow all stakeholders to participate in a public process and provide input to the new agency. Any agency that conducted its development in secret would naturally be highly suspect.
Before the profession begins to support an entirely new accrediting agency that is not yet recognized by any credible group such as the U.S. Department of Education, and with no track record of assessing quality education and training in the field, we believe that a determination must first be made that ACAOM, the existing accrediting agency, has not adequately responded to the needs of the profession. In our opinion, given ACAOM's ongoing work with AAOM and other organizations in the field relative to educational standards and its willingness to hear the profession's views, it is simply premature to begin supporting a new accrediting agency.
Given all the facts regarding ACAOM's present standing and credibility, given the questionable need for an additional accrediting agency in our field of medicine, and given the lack of transparency in NOMAA's structure and function, AAOM does not believe that the profession should support NOMAA at the present time. Accordingly, we suggest that all state professional associations, practitioners, educators and state regulators also withhold support for NOMAA at this time.
Gene Bruno, LAc, OMD
On Jan. 20, 2004, in response to the AAOM, Acupuncture Today received the following "open letter" from Dr. Priebe:
Open Letter to Gene Bruno and Other Colleagues of Oriental Medicine
Dr. Bruno and Colleagues,
Thank you for bringing the discussion about higher education and the broad-spread support for a credible first professional doctorate degree directly to the Oriental medicine profession via your submission to Acupuncture Today. This level of attention has inspired us to continue to move forward with the implementation of our new accreditation standards.
I do apologize for quoting the wrong section of the U.S. Secretary of Education's standards for the recognition of accrediting agencies in my letter to you. As you know, there have been long-standing concerns about the appearances of conflicts of interest and inappropriate sharing of resources and information between accrediting agencies and their member college organizations, and I wanted to assure you that we are aware of, and are attempting to comply with the highest ethical standards, including accepting criticism as constructively as possible. The section I quoted was indeed from the "exemption," or an "alternative" standard for the separate and independent" requirement, and I felt that it best summarized the meaning of that standard. Regardless of the error, I am disappointed the AAOM is taking an active and negative position against our organization, and request that the AAOM reconsider its actions. Your statements and position seem mean-spirited.
The NOMAA has reason to be concerned with protecting the standards and criteria that we have worked so hard to develop, and have requested that anyone, including yourself, simply sign a confidentiality agreement before reviewing what might be considered proprietary information. As you are aware, 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 and often opposing independent proposals by the profession to implement higher standards of education. We have been contacted by a number of persons who have close ties with that other agency, asking for more information about NOMAA, and have supplied copies of our standards upon receipt of the signed confidentiality agreements. At this time, having reached a point of comfort with the credibility, specificity and uniqueness of our standards, we are beginning to publish them, starting with our programmatic criteria.
The NOMAA standards are for a 4,000-hour, entry-level professional Doctor of Oriental Medicine (OMD) degree that are based, in part, on the Chinese and Oriental medicine programs in China, Taiwan and Korea, which are generally considered the "gold standard." NOMAA has also used material and recommendations from the California Acupuncture Board's Competency Task Force. This task force was convened a few years ago with expert representatives from state and national professional associations, and from the schools that are most widely recognized as leaders in Oriental medicine education, and was chaired by an individual who holds licenses as both a medical doctor and as an acupuncturist.
Combining and further developing the gold standards and expert recommendations, NOMAA has developed standards to accredit complete Oriental medical education programs offered in the U.S. and which lead to a credible OMD degree. By restricting the scope of recognition to complete Oriental medicine education programs, the NOMAA will be able to focus its assessment on comparable programs of the highest quality. And, while NOMAA does not confer accreditation on master's programs, NOMAA also does not prohibit an accredited program or institute from offering or including an approved master's degree as an element of its educational program.
NOMAA does not operate behind closed doors, with the exception of board meetings, where legal and organizational matters must be discussed in private. Three Board members of the AAOM were present at the meeting where we made our announcement in 2002. 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. These meetings have focused on the further development of our standards and criteria, and, after making recommended changes, we have gained the endorsement of the Council of Acupuncture and Oriental Medicine Associations and the Council on Oriental Medicine Education for our curriculum. We plan to hold more public meetings in the near future.
We are requesting that professional organizations, schools and boards consider endorsing NOMAA standards as meeting or exceeding their own standards of education. We are aware that the AAOM and other organizations have held long-standing positions to support and promote the development of a doctorate degree for the purpose of entry into the Oriental medicine profession, and we feel that we have done our best to meet those goals.
Please go to our Web site at www.nomaa.org and review our standards for yourselves. If they seem sufficient to meet the standards for entry into the independently licensed professional practice of Oriental medicine, then let us know. If you have any suggestions about how to improve our standards, please submit them. We welcome all criticism in hopes of using it constructively for the betterment of Oriental medicine education. If you are a school administrator interested in implementing our program, please contact me directly.
Ted Gagliano Priebe, LAc, OMD