I support the statements submitted by ASVA for the review of state acupuncture regulations with one exception.  

In section 8VAC85-110-110 Limitiation of Titles,  second paragraph, last sentence "and shall not use the terms "physician or "doctor" in name or practice unless he holds a clinical doctorate or PHd and simultaneously uses a clarifying titile, initials, abbreviation, or designation.  I do not agree with this statement. 

The statement, other states (Florida, Rhode Island, and New Mexico) attribute the professional designation of doctor or physician to licensed acupuncturists, even though the acupuncturist has not obtained a clinical doctorate degree.  This statement infers that acupuncturists in this state are held to the same regulations as other states.  This inference is false. 

Florida acupuncturists use the title Doctor of Oriental Medicine or Physicians Assistant based on the scope of pracitce and duties performed.  In Florida an acupuncturist is designated a Primary Care Physician because they perform basic routine medical screenings, order  medical diagnostic and laboratory tests, and are covered by most insurance companies.  They are not required to have a clinical doctorate of PhD but as a part of the bi annual licensing renewal process they are required to complete continuing education units in medical and diagnostic findings.   

Therefore, I would like to see the statement holds a clinical doctorate or Phd not be considered in the regulations.