VITCM supports the comments from Acupuncture Society of Virginia. In addition, VITCM's comments:

18VAC85-110-50. Educational requirements: graduates of approved institutions or programs in the United States.

VITCM supports the existing regulations concerning educational requirements.The regulation should update the requirements according to ACAOM, the national accreditation agency for acupuncture and Oriental medicine education.

18VAC85-110-60. Requirements of foreign graduates of nonaccredited educational programs in acupuncture and Oriental medicine.

should be replaced by "18VAC85-110-60. Requirements of foreign graduates in acupuncture and Oriental medicine".

The reason is  ACAOM only accreditates US schools. For  whose foreign graduates, as long as they passing NCCAOM examinations, Virginia State board should treat them equally to the students who graduated from the US schools accredited by ACAOM.  NCCAOM has a very restrict procedure to evaluate/judge such foreign students, if they had equivalent education as (or higher than)  ACAOM accredited schools in USA, they are allowed to take NCCAOM examinations and get the certificates.  In the regulation doesn't need mention ".....from nonaccredited educational programs in acupuncture and Oriental medicine by ACAOM". VA regulation could match the regulations in  neighbor States, such as Maryland.

18VAC85-110-80. Examination requirements for licensure.

VITCM recommends that requirement 2, “Passing the Practical Examination of Point Location Skills (PEPLS) test,” be eliminated from the regulations. Point location examination is now part of the NCCAOM acupuncture examination. Therefore, the inclusion of this requirement within the regulations is redundant and unnecessary.

18VAC85-110-90. Test of spoken English requirements.

Not necessary to mention language requirements in VA "acupuncture" regulation, if this is not mentioned in other professions' regulation.

And, any healthcare provider (not limited to "acupuncturis") may treat the patients who only speak spanish, Chinese or Korean, or other languages, it is not necessary the "acupuncturists" should know all such languages, or English.  If the provider's patients mostly from a spanish or Korean (or other) community, the regulation should not force the provider to speak English. Interpreter may be needed if the patient could not speak the language that the provider(please notes: this is not for acupuncture profession along) speaks.

18VAC85-110-100. General requirements.

VITCM strongly disagrees that the requirement for written documentation of or written recommendation to receive a diagnostic evaluation by physician, which is an unnecessary regulatory burden on both patients and "licensed acupuncturists" and their businesses, and is not necessary for the protection of public health, safety, or welfare.

Currently, unlike many years ago, "licensed acupuncturists" have enough education (and continue education) to know which patent needs additional information from a medical doctor or other healthcare providers. In most of cases, let patient get a diagnose from other doctors, causing patient spand additional time, money and efferts. From a feasible rule, we hope delete such reuirement. Many other States already removed such unfeasible requirement for many years.

Virginia residents often concurrently seek care with a licensed acupuncturist in addition to a licensed doctor of medicine and / or other healthcare professionals.  A patient receiving a form that notes that the state requires them to be notified of a recommendation to receive diagnostic examination by another health professional undermines the professional credibility of licensed acupuncturists, who are well aware of the limitations of the acupuncture and Oriental medicine scope of practice and their responsibility to refer patients, as necessary, to other providers. Most Insurance companies in Virginia do not currently cover acupuncture and acupuncture will not be included as an essential health benefit in Virginia. Acupuncture is an out of pocket expense for most individuals.  Therefore, this regulation should be repealed to be consistent with consumer behavior, insurance coverage, and the requirements of surrounding states.

Many patients residing in localities near Virginia borders, especially those in northern Virginia, may be getting acupuncture in other states or jurisdictions (i.e. Maryland, District of Columbia) where they work. This requirement would therefore not apply to those individuals and is therefore not being applied equally to all Virginians. There have been no reported incidents of the lack of a medical examination requirement causing harm or endangering the health, safety, or welfare of these individuals.

18VAC85-110-110. Limitation of titles.

This section of regulation should be reviewed for possible amendments that would provide further clarity on the use of titles. In Virginia, the title “Lic.Ac.” is no longer commonly used by licensed acupuncturists; and most, if not all licensed acupuncturists use the title “L.Ac.” VITCM feels that the title “Lic.Ac.” can be stricken from the regulation without burden on the profession. VITCM suggests the regulation use the title of OMD (Doctor in Oriental Medicine) to replace " Lic.Ac.", which indicates the provider is for practicing Oriental medicine, includes in the evaluation/ diagnose procedure of Oriental medicine, and application of the therapies of acupuncture, Chinese herbology, dietary therapy, Tuina/Chinese therapuetic massage and Qigong, Taichi and other mind-body adjustments.

The regulation should allow a "licensed acupuncturist" to use the title of “Dr.” as there are other states (Florida, New Mexico, Rhode Island, Novada, etc.) that attribute the professional designation of doctor or physician to licensed acupuncturists, even though the "acupuncturist" has not obtained a clinical doctorate degree. As a provider in Complementary and Alternative medicine (CAM), in real clinical practice, patients treat "Lic.Ac." as a doctor.

18VAC85-110-130. Maintenance of patient records.

VITCM notes that this regulation is not contained within the regulations governing any other health profession regulated by the Board of Medicine and therefore should be repealed.