Regarding 18 VAC85-110-150, requiring licensed acupuncturists to maintain active NCCAOM certification in order to continue to practice in VA: It is the position of the Acupuncture Society of Virginia (ASVA) that this requirement does not cause burden to the profession.  States that require NCCAOM certification put the cost and responsibility of ensuring competency maintenance for licensed acupunctuists on the NCCAOM. If this requirement were eliminated, it would put the burden for ensuring competency and verifying continuing education requirements on the VA Board of Medicine. ASVA believes that maintenance of NCCAOM certification provides protection to the public, and that the requirement should be retained in its current form.