I am an acupuncturist who has been licensed in Virginia for 19 years.  I understand and appreciate the value of an ACAOM-accredited education.  That being said, I know of a number of acupuncturists, some with excellent training and skills, who did not graduate from ACAOM accredited schools.  If this non-ACAOM school is located in Canada or Mexico or Asia, or anywhere other than the United States, these practitioners can submit their transcript to a credentialing body and, if their education is deemed sufficient, they can sit the NCCAOM exams and if they pass, can become licensed in Virginia.  I am sure it was not the intention of Virginia Regulators to allow a path to licensure for those who received their education out of the United States that is not available to those who attended school in the United States.  The NCCAOM exams are well-respected.  Those without sufficient education would be unable to pass these strenuous exams. Therefore, I believe this regulatory change is reasonable and will not endanger the citizens of Virginia.

I have 18 years of uninterrupted experience as a state licensed and National Board Certified Acupuncturist. I would be honored to serve the population in the Commonwealth of Virginia. This regulation change would assist me in the process of gaining Virginia licensure.

Everyone agrees that the NCCAOM examinations are extremely comprehensive and challenging and to score well, one needs an extensive understanding of Acupuncture. The high Virginia standard of competency will be maintained as long as these examinations continue to remain weighted as an essential.requirement.

I believe that national acupuncture graduates deserve the same legal right as foreign graduates. Those who graduate from U.S. schools should also be able to have their transcrpts reviewed in their effort to become licensed.

I believe that this regulation change should be approved.  It is unreasonable not to allow U.S. graduates the same courtesy we offer foreign graduates.  I agree of with the above comments, and feel certain that the NCCAOM exam is able to assess the knowledge base of a well educated acupuncturist.

I have received many accupuncture treatments, both from those with the accreditation currently demanded of their training facilities and those who have not graduated from universities and facilities with the type of accreditation demanded in order for the treatment specialists to be licensed in Viriginia. Very often the ones with the most in-depth training from masters with lifetime practices are a little older and completed training before their universities (etc.) had secured the desired accreditation. I feel that much of our regulatory practice in this state denies excellent practionners the ability to compete with foreign students, who may request evaluation of credentials. It's almost a reverse profiling, where the foreigners have precedence over many students from fine American institutions, institutions which may be visited, investigated, and tested for expertise because of their proximity (being in the country as opposed to being abroad.)

I feel that it is only justice to give American-trained students/practionners the benefit of the same evaluative procedures offered to the foreign practionners/students. The Americans will no doubt be practicing in America and adding to the quality of specialists in their field. Furthermore, at a time when insurances are beginning to recognize these practionners  as candidates for insurance claims,this growing field  can accommodate many more practionners. No one is wanting to certify those who lack the credentials necessary to treat the citizens of Virginia, but why shouldn't  USA healers and practionners be given an equal opportunity to be evaluated by the same standards as their foreign equals? I am sure there would be a large percentage who could "pass the muster." In today's economy don't we want to be developing more jobs for our  own citizens? It seems to me to be a win-win situation to let all be given the opportunity to prove their qualifications. Thank you for the opportunity to address this topic. 

                                                                                                                            Sincerely, Diahn Simonini

 offered to 

 I am an acupuncturist patient who travels long distances to get acupuncture treatment. By allowing transcript examination of U.S. graduates, with NCCAOM certification,  the Commonwealth of Virginia will attract well qualified, NCCAOM Certified Acupuncturists to better serve our local population.

Dear Commission:

I write in support of a regulation change in the path to licensure in Virginia for graduates of U.S. Acupuncture and Oriental Medicine schools to offer them the same privilege of transcript evaluation that you presently offer only to graduates of foreign schools.  Because Virginia already has the assessment criteria and process in place for foreign programs, I am in favor of allowing graduates of U.S. schools that were not accredited at the time of their graduation to participate similarly in this path to licensure. If their transcripts meet the same standards for licensure that you have set for foreign graduates, and if they have passed the NCCAOM exams, I believe the people of the Commonwealth of Virginia would greatly benefit.     

Very Sincerely, 

Lakshmi Fjord, Ph.D.

The inherent inequity of allowing a foreign-educated practitioner to gain licensure by passing the NCCAAOM exam yet deny a U.S. educated practitioner who also passes the NCCAOM exam just because s/he graduated from a school in candidacy status versus full accreditaiton status should end now.  I am certain that it was not the intent of the regulators to have this inequity manifest in this fashion as a result of the previous rulemaking.  To impose a greater level of scrutiny for those who study in the U.S. versus abroad tips the scales of fairness away from U.S. taught practitioners of in favor of those foreign-trained.  The benefits to the State of Virginia are multi-fold, which include without limitation, 1) having more students matriculate into candidacy status programs (note that all 3 schools of oriental medicine in Virginia are in candidacy status) without fear that they will not go on to become fully accredited even though approximately 90% of schools in candidacy status eventually gain full accreditaiton; 2) more students who graduate in a school certified to operate by SCHEV are likely to become practitioners in the Commonwealth which leads to more acupuncture services for a growing population looking for same; 3) keep acupuncture practices in the Commonwealth and avoid graduates from moving to Maryland or other neighboring states; and 4) provide a greater pool of qualified practitioners to select from for larger medical institutions such as hospitals, insurance companies and state-run medical facilities as they increasingly move toward the practice of integrative medicine.  

I have spent my adult years in Virginia.  As a homeowner, parent, former Fairfax County educator  and employee of  the U.S. government,  I’m a long-time member of the community.  I know from personal experience that acupuncture is amazing.  In fact, I am now a student at Virginia University of Oriental Medicine and excited to be part of this growing field.

It is important to change the regulations related to candidacy program to offer Virginians an important option in their health care decisions.  As you know, both the World Health Organization (WHO) and a 1997 National Institutes of Health (NIH) Consensus Statement have recognized acupuncture as effective in treating a wide variety of health conditions.

1. The current regulations are not in keeping with nationwide practices.   According to two website references on acupuncture (acufinder.com and  acupuncturecolleges.com), nearly all U.S. states that license acupuncturists require graduation from a program that is accredited OR that has candidacy status (some also recognize certain foreign programs or state-approved programs that are not accredited).

2.  The Accreditation Commission for Acupuncture and Oriental Medicine (ACAOM)recognizes the rigor of its candidacy process by allowing graduates from an ACAOM candidate OR accredited school to take the national certification exams in this field.  The ACAOM is the only national organization recognized by the U.S. Department of Education for AOM schools and programs in the U.S.  The school’s candidacy or accreditation status with ACAOM represents the highest level of AOM institutional or programmatic quality assurance available in the U.S. today.   

3.  The U.S. Dept. of Education has determined that schools designated by the ACAOM in candidacy status permit funding assistance  under the terms Of the Higher Education Act and other regulations..   (http://www2.ed.gov/admins/finaid/accred/accreditation_pg8.html)  By way of background,  under the terms of the Higher Education Act and other Federal legislation providing funding assistance to postsecondary education, an institution or program is eligible to apply for participation in certain Federal programs if, in addition to meeting other statutory requirements, it is accredited by a nationally recognized accrediting agency OR  if it is an institution or program which the U.S. Secretary of Education has determined that there is satisfactory assurance the institution or program will meet the accreditation standards of such an agency or association within a reasonable time. An institution of program may establish satisfactory assurance of accreditation by acquiring preaccreditation status with a nationally recognized agency that has been recognized by the U.S. Secretary of Education for the award of such status.  According to the Criteria for Nationally Recognized Accrediting Agencies, if an accrediting agency has developed a preaccreditation status, it must demonstrate that it applies criteria and follows procedures that are appropriately related to those used to award accreditation status.  The ACAOM is identified on the Department of Education’s webpage as meeting their criteria to designate acupuncture and Oriental Medicine  programs for candidacy with respect to funding. 

 4.  Failure to change Virginia’s regulations puts students and colleges in jeopardy.  In a Catch 22 quandry, to achieve final accreditation the school must show its success in  preparing students to pass the rigorous ACAOM national certification exams.  Yet the students who pass will be unable to practice in Virginia until the school achieves accreditation, which normally is 3+years after candidacy.  This is unfair to the student and may result in deterring the best and brightest students from taking a chance on enrolling in a program in the process of achieving final accreditation – which ultimately  is not in the best interest of Virginians.

Thank you for the opportunity to comment.

I am writing in support of the petitioner who wishes to have her transcript evaluated as would be required of an applicant from a foreign school.  It is not due to any failing on her part that the school that she graduated from in good standing had not yet been granted accreditation by the NCCAOM.  In addition, she passed the acupuncture boards and remains an NCCAOM practitioner in good standing over many years.

She wishes to relocate from Florida to Virginia (Buckingham County) to be closer to her grandchildren and to render acupuncture services to residents of that area.  I am currently serving mostof the people of Buckingham that Leslie Stone would be seeing.  I can tell you that it is a hardship for them to drive to Charlottesville for their appointments.  I would be better for them to have someone local.

Please give Ms. Stone's petition every positive consideration.

Sincerely,

Jody Forman, MSW, L.Ac., PLLC

I am a state licensed and National Board Certified (NCCAOM, 1996) Acupuncturist, practicing in Florida..  Leslie Stone, the petitioner of the request to amend the educational requirements for acupuncture, was a class mate in acupuncture school, 2 years ahead of me, and is a highly respected colleague in the field of acupuncture and Oriental Medicine.  I think that the Commonwealth of Virginia would be well served to have her almost 20 years of experience, learning and advanced skills available as part of your health care system.

However, as I understand, reading the petition, the core issue here is that there is a discrepancy between how the education of  acupuncturists trained in foreign schools and those trained in the US is considered when each are applying for licensure in the Commonwealth of Virginia, with all other requirements having been met.. This is an issue mainly regarding acupuncturists who were licensed before the widespread use of graduation from an ACAOM school was used as a licensure requirement.  Those in this situation are our long-time-practicing and experienced US acupuncturists.  The value of this experience and of post graduate training programs may be difficult to measure or compare, but is worth considering.

I was also an administrator at the acupuncture school that Leslie and I both attended.  At that time, in the early 1990’s, there were very few ACAOM accredited acupuncture schools, and none in the State of Florida.  The acupuncture school administration was aware that they would starting the accreditation process with the ACAOM, and made it a policy that all educational standards and requirements of the ACAOM would be part of the curriculum.  As the ACAOM requirements changed, so did our  curriculum.  So I can say that the acupuncture education received by Leslie Stone was nearly the same as that in the ACAOM schools of that time, given that all acupuncture schools have a slightly different curriculum.

I hope that this regulation change will be approved. 

Sincerely,  Jere Proctor

Dear Board

Thank you for your service to citizens of the Commonwealth.

Accupuncture is an ancient science but relatively new to America.

Not all schools are accredited, even where top experts are teaching in them.

Therefore American applicants should be given the same treatment as foreign applicants and be allowed to demonstrate their ability to meet the standards without regard to accreditation of schools attended.

Thank you

Bill Eberle

This new regulation request allows all graduates from non-accredited schools, inside and outside the U.S. to have their transcripts evaluated to demonstrate whether or not they have met Virginia's understandably high standards.

Dear Board

Thank you for your service to citizens of the Commonwealth.

Accupuncture is an ancient science but relatively new to America.

Not all schools are accredited, even where top experts are teaching in them.

Therefore American applicants should be given the same treatment as foreign applicants and be allowed to demonstrate their ability to meet the standards without regard to accreditation of schools attended.

Thank you

Bill Eberle

This new regulation request allows all graduates from non-accredited schools, inside and outside the U.S. to have their transcripts evaluated to demonstrate whether or not they have met Virginia's understandably high standards.

Without knowing the details of Ms. Stone’s specific circumstances, and while also being sympathetic to these circumstances, this specific regulation does not apply to graduates from US educational programs. Therefore, ASVA feels there is no cause for a change to this regulation, which would impose an undue burden on the Department of Health Professions as well as the agency that does the review.