Hi Lisa – I can hardly imagine the maze of B.S. you are going through dealing with school accreditation. I want to offer a few thoughts that might help or might backfire and make you even more frustrated.
I don’t know just how much of the proposed language you quote are revisions and how that differed from the older language, but the main comments I thought to offer have to do more with the bigger picture of any Standards and Criteria for an accreditation agency in the U.S. acupuncture/CM field.
Although there is certainly the possibility of linkage, there is also a difference between the standards of what is required to be taught in accredited schools and what practitioners are expected to do in the way they practice.
These proposed standards say that “students must demonstrate the ability to:” Blah, Blah, Blah ... They do not say “these are the standards you must employ in your practice”.
The way you end up practicing is more defined by the scope of practice your license/certification allows you to do than accreditation standards. The huge problem for acupuncture/CM practice is that we have a sizable variety in scope of practice in differing states.
I know it sounds profoundly stupid that schools would be expected to teach their students KSAs they would not even be allowed to perform in some states, but this is the clusterfuck we are in trying to find the best one size fits all education standards when there is nothing close to one size fits all scope of practice standards across the various states.
An alternate route might be to allow different schools to teach different KSAs and then have multiple accreditation standards for different schools. But then, in addition to the extra complexity this would entail, what of students graduating from one school with less comprehensive/expansive Standards and Criteria based on more limited scope of practice when some of those students want to practice in a state with a broader scope?
The proposed Standards and Criteria ACAHM is proposing could make sense for a state where Acupuncturists are considered to be primary care providers (PCPs) but they go overboard for states where Acupuncturists are not PCPs. That right there is a huge freaking difference.
You and POCA Tech, with very good reason, are a proponent of a more limited training model (albeit with far more of the critical hands-on clinical training most other schools fail their students in). But if you are trying to avoid multiple training standards with all the extra complexity this would involve, you might default to justifying more expansive training as following the “better to have it and not need it than to need it and not have it” philosophy.
The same goes for the overall TCM model. Only an idiot would think that model is the only right way to practice. Even in China, that model was a compromise for the sake of uniformity and ease of regulating the practice where everyone would share a floor level knowledge and common language as the entry-level.
There was a logic behind the effort to find a one size fits all system of training that would serve as a good enough entry level education and allow practitioners to speak the same language, as it were. It should never have been seen as “the way to practice” just “the way to start to practice”. This could have been OK if we had kept the scope similar across states and adjusted the training standards to provide for that scope.
I don’t know if this was any help. Probably not. I wish I had some advice that would help your cause.
I appreciate your perspective and what you’re saying makes sense. In a sense ACAHM is caught in a bind. On their website they offer one definition of accreditation as “the recognition that an institution maintains standards requisite...to achieve credentials for professional practice.” As you’ve pointed out, that’s a real problem when credentials for professional practice vary so dramatically, state to state. I know ACAHM does not see its role as the arbiter of what kinds of acupuncture practices should exist, but that’s what the Standards end up defining (if they’re not flexible enough).
ACAHM has also stated that their primary responsibility “is to oversee the quality of AHM education in the US and ensure graduates of accredited programs possess the necessary education and training to practice AHM safely and effectively.” That’s quite different from requiring all schools to meet the most expensive and lengthy state requirements under the justification of avoiding “the complexity of multiple training standards”. It just isn’t ACAHM’s job to resolve the variations in scope of practice. ACAHM does require schools to be transparent about where their graduates can and cannot practice based on state requirements, and I think that makes sense.
A lot of people believe that a school’s job is to fall in line with the most aspirational version of the acupuncture profession. That’s certainly what my alma mater, OCOM, did -- and that’s also how they ended up with some of the worst debt to income ratios in the country. As you can tell, I absolutely don’t think that’s my job or my school’s job. No acupuncture school can ensure that their graduates can practice ALL forms of AHM safely and effectively, there are just too many! For example, other schools can’t ensure that their graduates can see six patients an hour safely and effectively in a community setting, that’s why we had to make POCA Tech.
I have a lot of feelings about this (obviously) but I don’t have any doubts about whether ACAHM should accommodate clinical flexibility in its Standards. I don’t think that’s an unreasonable thing to insist on. So I guess I’m saying I appreciate your support (very much) but I don’t feel like I need advice. From my perspective I’m playing by the rules as written, and I’m just insisting that ACAHM does too.
I think just setting the stage with the differences in clinical scope gets closer to a rational educational setup. Graduates should be able to speak coherently about different scopes of practice and be able to perform safely and effectively within those privileges. It doesn't mean you know how to do everything but it does mean you understand the issues and what's going on. It also means choosing not to perform treatments you can perform legally on paper. Schools can then choose to focus on certain things for contextualized reasons.
One of the challenges there is that you can't really teach in the classroom what you can't follow up with in clinic. And it just isn't viable to have a student clinic where people are showing their ability to perform within a wide range of scope of practices -- logistically and economically it would be a huge mess to try to fit all that into one student clinic.
This is great, Lisa. I am hoping you will share your final comments, or at least some bullet points. Also, I couldn't easily see at the ACAHM site when the comment period closes and if anyone can comment. I'd certainly like to weigh in. While I am thrilled to see some of the proposed changes, I also share your concerns. I certainly don't see a way to incorporate these changes without making the programs even longer. And boy do I hate that SHOULD in the section on treatment plans. Honestly, I am concerned about the burden of (and possible danger from) the treatment plans my clients already have from others on their health care team.
Thanks, Elaine! My understanding is that the comment period closes on January 19th and yes, anyone can comment. I learned so much from watching the 5NP rule making process and one big thing was, the more specific and actionable the comment, the better. I will definitely share my comments (since you asked <3) — I anticipate that there are going to be pages and pages of tiny picky edits. Whatever comments you have, please share them with ACAHM! (And publicly if you’re up for that, I’d love to see them.)
I’ll definitely be writing more about the proposed revisions because wow, what a writing prompt they’re turning out to be.
( And yeah, unfortunately “treatment plans” are not always a positive thing.)
Hey Lisa - Thanks. I don't think you "need" advice either. Of all the people I have known in leadership roles in this field you have about the best mix of understanding the big picture and the wonky details all at once. And more tenacity than all of them. I still wish I could give you some sage advice, though. As for the schools going for the most aspirational version of the profession, this, again, is where the professional associations dropped the ball. The schools, the accreditation body and the exam/certification bodies, all have a tendency toward incestuous relationships. The professional associations should have been the check against that but this never happened.
Thanks! I agree 100% about the professional associations -- and they didn't play that role in part because so few practitioners were actually working, let alone being successful enough to give back as volunteers.
My first acupuncturist, who helped me heal from heinous nerve pain, never did the "10 questions" routine. He'd ask me pertinent questions related to the complaint, then place the needles and leave me be to bask in their goodness. I don't think he ever used more than six needles. And he never, to my recollection, asked me about my entire "lifestyle." His treatments were genius. They worked. Over time I knew I had to quit my 26-year nursing career and learn this medicine. As I was preparing to go to school, he said these words, which I will never forget: "Laurie, 80% of what you are about to learn over the next three years is bullshit. The other 20% is Truth." I was stunned and asked him "which 80%?" He said: Use discernment and trust your intuition. And so I did. I memorized everything for the tests. I fidgeted resentfully through the classes that I knew were non-essential material with hours of homework to fill the curriculum and nothing more. I knew that eliminating that filler could easily shave a year off the program. Standardization is problematic when it hardens into a single "correct" way to practice. Most experienced RN's know what to keep and what to discard, in the real working world. Flexibility is recognition of clinical reality and having constraint in intrusive "lifestyle" questions can itself be therapeutic.
After I shared the news of my graduation with the only person I'd ever thought of as a mentor, he said, "That's a nice piece of paper. Now go out and touch a thousand bodies."
A big part I'm seeing here is the connections to actual clinical practice. Somehow the training should connect to a real clinical need for a real group. Rather than exhaustively mandating a clinical approach, could the standard involve showing reflection and responsiveness to what shows up during clinical work? There needs to be some indoctrination but then also flexibility towards how clinician meets population needs.
I'm glad you are digging into the standards and posting about them!
Yes, I think the linchpin is clinical practice. As you've pointed out so clearly, it doesn't matter how "good" a school is if it's financially unsustainable. That includes its student clinic(s) -- all student clinics lose money, but they can't lose so much that they don't exist anymore. Our school has the great benefit of having a stable, community-supported clinic that defined a specific clinical need for a specific group of people who are willing to pay for the service and also willing to allow students to practice on them. It makes no sense to have accreditation standards that would wipe out that arrangement based on ideology. The future of acupuncture may come down to, what kind of acupuncture education (including the clinical aspect) can actually be funded without exploiting anybody? Our school can pass that test.
Most schools underwrite their student clinics via tuition. Our school is underwritten by a self-funded non profit so essentially, WCA patients (or the patients of other Away Clinics) pay for the training of future community acupuncturists. In other words, we have training that our community of patients and students can pay for out of pocket (supplemented by fundraising). Which means tuition has to cost less and treatments have to cost less and the whole thing has to be a lot simpler. Too bad everyone else appears to be allergic to this arrangement.
Hi Lisa – I can hardly imagine the maze of B.S. you are going through dealing with school accreditation. I want to offer a few thoughts that might help or might backfire and make you even more frustrated.
I don’t know just how much of the proposed language you quote are revisions and how that differed from the older language, but the main comments I thought to offer have to do more with the bigger picture of any Standards and Criteria for an accreditation agency in the U.S. acupuncture/CM field.
Although there is certainly the possibility of linkage, there is also a difference between the standards of what is required to be taught in accredited schools and what practitioners are expected to do in the way they practice.
These proposed standards say that “students must demonstrate the ability to:” Blah, Blah, Blah ... They do not say “these are the standards you must employ in your practice”.
The way you end up practicing is more defined by the scope of practice your license/certification allows you to do than accreditation standards. The huge problem for acupuncture/CM practice is that we have a sizable variety in scope of practice in differing states.
I know it sounds profoundly stupid that schools would be expected to teach their students KSAs they would not even be allowed to perform in some states, but this is the clusterfuck we are in trying to find the best one size fits all education standards when there is nothing close to one size fits all scope of practice standards across the various states.
An alternate route might be to allow different schools to teach different KSAs and then have multiple accreditation standards for different schools. But then, in addition to the extra complexity this would entail, what of students graduating from one school with less comprehensive/expansive Standards and Criteria based on more limited scope of practice when some of those students want to practice in a state with a broader scope?
The proposed Standards and Criteria ACAHM is proposing could make sense for a state where Acupuncturists are considered to be primary care providers (PCPs) but they go overboard for states where Acupuncturists are not PCPs. That right there is a huge freaking difference.
You and POCA Tech, with very good reason, are a proponent of a more limited training model (albeit with far more of the critical hands-on clinical training most other schools fail their students in). But if you are trying to avoid multiple training standards with all the extra complexity this would involve, you might default to justifying more expansive training as following the “better to have it and not need it than to need it and not have it” philosophy.
The same goes for the overall TCM model. Only an idiot would think that model is the only right way to practice. Even in China, that model was a compromise for the sake of uniformity and ease of regulating the practice where everyone would share a floor level knowledge and common language as the entry-level.
There was a logic behind the effort to find a one size fits all system of training that would serve as a good enough entry level education and allow practitioners to speak the same language, as it were. It should never have been seen as “the way to practice” just “the way to start to practice”. This could have been OK if we had kept the scope similar across states and adjusted the training standards to provide for that scope.
I don’t know if this was any help. Probably not. I wish I had some advice that would help your cause.
Hi Matt,
I appreciate your perspective and what you’re saying makes sense. In a sense ACAHM is caught in a bind. On their website they offer one definition of accreditation as “the recognition that an institution maintains standards requisite...to achieve credentials for professional practice.” As you’ve pointed out, that’s a real problem when credentials for professional practice vary so dramatically, state to state. I know ACAHM does not see its role as the arbiter of what kinds of acupuncture practices should exist, but that’s what the Standards end up defining (if they’re not flexible enough).
ACAHM has also stated that their primary responsibility “is to oversee the quality of AHM education in the US and ensure graduates of accredited programs possess the necessary education and training to practice AHM safely and effectively.” That’s quite different from requiring all schools to meet the most expensive and lengthy state requirements under the justification of avoiding “the complexity of multiple training standards”. It just isn’t ACAHM’s job to resolve the variations in scope of practice. ACAHM does require schools to be transparent about where their graduates can and cannot practice based on state requirements, and I think that makes sense.
A lot of people believe that a school’s job is to fall in line with the most aspirational version of the acupuncture profession. That’s certainly what my alma mater, OCOM, did -- and that’s also how they ended up with some of the worst debt to income ratios in the country. As you can tell, I absolutely don’t think that’s my job or my school’s job. No acupuncture school can ensure that their graduates can practice ALL forms of AHM safely and effectively, there are just too many! For example, other schools can’t ensure that their graduates can see six patients an hour safely and effectively in a community setting, that’s why we had to make POCA Tech.
I have a lot of feelings about this (obviously) but I don’t have any doubts about whether ACAHM should accommodate clinical flexibility in its Standards. I don’t think that’s an unreasonable thing to insist on. So I guess I’m saying I appreciate your support (very much) but I don’t feel like I need advice. From my perspective I’m playing by the rules as written, and I’m just insisting that ACAHM does too.
I think just setting the stage with the differences in clinical scope gets closer to a rational educational setup. Graduates should be able to speak coherently about different scopes of practice and be able to perform safely and effectively within those privileges. It doesn't mean you know how to do everything but it does mean you understand the issues and what's going on. It also means choosing not to perform treatments you can perform legally on paper. Schools can then choose to focus on certain things for contextualized reasons.
One of the challenges there is that you can't really teach in the classroom what you can't follow up with in clinic. And it just isn't viable to have a student clinic where people are showing their ability to perform within a wide range of scope of practices -- logistically and economically it would be a huge mess to try to fit all that into one student clinic.
Yes and this is part of why complementary medicine can't mimic conventional, hospital practitioners.
Here's the link to call for comments. I'll be weighing in (but waiting to see what Lisa has to say first!)
https://www.acahm.org/blog/proposed-revisions-to-standards
This is great, Lisa. I am hoping you will share your final comments, or at least some bullet points. Also, I couldn't easily see at the ACAHM site when the comment period closes and if anyone can comment. I'd certainly like to weigh in. While I am thrilled to see some of the proposed changes, I also share your concerns. I certainly don't see a way to incorporate these changes without making the programs even longer. And boy do I hate that SHOULD in the section on treatment plans. Honestly, I am concerned about the burden of (and possible danger from) the treatment plans my clients already have from others on their health care team.
Thanks, Elaine! My understanding is that the comment period closes on January 19th and yes, anyone can comment. I learned so much from watching the 5NP rule making process and one big thing was, the more specific and actionable the comment, the better. I will definitely share my comments (since you asked <3) — I anticipate that there are going to be pages and pages of tiny picky edits. Whatever comments you have, please share them with ACAHM! (And publicly if you’re up for that, I’d love to see them.)
I’ll definitely be writing more about the proposed revisions because wow, what a writing prompt they’re turning out to be.
( And yeah, unfortunately “treatment plans” are not always a positive thing.)
Hey Lisa - Thanks. I don't think you "need" advice either. Of all the people I have known in leadership roles in this field you have about the best mix of understanding the big picture and the wonky details all at once. And more tenacity than all of them. I still wish I could give you some sage advice, though. As for the schools going for the most aspirational version of the profession, this, again, is where the professional associations dropped the ball. The schools, the accreditation body and the exam/certification bodies, all have a tendency toward incestuous relationships. The professional associations should have been the check against that but this never happened.
Thanks! I agree 100% about the professional associations -- and they didn't play that role in part because so few practitioners were actually working, let alone being successful enough to give back as volunteers.
My first acupuncturist, who helped me heal from heinous nerve pain, never did the "10 questions" routine. He'd ask me pertinent questions related to the complaint, then place the needles and leave me be to bask in their goodness. I don't think he ever used more than six needles. And he never, to my recollection, asked me about my entire "lifestyle." His treatments were genius. They worked. Over time I knew I had to quit my 26-year nursing career and learn this medicine. As I was preparing to go to school, he said these words, which I will never forget: "Laurie, 80% of what you are about to learn over the next three years is bullshit. The other 20% is Truth." I was stunned and asked him "which 80%?" He said: Use discernment and trust your intuition. And so I did. I memorized everything for the tests. I fidgeted resentfully through the classes that I knew were non-essential material with hours of homework to fill the curriculum and nothing more. I knew that eliminating that filler could easily shave a year off the program. Standardization is problematic when it hardens into a single "correct" way to practice. Most experienced RN's know what to keep and what to discard, in the real working world. Flexibility is recognition of clinical reality and having constraint in intrusive "lifestyle" questions can itself be therapeutic.
After I shared the news of my graduation with the only person I'd ever thought of as a mentor, he said, "That's a nice piece of paper. Now go out and touch a thousand bodies."
What a great story! Thank you for sharing!
A big part I'm seeing here is the connections to actual clinical practice. Somehow the training should connect to a real clinical need for a real group. Rather than exhaustively mandating a clinical approach, could the standard involve showing reflection and responsiveness to what shows up during clinical work? There needs to be some indoctrination but then also flexibility towards how clinician meets population needs.
I'm glad you are digging into the standards and posting about them!
Yes, I think the linchpin is clinical practice. As you've pointed out so clearly, it doesn't matter how "good" a school is if it's financially unsustainable. That includes its student clinic(s) -- all student clinics lose money, but they can't lose so much that they don't exist anymore. Our school has the great benefit of having a stable, community-supported clinic that defined a specific clinical need for a specific group of people who are willing to pay for the service and also willing to allow students to practice on them. It makes no sense to have accreditation standards that would wipe out that arrangement based on ideology. The future of acupuncture may come down to, what kind of acupuncture education (including the clinical aspect) can actually be funded without exploiting anybody? Our school can pass that test.
Yes, the big question is, who pays for the training?
Most schools underwrite their student clinics via tuition. Our school is underwritten by a self-funded non profit so essentially, WCA patients (or the patients of other Away Clinics) pay for the training of future community acupuncturists. In other words, we have training that our community of patients and students can pay for out of pocket (supplemented by fundraising). Which means tuition has to cost less and treatments have to cost less and the whole thing has to be a lot simpler. Too bad everyone else appears to be allergic to this arrangement.