I'm signing because the NCCAOM has a well-defined scope - that of certifying that acupuncturists have been adequately trained in the basics of their profession, enough to safely treat the public. I would encourage the NCCAOM to focus on that mission, and to understand that adding more exams and more 'specialties' (as has been proposed) begins to create a barrier to what could be the last accessible and effective regulated medicine that there is. The NCCAOM since I graduated in 2011 has annually proposed considerable expansion in their scope, and most of these have been dismissed by its membership as being unsound. This is yet another example of an unsound proposal. Here are some reasons why it is is unsound: The NCCAOM credential is required to maintain state licensure for many acupuncturists. The NCCAOM advocates for this arrangement. Yet the current Code of Ethics is more suitable for a voluntary exceptional standard adopted by choice.
States that require NCCAOM credentials have their own regulatory boards, ethical codes, and disciplinary process. The NCCAOM Grounds for Professional Discipline empowers the NCCAOM to pull a practitioner’s credential, removing them from practice, even when a state board would allow continued practice for the same violation. This turns the NCCAOM into de facto regulators and creates double jeopardy for practitioners.
The NCCAOM reserves the right to take disciplinary action against any practitioner who violates the Code of Ethics. The Code covers behaviors ranging from serious threats to the public safety to those in the realm of Public Relations. The NCCAOM should explicitly limit the use of disciplinary action to violations that risk the public safety.