US Licensed Acupuncturists Letter to Congress

Dear Congresswoman Chu:

On behalf of the tens of thousands of licensed acupuncturists and all enrolled in our educational institutions, we thank you for being a tireless federal champion for the expansion and inclusion of acupuncture in this country. We thank you for the opportunity to submit the following amendments to the last introduction of your large bill from 2019 to expand access to acupuncture throughout federal systems.

What brings us together as an identifiable practitioner group is our education in what is globally recognized and practiced as Traditional Asian Medicine. Graduation from one of these institutions, or a foreign pathway from countries where this medicine is integral to their healthcare systems, is not simply "widely accepted"; It is required for licensure as a Licensed Acupuncturist.

This group represents a number of organizations that have leadership roles in hospitals, research institutions, and state/national advocacy organizations. One thing we all share in common is that we studied acupuncture extensively and hold Masters/Doctoral level degrees in acupuncture and are all Licensed Acupuncturists. We also share a grave concern that as acupuncture is being added to scopes of practice for practitioners learning a technique in 80-300 hour courses, with limited theory behind the teaching of the technique, the experts in the field do not have a pathway for inclusion that honors the years of training and the medical system that acupuncture belongs to. Before we no longer see Licensed Acupuncturists in the delivery of acupuncture services, we should take steps to ensure this doesn't happen.

DEFINITION OF LICENSED ACUPUNCTURIST: We ask that we federally define "licensed acupuncturist," rather than "qualified acupuncturist," to reflect who we are as a skilled and educated practitioner group, because we are already recognized as such where we are currently practicing. We may range in title from Licensed Acupuncturist to Doctor of Acupuncture to Acupuncture Physician, depending on the state, but the educational requirements for licensure remain the same.

Under the Bureau of Labor Statistics classifies Acupuncturists under the category of 29-1290  Miscellaneous Healthcare Diagnosing or Treating Practitioners with the following definition:

"Diagnose, treat, and prevent disorders by stimulating specific acupuncture points within the body using acupuncture needles. May also use cups, nutritional supplements, therapeutic massage, acupressure, and other alternative health therapies. Excludes “Chiropractors” (29-1011)." 

We believe that adding a separate federal definition for "qualified acupuncturist" creates a sense of separation from the medicine we spend years studying and reduces our services to the modality that other practitioner groups have been adding over the years to their scopes of practice. Yet, none of these practitioners study acupuncture techniques or theory extensively. To create a new definition that is inconsistent with state licensing regulations creates confusion. And since we are listed as "licensed acupuncturists" throughout the states, it seems most appropriate to continue federally defining us as "Licensed Acupuncturists."

DEFINITION OF LICENSED ACUPUNCTURIST SERVICES:

We feel that acupuncture has been well-defined, and rather than define "qualified acupuncture services," that we define "licensed acupuncturist services," not for exclusivity for delivery of services, but to acknowledge that while there are practitioners with versions of acupuncture in scope, the educational requirements are vastly different from those who are studying acupuncture as part of a masters/doctoral education in Traditional Asian Medicine programs. Defining our services allows patients to have access to acupuncture as a whole health system of medicine that also includes Chinese herbs, cupping, moxibustion and heat therapies, movement, meditation and breathing exercises such as Tai Chi and Qi Gong, manual therapies such as tui na massage and gua sha, along with prescriptive point combinations that require a differential diagnosis for treatment planning and execution. And while we are not asking CMS to include our full scope for reimbursement, we do believe it is imperative to distinguish the educational skills acquired in our programs whose techniques are not used as separate modalities for reimbursement of pain, but as a system of medicine that combines all modalities for the purposes of treating disease, illness and pain experienced in epidemic proportions in this country.

While we understand that state and federal legislators are not interested in turf battles between practitioner groups, we are the only medical practitioner group that is named for only one of their modalities in a complex system of medicine, and treated like technicians of a modality. We have watched our peers suffer the consequences of a reduction of their services to only one of their modalities, and are still watching them fight for expanded inclusion of services and a place in mainstream allopathic-centered patient care.

If we continue down the current path of expanding acupuncture services, but do not take steps to highlight and acknowledge our educational requirements, it tells our students and practitioners that the bulk of what we learned is not considered valuable or useful, and we risk having a chilling effect on the industry as a whole and are beginning to see programs shut down in response.

Before we keep hurtling down the path of reduction of services, we need to take steps to ensure that patients have access to the practitioners of acupuncture who have studied its theories extensively. It's important not only to understand that acupuncture works, but also why it works and that it works in conjunction with other forms of medicine. Without this discernment, our practitioners struggle to the meet the extensive burden of federally-granted student loan debt that they incur while in school. While most federal definitions defer to the states on licensing scope, we are in a unique situation in which all practitioner groups are categorized individually and honor pathways for leadership and advisory roles, yet we are excluded because we do not get our degrees from allopathic-medical schools or mainstream educational institutions.

While it is unusual to define a federal scope, we feel it is imperative to delineate tiers for acupuncture services based on educational requirements for licensure, rather than simply focusing on acupuncture services alone, as there is an enormous difference in treatment planning and execution of services.

EXPANSION OF GRADUATE MEDICAL EDUCATION:

Licensed Acupuncturists are the only practitioner group with thousands of hours in didactic and clinical training in both acupuncture technique and theory. We are proficient in allopathic medicine concepts that include anatomy, physiology, biology and chemistry, as well as disease model symptoms identification and intensive training for emergency department referrals. We take multiple board exams, depending on state requirements for licensure that include separate tests for Acupuncture, Chinese Herbs, Asian Bodywork (not offered separately, but included,) and Biomedicine that includes physical and manual therapies and disease symptom identification. We are certified in Clean Needle Technique BEFORE we enter clinical training.

While other groups are required to display proficiency in their own fields, there are no nationally accredited proficiency exams for acupuncture among other practitioner groups who have acupuncture in scope of practice. Yet, we require oversight by CMS from practitioners who know limited versions of acupuncture. In the case of recent 2020 CMS guidelines defining coverage of acupuncture for Chronic low back pain (Clbp,) we require oversight from practitioners such as physician assistants and nurse practitioners, who learn no acupuncture in their standard curriculums at all. We feel this a patient safety and access issue and that patients deserve access to the highest quality of services our medicine has to offer.

Again, we are not asking for exclusivity of our services. We are asking to be included in the US medical complex, where acupuncture is already being used and reimbursed for services by practitioners who know very little about our medicine. We are asking that we define the difference so that we can be included in federal programs and achieve parity in reimbursement, as all other practitioner groups with masters/doctoral level programs are allowed to achieve.

DIVERSITY, EQUITY AND INCLUSION:

There is an enormous move in this country to meet the needs of our diverse minority populations. Asian Americans experience high rates of discrimination, with a rise in violent rhetoric and attacks since the pandemic began. Anti-Asian sentiment is pervasive within our medical system as well. We, as a profession and industry have been told that while our medicine is accepted globally and its methods are often utilized in allopathic medical delivery, it is "experimental", "exploratory", and not considered for reimbursement of services without the evidence to prove we belong there.

We have spent decades passing state licensing statutes, working to be added to the Essential Healthcare Services list of states gearing up for any potential disease outbreak, creating and maintaining free-standing institutions with an accrediting body, national board certification exams, working with active military and veterans, and working in progressive integrative hospital settings and specialty health centers.

If we are to meet the needs of vulnerable populations, equitable policy must create a pathway for American citizens and their families, for whom this medicine is NOT alternative or complimentary; but rather, is primary care for millions of people. Moreover, of the tens of thousands of Licensed Acupuncturists, the majority of our practitioners are Asian and Asian-American.  It is not enough to expand scholarship access to and representation in allopathic graduate medical education or make a concerted effort to hire bilingual practitioners or interpreters. We must also consider ways in which minority populations with their own whole-health medical systems have access to their medicine inside mainstream healthcare delivery settings.

With evidence showing Licensed Acupuncturists can be of value in integrative teams that include, but are not limited to, pain management, substance use disorders, oncology, obstetrics, and traumatology in current settings for a small number of individual practitioners, we ask that Congress seek answers from ACGME for a plan to include non-allopathic systems of medicine in federal delivery models of healthcare.

Along with the amendments, submitted, we ask for a joint resolution expressing the sentiment of Congress that Traditional Asian Medicine is a nationally-recognized and accredited medical system comprised of accredited institutions with full medical curriculums approved by the Department of Education for federal student loan disbursement. We ask that Congress urge ACGME to create more pathways for primary care inclusion and residency programs, especially for practitioner groups that are on the front line of chronic pain conditions and substance use disorders caused by opioid distribution within medical environments.

We feel that as requests to include non-opioid methods of delivery and incorporate patient-centered teams to achieve better outcomes, graduate medical education and primary care residency programs should reflect that in educational settings, with as many viable options for recovery from pain and disease are possible.

We offer to work with all major stakeholders within the field of acupuncture to further provide a more comprehensive acupuncture bill, as well as work with ancillary (to our field) healthcare providers who seek inclusion or expansion within our bill, or an exemption from the language.

We, the undersigned, have spent the last two years learning valuable grassroots techniques and building unity within our industry. We will be actively reaching out to provide cosponsors, a companion bill in the Senate, and a plan to shepherd the language throughout the 118th Congressional Session.

Dr. Kallie Byrd Guimond, AcuCongress    Contact the author of the petition