Two of the items raised in this petition for rulemaking involve diagnostic exams. One would increase Acupuncturist scope to include diagnostic laboratory exams. Another would add language requiring Acupuncturists to perform basic laboratory exams if patient did not follow recommendation for exam by a medical doctor.  I am concerned that most acupuncture programs do not include ordering and interpreting of lab findings. Would adding these sorts of exams to scope mean that LAcs would be liable if they did not order such exams when warranted or if they did not accurately interpret results?  The regulations at present include a requirement that practitioners recommend a medical exam, without the additional requirement for practitioners to order diagnostic exams. I am unaware of any harm to the public from the current regulation.

I do not see any benefit to requiring LAcs to order laboratory exams, and I am concerned that these changes would leave practitioners responsible for interpreting lab results when many do not have appropriate training to do so.