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.