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Ted Gagliano Priebe

Hello Chris, Since you have mixed a number of issues together I see a need to separate these and add…

Hello Chris,
Since you have mixed a number of issues together I see a need to separate these and address them independently from each other. I agree with you the proposed First Professional Degree proposed by ACAOM and promoted by AAAOM is not needed but for different reasons than you may think. Like the DAOM degree the proposed FPD is a “vanity” degree and serves no purpose in health care or in providing entry into mainstream or what is being promoted as “Integrative Medicine”.
ACAOM- ACAOM is a programmatic or specialty accreditation agency and has the recognition for institutional accreditation. Accreditation provides a mechanism for accrediting commissions created and funded by institutions (CCAOM) to adopt standards and practices by which the institutions essentially “police” themselves. CSOMA on behalf of the CCAOM and AAAOM has continuously attempted to outsource this function to ACAOM. The most recent attempt was AB1260 which failed.
Regionally accredited means the Institution meets the critera required to operate as an Institution and has nothing to do with approving programs. Regional accreditation has been granted to a few schools that also are accredited by ACAOM. Technically, SCUHS accredited programmatically by CCE (The Council on Chiropractic Education) and
is a Western Association of Schools and Colleges (WASC) accredited school and is also accredited for its OM program by ACAOM. Bastyr is also accredited by their own regions (Northwest) regional accreditation agency, Northwest Commission on Colleges and Universities (NWCCU) in addition to ACAOM.
States set standards and enforcement of education (to protect the public) not the U.S Department of Education (DOE) or Regional Accreditation (WASC) and definitely not programmatic specialty accreditation agencies. Regional Accreditation is Institutional not Programmatic.
This is The California Acupuncture Board (CAB) and the Bureau of Private and Postsecondary Education (BPPE) (an entity intended to protect students from scam schools; with enforcement authority) domain to enforce Laws and Regulation for programs, in order to protect the public; this is why the CAB approves schools not ACAOM. The key to this is ACAOM does not meet the California Education requirements for primary care nor do they have written standards for a curriculum that meets California 3000 hr science requirement. All states recognize the IOM primary care educational standards for all primary care providers.
Both accreditation and State licensure/approval address the issue of quality in the educational offerings of private postsecondary institutions, but are totally independent of each other. State licensure/approval provides a mechanism by which institutions that fail to comply with quality standards established by the state can be denied permission to operate in their state. State standards provide different protections for students and accreditation should not be viewed as an alternative or substitute for the adoption and enforcement of state standards. Particular emphasis is placed on assisting schools in aligning curriculum to meet State regulatory and accreditation requirements. The US Department of Education offers this definition:

An institution of higher education operating without supervision of a state or professional agency and granting diplomas which are either fraudulent or because of the lack of proper standards worthless. (DOE Web Site)
Unfortunately, it can be argued most California acupuncture training programs fall into this group for the reasions articulated in my previous post. The same holds for most of the 50 ACAOM approved training programs. The Calif law effectively calls for primary care training for licensed acupuncturists (LAcs). Primary Care is supported given the two 93-11 opinion 1993 and 1995 as well as the LHC and joint Commission report. ACAOM never mentions primary care in any standard.

The ACAOM standard has numerous requirements that are illegal in California, I.E. Electro-dermal diagnostics, http://www.acaom.org/PdfVersion/Structure%20Scope%20and%20Standards...

http://www.acaom.org/PdfVersion/Policies%20and%20Procedures%20Handb... page 49 of PDF

What this means? You can not claim to be a National Institutional /Programmatic Accreditation Agency if you do not meet the Education Standard of the State, i.e.: California.

I hope this clarifies your questions,



Ted Priebe, OMD
Doctor of Oriental Medicine
Lic. No AC-2184
Appointed Member, Medical Evidence Evaluation Advisory Committee (MEEAC)

California Department of Workers’ Compensation, Medical Unit
www.tedpriebe.com 310-801-1462

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Ted Gagliano Priebe Comment by Ted Gagliano Priebe on January 10, 2010 at 12:33pm
States set standards and enforcement of education (to protect the public) not the U.S Department of Education (DOE) or Regional Accreditation (WASC) and definitely not programmatic specialty accreditation agencies. Regional Accreditation is Institutional not Programmatic.
This is The California Acupuncture Board (CAB) and the Bureau of Private and Postsecondary Education (BPPE) (an entity intended to protect students from scam schools; with enforcement authority) domain to enforce Laws and Regulation for programs, in order to protect the public; this is why the CAB approves schools not ACAOM. The key to this is ACAOM does not meet the California Education requirements for primary care nor do they have written standards for a curriculum that meets California 3000 hr science requirement. All states recognize the IOM primary care educational standards for all primary care providers.
Both accreditation and State licensure/approval address the issue of quality in the educational offerings of private postsecondary institutions, but are totally independent of each other. State licensure/approval provides a mechanism by which institutions that fail to comply with quality standards established by the state can be denied permission to operate in their state. State standards provide different protections for students and accreditation should not be viewed as an alternative or substitute for the adoption and enforcement of state standards. Particular emphasis is placed on assisting schools in aligning curriculum to meet State regulatory and accreditation requirements. The US Department of Education offers this definition: An institution of higher education operating without supervision of a state or professional agency and granting diplomas which are either fraudulent or because of the lack of proper standards worthless. (DOE Web Site) What this means? You can not claim to be a National Institutional /Programmatic Accreditation Agency if you do not meet the Education Standard of the State, i.e.: California.
Primary Care as required by Section 4926 is related to the fundamental status and responsibilities of the practitioner in relationship to the public and has nothing to do with the clinical practice of acupuncture as noted Section 4937. This is consistent with all primary care practitioners in the US regardless of their particular treatment specialties. Section 4926 cannot be used to expand the scope of acupuncture practice, which no one would want to do anyhow. We just need to assure that the overall nomenclature and educational requirements to be real medical science including science based needling therapy.
Best Regards,
Ted Priebe, OMD Doctor of Oriental Medicine Lic. No AC-2184 Appointed Member, Medical Evidence Evaluation Advisory Committee (MEEAC)
California Department of Workers' Compensation, Medical Unit www.tedpriebe.com 310-801-1462
scott Comment by scott on December 11, 2009 at 11:36am
Ted,
I'm not entirely sure that I am following you with regards to accreditation issues. Are you saying that CA acupuncture training programs are not supervised by state or professional agencies are possibly granting fraudulent degrees? Are they not accredited by the ACAOM and approved by the CA board of higher education?

I only ask this because a colleague of mine fulfilled the CCAOM standard of 60 hrs of college coursework to gain entry into a school of TCM and graduated with a combined BS/MS. This person wanted to pursue biomedicine with the hopes of combining it with her TCM training and applied to 3 post-baccaleurate pre-med programs. All 3 rejected her because these universities did not recognize her the conferred BS degree that was combined with her MS--they only recognized her coursework from junior college. The little that I understand is that regionally accredited institutions (non-profit colleges and universities) do not always accept credits or confirm degrees from nationally accredited institutions (trade schools, other for-profit institutions of higher learning, including many colleges of TCM).

Are you able to clarify?

Thanks

Scott

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