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Submitted to the New York Times

On Thursday, June 29, 2001, New York Times reporter Somini Sengupta, in an article, "Do-Little Albany? Not for Podiatrists or Bitten Dogs," wrote, "It has been a lucky year for podiatrists, though. They got one bill that allows them to be certified as acupuncturists, just like doctors and dentists…" Though such a bill has been introduced, it is far from becoming law. Fortunately, the podiatric acupuncture certification bills (S.01778 and A.03788) have never moved beyond passing the Senate in the three legislative years they have been introduced. These bills would allow podiatrists to practice acupuncture with the 300-hour training requirement now limited to physicians, dentists and osteopaths. The main question is, "Is it valid and appropriate for allied health professionals to practice acupuncture with educational standards far lower than that of New York State licensed acupuncturists?"

In New York and nearly forty other states, the entry-level requirements which lead to licensure in acupuncture for those with no prior medical training include master's-level education at an accredited school, and passing the national certification exam in acupuncture. The average accredited acupuncture program in the United States (there are at least 42, including seven in New York) has an average of 2,642 total program hours (1,725 is the minimum). This includes 1,130 hours in acupuncture theory and 909 hours clinical practice, for a total of 2,029 hours in acupuncture theory & practice. It also includes 492 hours in Western medical sciences (360 is the minimum), which are waived for health professionals who already have such training. Nationally-certified acupuncturists also complete regular continuing education to maintain certification.

By contrast, 300-hour abbreviated acupuncture training programs for physicians and dentists have no core curriculum, no minimum educational standards and no qualifying examination to ensure basic competency. Students often receive much of their training at home with videotapes, and rarely perform supervised clinical practice on the public. And physician programs offer no "specialty track," (e.g. gynecology, dentistry, sports medicine, neurology, orthopedics). All students train in a group, without regard to the specific patient population they serve. And the "cookbook" treatments taught in abbreviated programs are clinically less successful than individually tailored treatment. Certified acupuncturists have no continuing education requirement.

This raises serious quality of care questions for acupuncture patients, such as: How can the public ascertain the difference between a certified acupuncturist with abbreviated training and a fully-trained licensed acupuncturist? How can a patient tell if a certified acupuncturist has training that meets any kind of standard since a standard has not been established? How can abbreviated training programs be justified, when New York State recognizes acupuncture as a subject worthy of master's-level training? To date, none of the arguments offered by advocates of abbreviated training are based on quality of patient care.

To compound the problem, many insurance companies will pay for acupuncture treatment only if it is performed by a physician, so that patients are often denied coverage if they choose to see a fully-trained and licensed acupuncturist. Insurance parity, which is already law in California, Florida, Maine and Oregon, would require insurance companies that cover acupuncture care, to do so for licensed as well as certified providers.

New York was the second state in America to pass an acupuncture statute. Our 1974 law was intended to promote research into this new field, not provide a fast track to patient care. At that time, it was not known what training was required to learn and practice acupuncture properly. 27 years later, it is very clear that 300 hours is far from adequate. This is evidenced by insurance companies like Oxford Health Plans, who only admit nationally-certified acupuncturists in their provider lists

It is at best questionable for an allied healthcare provider to assume they are capable of adequately understanding a body of work that acupuncture students spend three years studying simply because they are a healthcare provider. Acupuncturists do not assume that with a survey-like course of say 300 hours that they could begin to diagnose western medical conditions, or provide dental or podiatric care. No one has yet adequately explained why practicing acupuncture would be any different.

The skills necessary for such diverse practices as medicine, podiatry or dentistry do not transfer to acupuncture practice. There is very little in the education of a podiatrist, physician or dentist that prepares them for acupuncture practice. There is no overlap in training beyond the hours in biomedical sciences. The ability to give an injection, draw blood or perform surgery is of little relevance to the practice of acupuncture. Acupuncture is a complex healthcare system, requiring serious study. Even if it was just another technique, acupuncture could not be learned properly in 300 hours.

Simply because a practitioner has not hurt anyone does not mean that they have helped them. Doing no harm is not the same as doing good. Some licensed acupuncturists have experience with training physicians in 300-hour acupuncture programs. Their most common finding is that the physicians, understandably, feel incompetent, particularly alongside students of a professional training program.

Podiatrists claim that, with acupuncture certification, they will "only treat the foot." This statement is misleading. Podiatrists have openly stated that they will in fact be able to use acupuncture points anywhere on the body to treat the foot. This then leads to podiatrists treating conditions using points that have effects on areas and functions unrelated to the feet.

Article 141, Section 7001 of the NYS Education Law states that "The practice of podiatry shall not include treating any part of the human body other than the foot." If podiatrists are not allowed to treat the hip or neck, even for the purpose of helping the foot, then why would they be allowed to practice acupuncture on those distant areas? With acupuncture certification they will be free to treat a wide range of pathologies, without enough training to even locate acupuncture points accurately. And patients will not know that their podiatrist is limited to treating the foot. Clearly, granting podiatrists the privilege of practicing acupuncture will greatly expand their scope of practice, regardless of how their bills are worded

Two wrongs do not make a right. It is inappropriate for physicians and dentists to practice acupuncture without meeting established national standards for proper theoretical and practical training. Extending the same error into the podiatric profession does not serve the public. If passed, the podiatric acupuncture bills would create a new population of inadequately trained practitioners. Over the years acupuncturists have raised educational standards substantially to elevate the level of practice in the profession. It would be a grievous error to degrade those standards for a yet larger community of other practitioners. Times readers who would like to learn more about this issue can visit www.ASNY.org.

Michael C. Gaeta, LAc Chairman, Acupuncture Society of New York Faculty member, New York College for Wholistic Health Education and Research