BILL ANALYSIS                                                                                                                                                                                                    







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          |Hearing Date:August 5,         |Bill No:AB                |
          |2002                           |1943                      |
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                  SENATE COMMITTEE ON BUSINESS AND PROFESSIONS
                          Senator Liz Figueroa, Chair

                       Bill No:        AB 1943Author:Chu
                 As Amended:  August 5, 2002        Fiscal: Yes

          
          SUBJECT:  Acupuncture.
          
          SUMMARY:  Codifies and increases entry-level curriculum  
          standards for acupuncturists, in addition to stating  
          legislative intent.

          Existing law:

          1)Provides for the licensing and regulation of  
            acupuncturists by the Acupuncture Board (Board) within  
            the Department of Consumer Affairs (Department).

          2)Defines the practice of acupuncture as the stimulation of  
            a certain point or points on or near the surface of the  
            body by the insertion of needles to prevent or modify the  
            perception of pain or to normalize physiological  
            functions, including pain control, for the treatment of  
            certain diseases or dysfunctions of the body and includes  
            the techniques of electroacupuncture, cupping, and  
            moxibustion.

          3)Requires the Board to establish standards for the  
            approval of schools and colleges offering education and  
            training in the practice of acupuncture, including  
            standards for the faculty in those schools and colleges,  
            and tutorial programs.  Regulations adopted by the Board  
            require a minimum of 2,348 education hours, divided into  
            specified areas.

          This bill:

          1)Provides that it is the intent of the Legislature, in the  





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            event that SB 1951 is enacted in the statutes of 2002, to  
            consider for implementation the recommendations of the  
            Milton Marks 'Little Hoover' Commission on California  
            State Government Organization and Economy to increase  
            curriculum hours for the licensure of acupuncturists in  
            excess of 3,000 hours up to 4,000 hours to fully and  
            effectively provide health services under their scope of  
            practice.

          2)Provides that it is the intent of the Legislature that  
            the Commission shall provide recommendations for  
            reviewing the competence of licensed acupuncturists not  
            subject to the 3,000 hour minimum curriculum requirement,  
            and provide recommendations for training, testing or  
            continuing education that would be required for these  
            individuals to meet the standards for continued  
            licensure.

          3)Requires schools and colleges offering education and  
            training in the practice of acupuncture to include a  
            minimum of 3,000 hours of study in curriculum pertaining  
            to acupuncture, in order to receive approval from the  
            Board for training programs.  Requires the Board to  
            establish the specifics of the 3,000 hours of study by  
            January 1, 2004. 

          4)Provides that the 3,000 hour requirement shall apply to  
            all students entering acupuncture training programs on or  
            after January 1, 2005.

          FISCAL EFFECT:  Unknown.

          COMMENTS:
          
          1.Purpose.  According to information provided by the  
            Author, this measure was introduced to increase  
            educational standards and quality of care for individuals  
            practicing acupuncture in the state of California.  The  
            Author believes that increased professional standards  
            would result in increased quality of care for consumers  
            and produce a pool of more confident and experienced  
            acupuncture practitioners to meet the growth and demand  
            for acupuncture treatment.

          2.Authority of the Acupuncture Board.  The Legislature has  
            authorized the Board to establish standards for approval  





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            of institutions and colleges offering education and  
            training programs in the practice of acupuncture and  
            oriental medicine.  Additionally, the Legislature has  
            authorized the Board to establish the amount and content  
            of the education required to be licensed as an  
            entry-level acupuncturist.

          3.Chronology of Curriculum Hours for Acupuncturists.  In  
            1975, certification standards were legislated in  
            California at 1,350 hours.  650 acupuncturists were  
            grandfathered into the system.  Acupuncture, acupressure,  
            moxibustion, and cupping were initially included in the  
            acupuncturists' scope of practice.  In 1980, legislation  
            expanded the definition of acupuncture to include  
            techniques of electroacupuncture, cupping and  
            moxibustion, and the use of herbs, nutrition, Oriental  
            massage, and exercise (Chapter 1313, Statutes of 1980).   
            In 1985, educational standards were increased to 2,348  
            hours (1,548 of theoretical training and 800 hours of  
            clinical instruction).  In 2000, the Board proposed an  
            increase of curriculum hours to 3,200 hours through  
            administrative regulations.  In 2002, the Board- created  
            Task Force on Competencies voted to adopt recommendations  
            for an increase of curriculum to 3,000 hours.

          4.How Many Board Approved Schools Will Be Impacted by this  
            Legislation?  There are currently 30 Board approved  
            schools.  It appears that 11 of the 30 schools are below  
            3,000 hours.  Therefore, at least 11 schools will have to  
            modify their curriculum to retain their approval status  
            with the Board.  Additionally, while 19 of the Board  
            approved schools may currently offer a program above  
            3,000 hours there is no guarantee that their specific  
            curriculum will be the same as what is approved by the  
            Board.  Therefore, even schools above 3,000 may have to  
            make changes to their curriculum.

          5.Is the Increase in Hours Justified or Just a Barrier to  
            Entry?  Generally speaking, requirements and standards  
            should only be increased when there is data indicating  
            that there is injury to the public, or that there are  
            specific educational deficiencies.  Absent this  
            justification, increased hours can be viewed as an  
            unnecessary barrier to entry.

            According to the letter of support from the Council of  





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            Acupuncture and Oriental Medicine Associations (Sponsor),  
            their profession has long held that 4,000-hour training  
            programs should be the minimal standard for the  
            profession.  The Sponsor states that educational  
            standards were last raised to 2,348 in 1985 and schools  
            have since continued to swell their programs up over  
            3,100, including 750 hours of unstandardized curriculum.   
            The Sponsor states that 35% of licensees surveyed report  
            that their acupuncture training program did not  
            adequately prepare them for their first year in practice.

            Proponents argue generally that students should expect  
            quality education, regardless of which school they  
            attend.  Proponents point out that current education  
            standards for acupuncture have not changed since 1984,  
            while the profession has grown and changed significantly,  
            and that this bill will standardize education so that  
            graduates will be better equipped to serve in the complex  
            arena of modern health care.

            On the other hand, the proposed increase of hours may  
            have an adverse impact on students and colleges.  The  
            increase will most likely require colleges to increase  
            didactic and clinical faculty, classrooms and other  
            resources to accommodate the additional hours.  The  
            financial impact on colleges has been estimated in the  
            millions of dollars.  The additional hours could add up  
            to a year to current programs, which will substantially  
            increase student tuition and loans.

          6.Joint Legislative Sunset Review Committee and SB 1951.   
            The Joint Legislative Sunset Review Committee (Joint  
            Committee), pursuant to statutory requirements, reviews  
            licensing boards approximately every four years.  The  
            Board is one of several health-related boards that  
            underwent review by the Joint Committee between 2001-02.   
            As part of this review process, both the Joint Committee  
            and the Department make recommendations regarding the  
            operation of these boards and the regulation of the  
            professions.  

            Specific to the educational requirements and scope of  
            practice of acupuncturists, the Department and the Joint  
            Committee both recommended further study of the  
            acupuncture profession by an independent consultant.  The  
            Joint Committee report states that:  "There is much  





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            debate within the acupuncture profession surrounding the  
            level of education that is needed for acupuncturists to  
            practice effectively, and the scope of practice which  
            determines exactly what tasks they may or may not  
            perform.  The Board has acknowledged this debate by  
            establishing the Task Force on Competencies and Outcomes.  
             The Department concurs with the Joint Committee's  
            preliminary recommendation that the scope of practice for  
            acupuncturists needs to be clarified and codified in  
            statute.  To resolve this debate, the Department  
            recommends an independent consultant be retained by the  
            Department, with funding provided by the Board, to assess  
            the educational needs of practitioners and the scope of  
            practice of acupuncturists.  As the practice of  
            acupuncture evolves, it may be necessary to make changes  
            to the practice act in order to reflect contemporary  
            health care.  To prepare for these changes, this  
            independent health care consultant working with the  
            Department should assess the practice and report to the  
            Board, the Department, and the Joint Committee prior to  
            the Board's next sunset review."

            SB 1951 (Figueroa) was introduced to incorporate the  
            recommendations of the Joint Committee relative to the  
            Board.  SB 1951 as initially amended, required an  
            independent consultant to conduct a comprehensive  
            analysis of the scope of practice and educational  
            requirements for acupuncturists, and makes other changes  
            related to the Board.  It should be noted that the Author  
            of SB 1951 recently agreed to accept an amendment that  
            will request the Little Hoover Commission, rather than an  
            independent consultant, to conduct the specified  
            comprehensive analysis.

          7.Does the Measure's Intent Language Undermine SB 1951?   
            According to the letter of opposition from the Council of  
            Colleges of Acupuncture and Oriental Medicine (Council),  
            the Council strongly believes that AB 1943's intent  
            language undermines the Joint Committee's recommendation  
            in SB 1951.  The Council argues that the intent language  
            is attempting to circumvent the role of the Little Hoover  
            Commission by limiting its investigative authority.  The  
            Council states that AB 1943's intent language predisposes  
            that the Little Hoover Commission is required to find  
            that education hours for colleges must exceed 3,000  
            hours.  According to the Council, this does not allow the  





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            Little Hoover Commission to determine through its own  
            research and public hearings the appropriate number of  
            education hours.  By implication, AB 1943 would preclude  
            a finding by the Little Hoover Commission that less than  
            3,000 hours for a core curriculum of a college may be  
            sufficient.

            According to the Accreditation Commission for Acupuncture  
            and Oriental Medicine (ACAOM), the legislative intent  
            language basically has the effect of biasing or  
            predisposing the Little Hoover Commission to recommending  
            increases to the curriculum requirement to a level up to  
            4,000 hours.  The ACAOM argues that this language is  
            inconsistent with SB 1951 and thwarts the intent of the  
            Joint Committee which is to have the Little Hoover  
            Commission (or an independent consultant) provide an  
            "independent" and unbiased assessment as to the  
            appropriate educational standards for licensure,  
            including whether they should remain as they are,  
            increased, or decreased.  If, for example, the Little  
            Hoover Commission believes that 3,000 hours or less was  
            adequate to protect consumers, AB 1943 would prevent a  
            fully independent assessment of what the educational  
            standards should be relative to the best interests of the  
            consumer.  The ACAOM believes that it biases the entire  
            "assessment" towards increasing hours, which is not an  
            "independent assessment" and is not what SB 1951  
            contemplates.  The ACAOM proposes the following  
            amendment:  "It is the intent of the Legislature to  
            consider for implementation, if SB 1951 is enacted...,  
            the recommendations of the Milton Marks 'Little Hoover'  
            Commission on the curriculum requirements for the  
            licensure of acupuncturists."

            An alternative approach suggested by the ACAOM is to  
            change the intent language as follows:  it is the intent  
            of the Legislature to consider for implementation, if SB  
            1951 (Figueroa) is enacted in the statutes of 2002, [  the  ]  
            ANY recommendations of the Milton Marks "Little Hoover"  
            Commission on California State Government Organization  
            and Economy to increase curriculum hours for the  
            licensure of acupuncturists in excess of 3,000 hours up  
            to 4,000 hours to fully and effectively provide health  
            services under their scope of  practice.

          8.Should the Implementation Timeframe Be Extended to 2006?   





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            According to the letter of opposition from the Council,  
            while they appreciate the language delaying the  
            implementation of the 3,000-hour requirement until 2005,  
            this still imposes difficulties for colleges.  The  
            Council states, as it is expected that it will take  
            approximately two years for the Board to determine and  
            approve curriculum and promulgate regulations, very  
            little time, if any, would be left for colleges to  
            institute new courses, and hire the faculty necessary to  
            comply with the law.  For this reason, the Council  
            requests that the effective date be changed to January 1,  
            2006.

          9.Author Does Not Intend to Grandfather Current Licensed  
            Acupuncturists.  This measure expresses the intent of the  
            Legislature to have the Little Hoover Commission provide  
            recommendations for reviewing the competencies of  
            licensed acupuncturists not subject to the 3,000 hour  
            minimum curriculum requirement and provide  
            recommendations for training, testing or continuing  
            education that would be required for these individuals to  
            meet the standards for continued licensure.  It is  
            appropriate and necessary for the Legislature and the  
            Board to ensure the competency of those acupuncturists  
            not subject to the increase in hours.

          
          SUPPORT AND OPPOSITION:
          
           Support  :
          American Association of Oriental Medicine
          American College of Oriental-Western Integrated Medicine
          American Federation of Government Employees AFL-CIO Local 2391
          Association of Korean Oriental Medicine & Acupuncture of  
          California
          California Acupuncture Board
          California Alliance of Acupuncture Medicine
          California Certified Acupuncturists Association
          California Labor Federation, AFL-CIO
          California State Oriental Medicine Association
          California Teachers of Acupuncture and Oriental Medicine
          Chinese American Civil Rights Organization
          Chinese American Political Action Committee
          Coalition for the Advancement of Traditional Oriental Medicine
          Council of Acupuncture and Oriental Medicine Associations
          Esparza-Katz Productions (Moctesuma Esparza)





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          Florida State Oriental Medicine Association
          Japanese Acupuncture Association of California
          Kiwanis Club of Monterey Park
          National Board of Acupuncture and Orthopedics
          National Guild for Acupuncture and Oriental Medicine
          Sacramento County Supervisor Illa Collin
          San Francisco Labor Council, AFL-CIO
          Sherman Oaks Chamber of Commerce
          United California Practitioners of Chinese Medicine
          South Baylo University
          Southern California University of Health Sciences
          Acupuncture Continuum Clinic
          Acupuncture Wellness Clinic
          Almond Grove Traditional Chinese Medicine & Acupuncture Clinic
          Asahi Comprehensive Health Center
          Balance and Harmony Acupuncture and Oriental Medicine Clinic
          California Acupuncture Center
          California Acupuncture Medical Association
          Chinese Health Institute
          Chinese Herb Academy
          Delicate Balance Health Care Center
          East/West Health Center
          Golden Rainbow Acupuncture
          Healing Touch Acupuncture Clinic
          Kan-Sai Health Center, Inc.
          Las Tunas Acupuncture & Herbs Clinic
          Meridian Acupuncture Clinic
          Numerous individual acupuncturists























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            Opposition  :
          Accreditation Commission for Acupuncture and Oriental  
          Medicine
          Acupuncture and Oriental Medicine Alliance 
          Council of Colleges of Acupuncture and Oriental Medicine
          Emperor's College
          Northwest Institute of Acupuncture and Oriental Medicine
          Oregon College of Oriental Medicine
          Pacific College of Oriental Medicine
          Santa Barbara College of Oriental Medicine
          Tai Sophia Institute


          Consultant:Kristin J. Triepke