BILL ANALYSIS Ó
SB 218
Page 1
Date of Hearing: August 6, 2013
ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER
PROTECTION
Susan A. Bonilla, Chair
SB 218 (Yee) - As Amended: August 5, 2013
SENATE VOTE : 23-6
SUBJECT : Healing arts.
SUMMARY : Authorizes the creation of a non-profit California
Traditional Chinese Medicine Traumatology Council (Council),
requires the Council to develop standards for the education and
training of applicants, and authorizes the Council to issue
certificates to qualified applicants to practice as a California
certified traditional Chinese medicine traumatologist (CCTCMT),
and to discipline certificate holders for specified violations.
Specifically, this bill :
1) Defines "California traditional Chinese medicine
traumatology" (TCMT) as including a range of treatments to
address both acute and chronic musculoskeletal conditions
through stimulation of acupressure points. Techniques
include, but are not limited to, brushing, kneading, rolling,
pressing, rubbing, pushing, holding, and lifting the areas
between each of the joints to open the body's defensive chi
and stimulate the energy movement in the meridians.
2) Defines a "California certified traditional Chinese medicine
traumatologist" as "a person who has been certified by the
Council to perform California traditional Chinese medicine
traumatology."
3) Requires the establishment of the Council, which shall be a
non-profit organization exempt from taxation as specified,
for the purpose of developing standards for, and certifying
the practice of, TCMT.
4) Authorizes the Council to commence activities after
submitting a request to the Internal Revenue Service seeking
the exemption.
5) Specifies that the Council shall consist of five members,
each of whom shall serve four year terms:
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a) Two representatives from the clinical settings of
traumatology;
b) One representative from the Medical Board of California;
and,
c) Two representatives from the California Medical
Association.
6) Requires that the representatives from the clinical settings
of traumatology be selected by professional societies,
associations, or other entities, whose memberships are
comprised solely of practitioners of TCMT.
7) Clarifies that the selecting professional society,
association, or entity must have a dues-paying membership in
California of at least 30 individuals for the last three
years and shall have bylaws that require its members to
comply with a code of ethics.
8) Requires the meetings and deliberations of the Council to be
subject to the provisions of the Bagley-Keene Open Meeting
Act, and all hearings shall be subject to the provisions of
the Ralph M. Brown Act.
9) Requires the Council to issue the title and certificate for
CCTCMT to any applicant who applies on a form developed by
the Council and meets all of the following requirements:
a) Is at least 18 years of age;
b) Is not subject to denial for reasons related to the
making of false statements, conviction of a crime, acts
involving dishonesty or deceit, acts that would otherwise
constitute grounds for suspension or revocation of a
license under the Business and Professions Code, and a lack
of good moral character, as specified;
c) Passes a written examination developed and administered
by the Council that tests the applicant's ability,
competency, and knowledge in the practice of TCMT; and,
d) Completes and furnishes:
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i) For an applicant who has completed education and
training outside of the United States or Canada,
documented evidence of education and training, and at
least eight years of clinical experience in TCMT that
meets the standards established by the Council; or,
ii) For an applicant who has completed education and
training inside the United States or Canada, a
certificate in TCMT upon completion of a curriculum in
the subject, which provided adequate instruction in
thirteen specified subjects, as well as 1,000 hours in a
clinical internship in TCMT.
10) States that
documentation of education and training may include degrees,
certificates, transcripts, and proof of academic or clinical
residency.
11)Requires the Council to investigate all of the documentation
provided by the applicant and verify its authenticity to
evaluate whether an applicant meets the certification
standards, including the level of experience and training to
sufficiently qualify for the traumatology certification.
12) Requires the
certificate holder to renew his or her certificate every two
years.
13) Requires the
Council to develop and report to the Legislature by January 1,
2016, all of the following:
a) The standards for approval of educational and clinical
training programs;
b) The standards for evaluating the education, training,
and clinical experience of an applicant;
c) The written examination; and,
d) A continuing education program.
14) Prohibits a CCTCMT
from practicing medicine, or practice within the scope of
activities regulated by the State Board of Chiropractic
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Examiners.
15) Requires an
applicant for certification to file an application with the
Council.
16) Prohibits an
individual who is not qualified to receive the title and
certificate from holding himself or herself out as a CCTCMT.
17) Requires
certificate holders to notify the Council of his or her home
address and any business address where he or she regularly
practices, whether as an employee or as an independent
contractor, and further requires the certificate holder to
notify the Council of any change of address within 30 days of
the change.
18) Requires the
certificate holder to include the name under which he or she
is certified and his or her certificate number in all
advertising, and to display his or her original certificate at
his or her place of business.
19) Requires the
certificate holder, upon request at the location where he or
she practices, to provide the name under which he or she is
certified and the certificate number to a member of the
public, the Council, or a member of law enforcement or a local
government agency.
20)Requires applicants to pay an application fee and a renewal
fee, to be set by the Council in an amount not to exceed the
amount required to cover the reasonable cost of administering
the program.
21)Requires that moneys received by the Council be utilized by
the Council to pay for the costs associated with
administering these provisions.
22)Requires the Council to provide a breakdown of costs
associated with administering these provisions on an Internet
Web site.
23)Declares that it is an unfair business practice for any
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person to hold himself or herself out as a CCTCMT or to use
the title of "California certified traditional Chinese
medicine traumatologist" without meeting the specified
requirements.
24)Declares that it is a violation of these provisions for the
certificate holder to commit, and the Council may deny an
application for a certificate or suspend or revoke a
certificate for, any of the following, as specified:
a) Unprofessional conduct, as specified;
b) Procuring a certificate by fraud, misrepresentation, or
mistake;
c) Violating or attempting to violate, directly or
indirectly, or assisting in or abetting the violation of,
or conspiring to violate, any of these provisions, or any
rule or bylaw adopted by the Council;
d) Conviction of any felony, or conviction of a misdemeanor
that is substantially related to the qualification or
duties of a certificate holder;
e) Impersonating an applicant or acting as a proxy for an
applicant;
f) Impersonating a CCTCMT, or allowing an uncertified
person to use a certificate;
g) Committing any fraudulent, dishonest, or corrupt act
that is substantially related to the qualifications or
duties of a certificate holder; or,
h) Committing any act punishable as a sexually related
crime.
25) Requires the
Council to investigate within 30 days any consumer complaints
against a certificate holder, and further requires the Council
to establish an Internet Web site where consumers may file
complaints, including a web-based complaint form.
26) Prohibits the
Council from disciplining or denying a certificate to a
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certificate holder or applicant except according to these
provisions.
27) Requires the
Council to act in good faith and in a fair and reasonable
manner in denying an application or disciplining a certificate
holder, and further deems certain procedures to be "fair and
reasonable," as specified, although a court may also find
other procedures to be fair and reasonable when the full
circumstances or considered.
28)Deems disciplinary procedures to be fair and reasonable if
specifically authorized by statute or if all of the following
apply:
a) The procedures has been set forth in the articles or
bylaws of the Council, and such provisions are provided
annually to all members;
b) The procedures provide for 15 days' prior notice of the
discipline to the certificate holder and the reasons
therefor;
c) The procedures provide an opportunity for the accused to
be heard, orally or in writing, not less than five days
before the effective date of the discipline by the
decision-making body;
29)Requires notice of discipline to be given by a method
reasonably calculated to provide actual notice, as specified.
30)Authorizes the Council to discipline a certificate holder by
probation, suspension for a period not to exceed one year,
revocation, suspension, or other authorized action, as
specified.
31)Authorizes the Council to issue an initial certificate on
probation, with specific terms and conditions.
32)Requires the Council to take all of the following actions if
it receives notice that a certificate holder has been arrested
and charges alleging specified offenses have been filed,:
a) Immediately suspend the certificate on an interim basis;
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b) Notify the certificate holder within 10 business days of
the suspension and the reasons therefor; and,
c) Notify the employer, if known, of the certificate
holder, within 10 business days of the suspension.
33)Requires the suspended certificate, upon notice of a
conviction, to be permanently revoked; and further requires
the Council to provide notice to the certificate holder of the
existence of that evidence within 10 business days, and that
the certificate will be revoked within 15 business days unless
countervailing evidence is provided by the certificate holder.
34)Requires that any action challenging discipline or denial,
including claims of defective notice, to be commenced within
one year after the date of the certificate denial or
discipline; and further authorizes a court to grant relief,
including reinstatement, if it finds that relief to be
equitable under the circumstances.
35)Declares that denial or discipline based on substantive
grounds that violates contractual or other rights, or is
otherwise unlawful, is not made valid by compliance with these
provisions.
36)Requires the Council, upon notice to the Council that the
charges resulted in an acquittal, to immediately reinstate a
suspended certificate and provide notice of the reinstatement
within 10 business days to any business that previously
received a notice of suspension.
37)Requires the Council, notwithstanding any other law and if it
receives clear and convincing evidence that a certificate
holder has committed an act punishable as a sexually related
crime or felony that is substantially related to the
qualification, functions or duties of a certificate holder, to
immediately suspend the certificate; further requires the
Council to consider any available mitigating evidence, except
as specified.
38)Requires the Council, if it suspends a certificate for a
sexually related crime or felony substantially related to the
qualification, to take the following additional actions:
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a) Notify the certificate holder within 10 business days of
the suspension, the reason therefor, and the holder's right
to request a hearing;
b) Notify any employer or contractor, and the appropriate
local government permitting authority, within 10 business
days of the suspension; and,
c) Hold a hearing within 30 business days, if the holder of
the suspended certificate so requests in writing, to
challenge the factual basis for the suspension.
EXISTING LAW:
1)Establishes the California Massage Therapy Council (CAMTC) and
defines the responsibilities and duties of the CAMTC.
(Business and Professions Code (BPC) Section 4600.5)
2)Requires the CAMTC to issue a "massage therapist" or
"massage practitioner" certificate to an applicant, who
submits a written application and provides satisfactory
evidence that he or she meets all of the specified
education, experience or examination requirements. (BCP
4601)
3)Makes the unlawful practice of medicine a public offense
that may be punishable as either a misdemeanor or felony.
(BPC 2052)
4)Regulates and licenses the practice of acupuncture by the
Board. (BPC 4928)
5)Defines 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. (BPC 4927)
6)Requires the California Acupuncture Board to issue a
license to practice acupuncture to any person who makes
an application, pays specified fees, and meets specified
requirements. (BPC 4938)
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7)Makes the unlawful practice of acupuncture a public offense
that may be punishable as a misdemeanor, with a fine of not
less than $100 and not more than $2,500, or imprisonment in a
county jail for a period not exceeding one year, or both.
(BPC 4935)
8)Requires the Board to establish standards for the
approval of schools and colleges offering education and
training in the practice of an acupuncturist, as
specified, and requires training programs to include
3,000 hours of study in curricula pertaining to the
practice of acupuncture. (BPC 4939)
9)Requires each acupuncturist to complete 50 hours of
continuing education every two years as a condition of
renewal of his or her license. (BPC 4945)
FISCAL EFFECT : Unknown
COMMENTS :
1)Purpose of this bill . This bill would provide certification
and title protection for the practice of "traumatology" - a
branch of traditional Chinese medicine - to be overseen by a
non-profit Council authorized in statute. Underlying concerns
with the bill include questions as to its necessity, whether
its provisions will ultimately inform or potentially confuse
consumers, and whether or not the statute contains sufficient
consumer protections and legislative oversight. This bill is
sponsored by the American Traditional Chinese Medicine
Traumatology Association (ATCMTA).
2)Author's statement . According to the author, "Traumatology is
an unregulated practice in the State of California. No
government body oversees Traumatology's level of education,
training and experience. SB 218 (Yee) will place this practice
under a non-profit's oversight and assure the public in a
standard level of experience, training and care."
3)Understanding traumatology and "Traditional Chinese Medicine" .
As defined by this bill, "California traditional Chinese
medicine traumatology" includes "a range of treatments to
address both acute and chronic musculoskeletal conditions
through stimulation of acupressure points. Techniques include,
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but are not limited to, brushing, kneading, rolling, pressing,
rubbing, pushing, holding, and lifting the areas between each
of the joints to open the body's defensive chi and stimulate
the energy movement in the meridians."
It should be stressed that the bill's own provisions appear to
restrict the scope of practice of CCTCMTs to acupressure
alone, which is one of a larger number of modalities
traditionally associated with traumatology. The bill
explicitly excludes the practice of medicine and chiropractic,
and the practice of acupuncture or physical therapy without a
license is prohibited by existing law.
Traumatology is considered a subset of traditional Chinese
medicine, and, according to the author, has been practiced in
an unlicensed fashion in California for roughly 150 years.
Western medicine also uses the term "traumatology" to describe
the unrelated study of wounds and injuries caused by accidents
or violence and the repair of those wounds and injuries, and
should not be confused with the practices of TCM.
According to the National Center for Complementary and
Alternative Medicine (NCCAM) within the National Institutes of
Health, the broader category of TCM originated in ancient
China and has evolved over thousands of years. "TCM
practitioners use herbs, acupuncture and other methods to
treat a wide range of conditions?The TCM view of how the human
body works, what causes illness, and how to treat illness is
different from Western medicine concepts?The human body is
regarded as an organic entity in which the various organs,
tissues, and other parts have distinct functions but are all
interdependent. In this view, health and disease relate to
balance of the functions."
NCCAM also notes the breadth of its use: "Today, TCM is
practiced side by side with Western medicine in many of
China's hospitals and clinics. TCM is widely used in the
United States. Although the exact number of people who use
TCM in the United States is unknown, it was estimated in
1997 that some 10,000 TCM practitioners served more than 1
million patients each year.
However, NCCAM also strikes a note of caution: "Although TCM
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is used by the American public, scientific evidence of its
effectiveness is, for the most part, limited. Acupuncture
has the largest body of evidence and is considered safe if
practiced correctly. Some Chinese herbal remedies may be
safe, but others may not be."
As of 2012, there were approximately 60 accredited TCM
educational institutes nationwide, with 20 located in
California. There are no known national standards for
traumatologists. Currently, traumatology courses are offered
in accredited schools for acupuncture, but there is no known
school in California that teaches traumatology exclusively.
4)Understanding the non-profit "massage therapy" model of
professional certification . The non-profit Council proposed to
be created by this bill was modeled after the non-profit
California Massage Therapy Council (CAMTC) currently
overseeing the certification and discipline of massage
practitioners.
CAMTC was enacted in 2008 (SB 731 (Oropeza), Chapter 384) to
create a standardized system of voluntary statewide
certification of massage professionals. Current law makes it
an unfair business practice for anyone not certified by CAMTC
to use certain massage-related titles. Applicants for
certification must complete a specified number of educational
hours and pass an examination which is administered by the
National Certification Board for Therapeutic Massage and
Bodywork (NCBTMB). The statutes related to regulation of
massage therapy and CAMTC will sunset on January 1, 2015
unless extended by legislative action.
CAMTC is led by a volunteer board of directors comprised of
professionals from California's massage community, including
massage associations, schools, and businesses. While CAMTC
does not accredit or approve schools, it does have the
responsibility to determine if the curriculum of schools meets
the legal requirements for applicants to obtain certification.
Schools must either be nationally accredited or approved by
the California Bureau for Private Postsecondary Education or a
California community college. CAMTC regulates approximately
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38,000 certified massage professionals.
If a certificate holder violates the terms of certification,
CAMTC is authorized to suspend or revoke the holder's
certification, but CAMTC has no cite and fine authority.
CAMTC may deny, discipline or revoke certification for a
variety of reasons including: failure to obtain a clear
fingerprint check; reports of unprofessional conduct in
another state; any attempt to obtain a certificate through
misrepresentation or fraud; or committing any act punishable
as a sexually-related crime. All of the relative disciplinary
procedures are carried out by an employee of CAMTC. Since
2010, there have been approximately 130 certificate
suspensions or revocations.
5)Arguments in support . According to the American Association
of Acupuncture & Traditional Chinese Medicine, "SB 218
(Yee)?would provide a pathway for skilled traumatologists,
trained in this unique branch of [TCM] to achieve
certification from the State of California. The establishment
of high educational standards and oversight would provide
Californians with basic assurances of safety when receiving
services from a [CCTCMT].
"?Some acupuncture organizations have made the argument that
the establishment of a traumatology certification would
endanger public safety. This assumption is absolutely
misguided. Traumatology, unlike acupuncture, is an
unregulated profession in California. How can an unregulated
practice be more dangerous than one that is under state
jurisdiction? SB 218 will increase public safety by regulating
this profession.
"Second, a few acupuncture organizations contend that the
education provisions of SB 218 are inadequate. The opposition
bases their claims on the practice of traumatology in China.
Chinese traumatologists have clinical duties within hospitals,
and may even diagnose and practice medicine. Obviously, the
practice of traumatology in California is very limited
compared with China. A California certified traumatologist
will not have the same duties and responsibilities of as a
traumatologist in China, and, therefore, will not require an
equivalent level of education?.
"SB 218 would simply bring about a public recognition of this
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unique branch of TCM. This bill would provide the legal means
for traumatologists to obtain certification, resulting in
increased mainstream acceptance and the implementation of
oversight to safeguard the public."
6)Arguments in opposition . According to the California
Acupuncture Coalition, which has taken an Oppose Unless
Amended position, states that "SB 218 will confuse and
endanger consumers. The proposed certification title utilizes
the terms "Chinese medicine" and "traditional Chinese
medicine." Both terms are essentially synonymous with
fullscope, fulltraining acupuncture and Asian medicine
professionals. These terms are internationally recognized by
entities such as the World Health Organization and the
National Institutes of Health .... Use of these terms in
conjunction with a substandard7) certification will confuse
consumers, potentially misleading consumers into believing
that certificants possess significantly deeper and broader
levels of training than would be required under this bill."
CAC also contends that the use of the term "Chinese medicine" in
the title authorized by this bill conflicts with the intent of
the Acupuncture Act because of its prohibition on representing
oneself as trained, experienced or an expert in Chinese
medicine without an acupuncture license. "Accordingly, the
CAC remains strongly opposed to SB 218 unless it is amended to
remove from the certificate title the term Chinese medicine or
any other term likely to cause the consumer public to confuse
certificants with fullscope, fulltraining licensed
acupunctur8)ists."
9)This bill in practice . The practical effect of this bill
would be to create a non-profit Council funded by user fees or
other donations that would set its own educational, training
and testing standards, allowing individuals to advertise
themselves as "California certified" traumatologists. Those
without certificates could continue to provide traumatology
services that are otherwise legal, as long as the
practitioners do not claim to be certified. The traumatology
practices covered by this bill would be limited to
acupressure. Discipline by the Council would be limited to
action against the certificate, ranging from minor
restrictions to complete revocation.
10)Questions for the Committee. The most recent version of this
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bill presents a number of outstanding questions and issues
that the Committee may wish to consider:
a) Is this bill necessary ? The California Acupuncture Board
has estimated that there are 150 practitioners of
traumatology in this state, although it is unknown how many
of these practitioners would seek a certification, or if
applicants might come from other states or countries. The
number of potential applicants is difficult to forecast
since the qualifications for the certificate are left
largely to the discretion of the Council. The Committee may
wish to consider at the threshold whether or not this bill
is necessary in light of the small number of potential
applicants.
Furthermore, given that the Council and its work would need
to be supported exclusively by fees - and cannot even start
issuing certificates until it has completed its design of
education, training and testing standards - it is not clear
how the Council could be created and operated over the long
term with such a low number of expected applicants.
The Senate Appropriations Committee analysis of a prior
version of this bill noted that it expected a similar
program situated under the California Acupuncture Board,
proposed by a previous version of this bill, to have
start-up costs of $80,000 and ongoing costs between
$150,000 and $200,000 per year. While fiscal matters are
outside the purview of this Committee, the question remains
whether there are enough potential applicants to justify
and support the creation of a third party certificating
body for title rights alone.
The Committee may also wish to inquire of the author as to
the evidence of consumer confusion in the market for
traumatology services that cannot be addressed by existing
law and therefore make title protection necessary.
b) Will this bill decrease, or increase, consumer
confusion ? As noted above, this bill only authorizes
certain individuals to use the term "California certified"
in advertising traumatology services (which may only
include acupressure). It does not stop uncertified
individuals from claiming to offer traumatology services.
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There is also some confusion as to the boundary between
traumatology as defined by this bill and the practice of
acupuncture. The Acupuncture Licensure Act prohibits
individuals without an acupuncture license from
"representing that he or she is trained, experienced, or an
expert in the field of acupuncture, Asian medicine or
Chinese medicine." As a result, the title provided by this
bill - which contains the words "Chinese medicine" - may
actually confuse consumers as to what kind of treatments a
particular practitioner is licensed to provide.
More importantly, it allows an individual to advertise him or
herself as 'California certified', but the state would have
very little role in the setting of standards for the
educational, training and testing requirements. The Council
would have that responsibility and others, including the
investigation of applicants' qualifications and deciding
matters of discipline. As a result, consumers may get the
mistaken impression that the state has created - and
investigates and enforces - standards for the proper
practice of traumatology when the regulation is actually
performed by a private party.
There is also a possibility of confusion based on the scope
of practice provided for in this bill. By its own terms,
this bill appears to be limited to acupressure, but the
curriculum described in the qualifications section includes
"Chinese herbs and formulas" (which is part of what is
generally thought of as traumatology). As such, consumers
may be confused as to what kinds of services are really
being "certified", and even applicants or certificate
holders may not be clear on which practices fall under the
scope of the certificate and which do not.
As such, the Committee may wish to consider whether or not
the title protection offered by this bill would actually
better inform consumers about the nature and quality of
traumatology services, and help them make a more useful
distinction between certificated and uncertificated
providers.
c) Does the state have sufficient oversight capability to
ensure consumer protection ? As noted above, the state would
have little control over the standards set or the decisions
made by the Council. And while this model of
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self-regulation does have some precedent in the industries
of massage therapy, interior design and tax preparation,
those professions generally do not purport to exist for the
treatment of health conditions. This bill describes
traumatology as offering "a range of treatments to address
both acute and chronic musculoskeletal conditions." As
such, the Committee may wish to consider whether or not it
is appropriate for a profession that views itself as a
health care treatment provider should be entirely
self-regulating while operating under the aegis of the
state.
Further, this bill does not include basic consumer
protections found under the CAMTC model, such as
fingerprinting, background checks, or a standard "sunset
date" for its authority. There are also outstanding
technical issues, not the least of which is the lack of any
designated authority to select the two representatives to
the Council from the traumatology industry.
It should also be made explicit that it is unprofessional
conduct to fail to comply with the Health Freedom Act (BPC
2053.5 & 2053.6), which requires specified disclosures to
patients when providing certain alternative or
complementary medicine treatments, such as the use of
herbal remedies, which do not constitute the practice of
medicine.
The Committee may wish to consider whether or not this bill
contains sufficient consumer protection safeguards to
justify the granting of a title that includes the words
"California certified."
11)Prior legislation . SB 1488 (Yee) of 2012 would have
established the California Traditional Chinese Medicine
Traumatology Council as a non-profit organization to provide
for the certification and regulation of the practice of
California traditional Chinese Medicine traumatologists, as
well as report to the Legislature on standards for approving
education programs, and evaluating the education, training and
clinical experience of applicants. That bill failed passage
in the Assembly Business, Professions and Consumer Protection
Committee.
SB 628 (Yee) of 2011 would have changed the name of the
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California Acupuncture Board to the "Traditional Chinese
Medicine Board," redesignated licensed acupuncturists as
licensed "Traditional Chinese Medicine Practitioners," and
would have included traumatology in the authorized activities
of a licensed acupuncturist. That bill failed passage in the
Assembly Business, Professions and Consumer Protection
Committee.
SB 731 (Oropeza) (Chapter 384, Statutes of 2008), established
the voluntary statewide certification of massage therapists by
the Massage Therapy Organization (MTO), which was renamed the
CAMTC in 2011. The goal of the CAMTC is to standardize the
process of certification throughout the state. The
certification allows for massage professionals to work in
multiple California locations without the need for multiple
permits or fees.
REGISTERED SUPPORT / OPPOSITION :
Support
------------------------------------------
|American Traditional Chinese Medical |
|Traumatologist Association (sponsor) |
|Alhambra Medical University |
|------------------------------------------|
|American Association of Chu Pui Kok Chong |
|Tong |
|------------------------------------------|
|American Association of Acupuncture & |
|Traditional Chinese Medicine |
|------------------------------------------|
|American Chinese Cultural Exchange & |
|Trading Association |
|------------------------------------------|
|Andrew University Berkeley |
|------------------------------------------|
|Association of Traditional Medical |
|Doctors |
|------------------------------------------|
|California Acupuncture Medical |
|Association |
|------------------------------------------|
|California Acupuncture Oriental Medicine |
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|Association |
|------------------------------------------|
|California Chinese Quangxi Association |
|------------------------------------------|
|California Chiropractic Association |
|------------------------------------------|
|Cantonese Association of Oakland |
|------------------------------------------|
|Chee Kung Tong Association |
|------------------------------------------|
|Chin Ying Chong Association |
|------------------------------------------|
|Chinese American Association of Commerce |
|------------------------------------------|
|Chinese Athletic Association of San |
|Francisco |
|------------------------------------------|
|Chinese Consolidated Benevolent |
|Association |
|------------------------------------------|
|Chinese Medicine Society of America |
|------------------------------------------|
|Council of Acupuncture & Oriental |
|Medicine Associations |
|------------------------------------------|
|Guangxi Chinling Association Oakland of |
|U.S.A. |
|------------------------------------------|
|Hip Sing Association |
|------------------------------------------|
|Hop Sing Association |
|------------------------------------------|
|Hop Wo Benevolent Association |
|------------------------------------------|
|Hoy-Sun Ning Yung Benevolent Association |
|in America |
|------------------------------------------|
|Kong Chow Benevolent Association |
|------------------------------------------|
|Kwok Shing Hong Company |
|------------------------------------------|
|Mar's Family Association |
|------------------------------------------|
|Ng Family Benevolent Association |
|------------------------------------------|
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|Sam Yick Benevolent Association of |
|Western U.S.A. |
|------------------------------------------|
|Sam Yup Benevolent Association |
|------------------------------------------|
|San Francisco Lodge Chinese American |
|Citizens Alliance |
|------------------------------------------|
|Soo Yuen Benevolent Association |
|------------------------------------------|
|Sue Hing Benevolent Association |
|------------------------------------------|
|Suey Sing Association |
|------------------------------------------|
|Tom Family Benevolent Association |
|------------------------------------------|
|Unified Association |
|------------------------------------------|
|United Acupuncture Association |
|------------------------------------------|
|Vietnam Chinese Mutual Aid and Friendship |
|Association of Oakland |
|------------------------------------------|
|Vietnam Chinese United Association of |
|U.S.A. |
|------------------------------------------|
|Vietnamese Acupuncture & Oriental |
|Medicine Association Institute |
|------------------------------------------|
|Vietnam Chinese Mutual Aid and Community |
|Center |
|------------------------------------------|
|Wong Family Benevolent Association |
|------------------------------------------|
|World Federation of Chinese Organizations |
|From Vietnam |
|------------------------------------------|
|Wu Yi Friendship Association |
|------------------------------------------|
|Yeong Wo Benevolent Association |
|------------------------------------------|
|Ying On Association |
------------------------------------------
898 small businesses & private individuals
SB 218
Page 20
Opposition
Academy of Chinese Medicine
Association of Korean Asian Medicine & Acupuncture of California
California Acupuncture Board
California Acupuncture Coalition
California Certified Acupuncturists Association
California Chamber for History of Chinese Medicine
California State Oriental Medical Association
Japanese Acupuncture Association of California
New England School of Acupuncture
Research Institute of Chinese Medicine
United California Practitioners of Chinese Medicine
2160 small businesses & private individuals
Analysis Prepared by : Hank Dempsey / B.,P. & C.P. / (916)
319-3301