BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:   July 3, 2012 

              ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER 
                                     PROTECTION
                                 Mary Hayashi, Chair
                      SB 1488 (Yee) - As Amended:  June 19, 2012

           SENATE VOTE  :   22-9
           
          SUBJECT  :   Healing arts: California traditional Chinese Medicine 
          traumatologist certification. 

           SUMMARY  :   Establishes the California Traditional Chinese 
          Medicine Traumatology Council (Council) to administer a 
          "California certified traditional Chinese Medicine traumalogist" 
          certificate program, until January 1, 2017.    Specifically, 
           this bill  :   

          1)Establishes the Council to administer a California certified 
            traditional Chinese Medicine (TCM) traumatologist certificate 
            program, until January 1, 2017.  

          2)Requires the Council to be a 501(c)(3) non-profit organization 
            comprised of the following five members: 

             a)   Three representatives from the clinical settings of 
               traumatology, who shall be selected by professional 
               societies, associations, or other entities, whose 
               memberships are comprise solely of practitioners of 
               California TCM traumatology and are eligible, as defined; 

             b)   One representative from the Medical Board of California 
               (MBC); and, 

             c)   One representative from the California Medical 
               Association (CMA). 

          3)Requires the Council to issue a two-year California TCM 
            traumatology certificate to applicants who satisfy the 
            following requirements: 

             a)   Are at least 18 years old; 
               
             b)   Provides satisfactory evidence of one of the following: 









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               i)      Satisfactory completion of an educational and 
                 clinical training program approved by the Council 
                 requiring a minimum of 880 hours of instruction in 
                 California TCM  traumatology; or,

               ii)    In the case of an applicant who has completed 
                 education and training outside the United States (U.S.) 
                 and Canada, documented education, training, and at least 
                 eight years of clinical experience in TCM traumatology 
                 that meets standards established by the Council. 

             c)   Is not subject to denial as a result of a crime, 
               disciplinary action, or misrepresentation; and,

             d)   Passes a written examination developed and administered 
               by the Council, as specified; and, 

             e)   Submits an application fee that covers the Council's 
               cost to process the application and cannot exceed $200.  

          4)Requires the Council to investigate all of the documentation 
            provided by an applicant and verify its authenticity to 
            evaluate whether an applicant meets the certification 
            standards;

          5)Requires the Council to develop, and report to the 
            Legislature, by January 1, 2015, on all of the following:

             a)   The standards for evaluating the education, training, 
               and clinical experience of an applicant who has completed 
               education and training outside of the U.S. and Canada;

             b)   The written examination; 

             c)   A continuing education (CE) program for California 
               certified TCM traumatologists. 

          6)Allows a certificate holder to renew his or her certificate 
            within six months after expiration if the certificate holder 
            pays the necessary fees.  Establishes the following 
            certificate fee schedule: 

             a)   The renewal fee shall be $100; 

             b)   The delinquency fee shall be $25; 








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             c)   The duplicate or replacement engraved wall certificate 
               shall be $15; and, 

             d)   The duplicate or replacement engraved renewal 
               receipt/pocket certificate shall be $10. 

          7)Requires that money received under this bill shall be used by 
            the Council to pay for associated administrative costs.  

          8)Provides that it is an unfair business practice for any person 
            to hold himself or herself out as a "California certified TCM 
            traumatologist" or use that title unless he or she is 
            certified by the Council.  

          9)Prohibits a California certified TCM traumatologist from 
            practicing: 

             a)   Medicine as defined; and, 
                
             b)   Within the scope of activities regulated by the Board of 
               Chiropractic Examiners (BCE). 

          10)Authorizes the Council to deny, suspend, or revoke a 
            certificate for any of the following reasons: 

             a)   Unprofessional conduct, as specified; 

             b)   Procuring a certificate by fraud, misrepresentation, or 
               mistake;

             c)   Violating a provision of this bill or a Council bylaw; 

             d)   Conviction or misdemeanor relating to the certificate 
               holder's qualifications or duties; 

             e)   Impersonating or acting as a proxy for an applicant; 

             f)   Impersonating a California certified TCM traumatologist 
               or permitting an uncertified person to use a certificate;

             g)   Committing any fraudulent, dishonest, or corrupt act in 
               the course of duties; or, 

             h)   Committing a sexually related crime.








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          11)Subjects Council meeting to the rules of the Bagley-Keene 
            Open Meeting Act. 

          12)Creates the following definitions: 

             a)   "California certified TCM traumatologist" to mean a 
               person who has been certified by the Council to perform 
               California TCM traumatology; 

             b)    "Council" to mean the California Traditional Chinese 
               Medicine Traumatology Council; and,

             c)    "California traditional Chinese Medicine traumatology" 
               to include 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 both meridians, but do not include 
               manipulation techniques to realign the musculoskeletal and 
               ligamentous relationship, also known as bone setting.

           EXISTING LAW  : 

          1) Establishes the Acupuncture Board (Board) within the 
             Department of Consumer Affairs (DCA), which licenses and 
             regulates the acupuncture profession pursuant to the 
             Acupuncture Licensure Act (Act). 

          2) Defines an acupuncturist as an individual who has been 
             licensed to practice acupuncture pursuant to the Act.  
             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. 

          3) States that a licensed acupuncturist is authorized to do the 
             following: 

             a)   To engage in the practice of acupuncture;








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             b)   To perform or prescribe the use of Asian massage, 
               acupressure, breathing techniques, exercise, heat, cold, 
               magnets, nutrition, diet, herbs, plant, animal, mineral 
               products, and dietary supplements to promote, maintain, and 
               restore health.  Nothing prohibits any person who does not 
               possess an acupuncturist's license or another license as a 
               healing arts practitioner from performing, or prescribing 
               the use of any of these modalities, as specified. 

          4) States that the Board shall issue a license to practice 
             acupuncture to any person who applies and meets the following 
             requirements: 

             a)   Is at least 18 years of age; 

             b)   Furnishes satisfactory evidence of completion of one of 
               the following:  an education and training program, as 
               specified; satisfactory completion of a tutorial program in 
               the practice of acupuncture which is approved by the Board; 
               or, in the case of an applicant who has completed education 
               and training outside the U.S. and Canada, documented 
               education training and clinical experience, as specified; 

             c)   Passage of a written examination administered by the 
               Board, as specified; and, 

             d)   Completion of a clinical internship training program 
               approved by the Board.  

           FISCAL EFFECT  :   Unknown.  This bill has been keyed non-fiscal 
          by the Legislative Counsel. 

           COMMENTS :   

           Purpose of this bill  .  According to the author's office, 
          "Current law does not provide for the oversight of 
          traumatologists in California.  SB 1488 is a titling act that 
          will provide the public with a level of protection through the 
          establishment of a non-profit council that will determine the 
          standards of training and experience necessary for a person to 
          be certified as a California certified TCM Traumatologist.  

          "The creation of this certification program will provide a 
          pathway for skilled TCM traumatologists to receive recognition 








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          as one of the participants in the health care of the public.  
          TCM traumatology, like acupuncture, takes a holistic approach to 
          the body with a complete theoretical system that has provided 
          cures to people for centuries.  A group of such practitioners 
          exist in the State of California and have been providing care to 
          the public for more than 50 years to date.  The intent of this 
          bill is to allow some oversight of this practice to ensure 
          public safety and to give people confidence and assurances that 
          for those traumatologists who are certified, they have met 
          certain standards and requirements to call themselves a 
          'California certified TCM traumatologist.'"

           Background  .  This is the second time that the author is hearing 
          a bill in this committee and session related to traumatology.  
          This bill differs from its previous version, SB 628 (Yee) of 
          2009 because it removes licensure of a traumatologist from under 
          the Board and instead creates a certification program 
          administered by the Council, defines the scope of TCM 
          traumatology, removes the orthopedic association from the 
          Council membership, expressly prohibits the practice of 
          chiropractic by traumatologists and bone setting.  Proponents of 
          this bill contend that there are individuals who already hold 
          themselves out as traumatologists, and use the term 
          "traumatology" in their business name, and that this bill would 
          regulate and provide oversight for a group of practicing 
          traumatologists that are unregulated.  

          Traumatology is one of the modalities that constitute TCM.  The 
          term "traumatology" is also defined as the study of wounds and 
          injuries caused by accidents or violence to a person, and the 
          surgical therapy and repair of the damage.  It is often 
          considered a subset of surgery and in countries with the 
          specialty of traumatology surgery it is most often a 
          sub-specialty to orthopedic surgery.  

          Before China systemized their health care system, individuals 
          acquired their mastery of traumatology through a 
          master-apprentice relationship.  These practitioners learned 
          from a master through hands-on training.  

          The practice of traumatology, as practiced in other countries, 
          incorporates components found within different healing arts 
          professions licensed under DCA - acupuncture, orthopedics, and 
          massage therapy. 









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          Generally, the Business and Professions Code (BPC) specifies 
          education, experience, and examination requirements for 
          licensure for professional occupations within DCA.  This bill, 
          as amended on June 19, 2012, requires applicants to complete 
          education, training, and examination requirements developed by 
          the Council, with a minimum of 880 hours of instruction in 
          California TCM traumatology.  This bill also requires the 
          Council to develop standards for issuing a certificate to 
          applicants who have completed education and training related to 
          traumatology outside of the U.S. and Canada.  This bill requires 
          the Council to investigate and verify the authenticity of 
          documentation provided by applicants to determine whether 
          applicants qualify for certification.  This bill also requires 
          the Council to develop and report to the Legislature by January 
          1, 2015, on the standards for the approval of educational and 
          training programs, the written examination, and the CE program 
          for California certified TCM traumatologists. 
           
          The provisions relating to educational requirements for TCM 
          certification is one of the primary reasons TCM colleges are 
          opposing this measure; they contend that practicing 
          traumatologists in China are medical doctors specializing in 
          traumatology who can substantiate education requirements and are 
          eligible for an acupuncturist licensure if the applicant can 
          provide proof of education and training completed outside the 
          U.S. and Canada that meet specified standards (BPC Section 
          4938).  The TCM schools state that this bill would provide a 
          structure for individuals who do not have the documentation to 
          apply for an acupuncture license to receive certification as a 
          TCM traumatologist with less education requirements. 

          In January 2005, the Board promulgated regulations that included 
          traumatology as a subject matter for didactic instruction that 
          could be counted towards licensure requirements (Board 
          Regulation, Title 16, Article 3.5, Section 1399.434).  The 
          curriculum in acupuncture and Oriental medicine principles, 
          theories and treatment consists of at least 1,255 hours of 
          didactic instruction in specified areas, including traumatology. 
            Some TCM schools will offer a one-year certification program 
          that specializes in traumatology for acupuncturists.  
           
           There are approximately 60 accredited TCM educational institutes 
          nationwide, and 20 of them are located in California.  
          Currently, there are no national standards for traumatologists. 
          Acupuncture is legalized in 50 states of the U.S.  Currently, 








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          traumatology courses are offered in accredited schools for 
          acupuncture, as a portion of the study.  Currently, there is no 
          traumatology school in California.  The author's office also 
          notes that for at least the previous ten years, traumatologists 
          have had regular, annual, and special workshops and seminars in 
          the Bay Area and abroad, including China and Hong Kong.

          While the Board is overseen by the DCA, this bill establishes a 
          non-profit Council to certify TCM traumatologists that is not 
          overseen by the DCA or any other state agency or entity.  

          Last year, the author's office estimated that approximately 
          70-100 individuals would be eligible for certification as a TCM 
          traumatologist.  This bill caps the certification fee at $200, 
          and initial certification of traumatologists under this bill 
          results in estimates of up to $20,000 in revenue to the Council. 
           On the other hand, there are approximately 12,000 licensed 
          acupuncturists in this state and the initial license fee is 
          $325.  The certification of traumatologists may have the 
          unintentional consequence of redirecting individuals who would 
          have applied for an acupuncture license to instead obtain a 
          California certified TCM Traumalogist certificate, due to lower 
          fees and eligibility requirements. 

          This bill requires the Council to determine California TCM 
          traumatology certification standards, including experience and 
          training requirements.  The committee membership is comprised of 
          three representatives from the clinical settings of 
          traumatology, one representative from the MBC, one 
          representative from the CMA.  The Acupuncture Board, which 
          licenses practitioners of eastern medicine, and has promulgated 
          regulations relating to traumatology, is not represented on the 
          Council. 

          This bill allows for the Council to develop and report to the 
          Legislature, by January 1, 2015, or two years later on the 
          standards for the approval of educational and training programs, 
          the written examination, and the CE program for California 
          certified TCM traumatologists.  While the provisions of this 
          bill would take effect on January 1, 2013, the standards could 
          technically be developed two years after a certificate may be 
          issued, or half-way through the term of the pilot program, which 
          sunsets on January 1, 2017.

           Support  .  According to the American Traditional Chinese Medical 








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          Traumatology Association, "This bill would provide a pathway for 
          a skilled traumatologist, trained in this aspect of TCM, to 
          achieve California certification.  This certification process, 
          within SB 1488, would thereby provide Californians with basic 
          health and safety assurances. 

          "SB 1488 would safeguard would safeguard the public by: 

             1)   Requiring government oversight through the creation of a 
               non-profit Council consisting of �five] members: one 
               representative each from the MBC and the CMA and three 
               representatives from the clinical settings of practicing 
               traumatology to assist in assuring the highest standard and 
               peer review oversight; 

             2)   Regulating the use of the title 'traumatologist' so that 
               those using the term would have to satisfy the standards 
               and level of experience set forth by the newly created 
               Council, allowing the public to distinguish between those 
               that are certified and qualified from those that are not; 
               and, 

             3)   Requiring, for the first time in law, that a 
               traumatologist shall not practice medicine or chiropractic 
               manipulations."

           Opposition  .  According to the BCE, "The BCE has public safety 
          concerns related to the proposed scope of traumatology and 
          questions whether the proposed training and certification 
          standards would assure public protection?  Only after competent 
          training and adequate education, supported by standardized 
          education and nationally recognized testing, can the BCE support 
          the introduction of any new health care entity which would 
          potentially need to make an urgent and accurate diagnosis and 
          referral of patients who may need urgent or even emergency 
          medical care?" 

          According to the Southern California University of Health 
          Sciences and several TCM colleges, "''TCM Traumatology is part 
          of TCM.  Traumatologists use TCM theories, diagnosis, 
          tui-na/massage skills and herbs in their practice.  Therefore, 
          the regulation of this discipline should not be separated from 
          the current acupuncture license system which is overseen by the 
          Board?  The proposed 880 hour education requirement for the TCM 
          traumatology �certificate] is clearly below the current higher 








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          standards of the existing Acupuncture and Oriental Medicine 
          requirements (minimum 3,000 hours).  Inadequate controls are 
          provided for in this bill relative to ensuring the legitimacy of 
          foreign training?  The most recent version of this bill would 
          require, but not until January 1, 2015, the Council to submit a 
          plan for the educational, training, and examination standards 
          for TCM traumatology certification.  This is not too little, but 
          too late to protect the public for two years until standards and 
          tests are formulated."

          According to the American College of Traditional Chinese 
          Medicine, "The title 'TCM Traumatologist' requires a minimum of 
          6,000 hours of training in China.  In China, the title of 
          'TCM Traumatologist' is designated only to individuals who have 
          graduated from a TCM college or university (4,000 hours and a 
          minimum of two more years specializing in traumatology - for a 
          total of at least 6,000 hours).  We do not offer this level of 
          training in the U.S."

          According to the National Federation of TCM Organizations, 
          "Since the legalization of acupuncture in California 37 years 
          ago, the profession has grown.  Today, acupuncture is legalized 
          in 50 states across the nation.  This growth and recognition is 
          based on the standards that were set by the profession through 
          its national professional certification and accredited bodies 
          that are accredited by related federal agencies and accepted by 
          state governments.  We consider it a self-serving means to 
          satisfy the individuals who refuse to abide by the standards of 
          the �acupuncture] profession and get their license through the 
          standard process as all other practitioners have been doing."

           Related Legislation  .  SB 628 (Yee) of 2011, would have created a 
          Traumatology Committee (Committee) within the Board and would 
          have authorized the Committee to determine certification 
          standards for, and certify traumalogists from March 1, 2012 to 
          December 1, 2012.  This bill was amended to delete all 
          provisions relating to traumatology, and to instead codify 
          regulations promulgated by the related to an acupuncturist's 
          permitted use of the title "Doctor."  This bill is pending in 
          the Assembly Appropriations Committee. 

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           








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          American Association of Acupuncture and Traditional Chinese 
          Medicine 
          American Chinese Cultural Exchange & Trading Association 
          American Traditional Chinese Medical Traumatology Association 
          California Acupuncture Medical Association 
          California Acupuncture Oriental Medicine Association 
          Cathay Post No. 384 
          Chi Wan Mok Traditional Chinese Medical Center
          Chinese Consolidated Benevolent Association 
          Chinese Culture & Health Center 
                 Ching's Chinese Medical & Therapy Center 
          Chinlien Association
          Daminh Alumni Association U.S.A.
          David Lu Traditional Chinese Medical Center
          Deng Shao Ji Chinese Medical Center
          Dian Gui Liu Chinese Herbal Medical Center
          Gee Association 
          GL Health & Herbs Service Center 
          Hai Feng Chinese Herbal Center 
          Hai Feng Traditional Chinese Medical Center 
          Hai Phong Overseas Chinese Association 
          Ho Ying Heng 
          Hoy-Sun Ning Yung Benevolent Association in America 
          Huang's Traditional Chinese Medical Center
          Hung Yue Louie Chinese Medical Acupuncture Center
          Jian Zheng's Chinese Medical Center
          Jiang Die Liang Chinese Medical Center 
          Jiang's Wellness Center 
          Johnson Herb Services 
          Kang Hua Chinese Herbal Center 
          Kwong Tim Leung Traditional Chinese Medical Center
          Las Tunas Acupuncture & Herbs Pain Relief Center 
          Liang's Traditional Chinese Medical Center
          Nathan Lee Traditional Chinese Medical Center
          National Guild of Acupuncture and Oriental Medicine
          Peng Tsing Tong Chinese Medical Center 
          RiYing Gong Traditional Chinese Medical Center
          S.H. Body Therapy 
          Shu Lin Han Traditional Chinese Medical Center 
          Sidra Yoy Wu Chinese Medical Center
          Simon Tang Chinese Medical Center 
          Soo Yuen Benevolent Association 
          Tim Lee Traditional Chinese Medical Center
          Tony's Pain Medical Center 
          Toy's American Traditional Chinese Medical Center 








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          Traditional Chinese Medical Center 
          United Association 
          U.S. Organization of Chinese Merchants from Vietnam, Cambodia 
          and Laos
          Vietnam Chinese Mutual Aid Friendship Association of Oakland
          Vietnamese Acupuncture and Oriental Medicine Association 
          Institute
          Wang Guo Zhu Traditional Chinese Medical Center
          William Wu Traditional Chinese Medical Center
          Wong Family Benevolent Association, Inc. 
          Wong Man Keung Traditional Chinese Medical Center
          Wong's Traditional Chinese Medical & Traumatology Center
          Yu's Herbal Chinese Medical Center 
          Numerous Individuals
           
            Opposition 
           
          1-2-3 Acupuncture Clinic 
          AAA Acupuncture 
          Academy of Chinese Medicine 
          AcuEnergize
          Acu-Herbs Healing
          Acu-Medi Health Center 
          AcuSpa
          Acupuncture & Healing Arts Center of Visalia
          Acupuncture & Herbs Clinic
          Acupuncture & Herbal Care of Los Altos
          Acupuncture Herb Center 
          Acupuncture and Natural Herbs 
          Acupuncture in Yan Clinic
          Acupuncture for Wellness
          Acupuncture RN 
          Acupuncture Weight Control Center
          Ahola Clinic Corp. 
          Al Acupuncture Healing Center 
          All Care Acupuncture & Herbs Clinic 
          American College of Traditional Chinese Medicine 
          American Diabetes Chinese Medical Center
          American Institute of Acupuncture Orthopedics & Traumatology 
          American Institute of Chinese Medicine, Inc. 
          Anna Lin Natural Healthcare 
          Anto Acupuncture & Chinese Medicine Clinic
          Asian Bodywork Therapy
          Association of Korean Asian Medicine and Acupuncture of 
          California 








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          Association of World Traditional Medicine
          Asyrah's Garden
          Aurora Acupuncture 
          Awareness Center 
          AXOS Acupuncture 
          Bina Jangda Acupuncture 
          Bin Zhi Acupuncture Clinic 
          Bliss Acupuncture Clinic 
          Blossom Hill Chiropractic
          Board of Acupuncture 
          Board of Chiropractic Examiners
          Buddhist Society of America
          California Acupuncture Center
          California Alliance of Acupuncture Medicine 
          California Certified Acupuncturists Association 
          California Green Cross Clinic 
          California State Oriental Medical Association 
          California Traditional Articulated Healing Center
          Chinatrust Bank (U.S.A.)
          Chen's Acupuncture and Chinese Medicine Clinic 
          Chinese Medicine & Acupuncture Healing Center 
          Chinese Medicine Clinic & Education Center
          Chinese-West Medical Center, LLC 
          Da Ming Acupuncture and Herb Center
          Ding Li Acupuncture Clinic 
          DO Oriental Medical Group 
          California Neurohealth
          Dong Kook  Health Care Center 
          Dr. Wang Acupuncture Clinic
          East Traditional Medicine 
          Echoi Acupuncture 
          eCosway
          Emperor's College
          Family Health Group 
          Fang's Art Studio 
          Five Branches University 
          Five Element Care
          Fullness Auto Service Centre
          Good Samaritan Acupuncture
          Goodkin Acupuncture 
          Health Tune-up 
          Heaven Grace Herbal Clinic 
          Holistic Healing Center
          Holy Acupuncture
          Hong Yan Medical Clinic 








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          Japanese Acupuncture Association of California
          JJ Acu & Herb Clinic 
          Johnson Acupuncture Clinic
          Julie Cao Acupuncture Clinic
          Jun Paek Acupuncture Clinic 
          Karen Acupuncture Clinic Inc. 
          Kim Neumann Acupuncture 
          Korean Acupuncture & Asian Medicine Association
          Larchmont Traditional Medicine 
          Li Ma Acupuncture 
          Lido Partners
          Livermore Acupuncture & Herbal Clinic 
          Lotus East-West Medical Center 
          Middle Path Acupuncture Clinic 
          MJ Acupuncture
          National Federation of Chinese TCM Organizations
          N's Quick Printing 
          Oceanside Acupuncture 
          Oriental Cosmos Health Center
          Ou's Acupuncture 
          Ouyang Paint Management Center 
          Pacific College of Oriental Medicine
          Pan Acupuncture & Herb 
          Pacific Complementary Medicine Center 
          Peace Acupuncture Clinic 
          Pei YuKun Acupuncture, Acupressure and Oriental Medicine Clinic
          Professional Skin & Body Care Inc. 
          PSW Acupuncture Inc. 
          Qi Dragon Healing Center 
          Rancho Bernardo Chiropractic 
          Research Institute of Chinese Medicine 
          San Jose Functional Medicine 
          Sheila's Acupuncture and Herbs
          Shen's Acupuncture Clinic 
          Southern California University of Health Sciences 
          Stephen Imports, Inc. 
          Su Clinic
          Sun Healing Center
          Sunson Co. Xia's Acupuncture Clinic
          Temescal Acupuncture Center 
          The American Institute of Finger Surgery 
          The Redwood Clinic
          Tong Zhang Acupuncture
          Total Health Care, Inc. 
          Traditional Healing Arts








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          Traditional Healing Arts Center 
          Tsubakiyama Acupuncture Clinic 
          Underground Stream Qi Acup.
          UniCare 
          United Acupuncture & Herbs 
          United California Practitioners of Chinese Medicine 
          University of East-West Medicine
          Valley Health & Acupuncture 
          Wang Ping Acupuncture Clinic
          Whole Health Associates
          World Alternative Medicine Health 
          WTX Medical Group
          Xing Lin Acupuncture & Chinese Medicine Clinic 
          Yan Xiang Li's Acupuncture Clinic 
          Xu's Acupuncture Clinic
          Yan-Hua Total Health Care, Inc. 
          Yan Xiang Li's Acupuncture Clinic 
          Ye's Acupuncture Clinic 
          Yo San University 
          Numerous individuals 

           Analysis Prepared by  :    Joanna Gin / B.,P. & C.P. / (916) 
          319-3301