I believe that the NCCAOM examination and certification process is one of the most valuable institutions created by our profession over the last 30 years. NCCAOM Diplomates have demonstrated to their colleagues and to the public that they are appropriately educated and competent to enter the practice of their profession. The process of certification requires a personal commitment to continuing education and ethical conduct that is enforced and renewed. The certification thus offers a unique assurance to patients. This is especially important in states such as New York that have low training standards, no requirement for continuing education on the part of licensees and, in the case of herbal practice (now in scope in NY) no examination or training requirements for Chinese herbal competency. Without the NCCAOM Diplomate patients in NY have few, if any, assurances about the original and continuing education of a practitioner.

There is no United States standard that is a credible alternative the NCCAOM process. This is particularly true of any state license including California’s. It is also not the case that either the DAOM (post-graduate doctorate) or the DACM (our new first professional degree) can replace this process. These points are discussed below.

As an NCCA (and NCCAOM) Diplomate since 1989, I have committed to the process of certification and examination for almost 28 years, not because I was ever required to but because this process supports the integrity of our profession and protects our patients.

I started writing herbal formulas in 1982 and 1983. I’d been trained for about a year in a program that no longer exists with Subhuti Dharmananda, Ph.D. who had been a close student of Hong Yen Hsu and so the learning I did was based on Shang Han Lun formulas with a Kampo approach. I continued study and practice, until I left for graduate school in anthropology in 1984. I later resumed my study of TCM at ACTCM in 1986. I graduated in 1989. I took the NCCA (not yet OM) acupuncture exam in 1989 and the California acupuncture licensing exam (CALE) in 1990. Both exams used live humans for point location and, in addition to testing on herbal formulas, the CALE also required herb identification. Those were the days.

In 1989 the NCCA exam was a relatively new thing and many people in California viewed it as both an important professional gesture (it was an independent national exam) and later as a “second best” exam when compared to the CALE. This view point persisted for many years and, while I generally agreed with it during the nineties, years of scandal and carelessness in California’s administration of the exam and years of improvement on the part of NCCAOM have changed the equation completely.

Today CALE is a 200 question multiple choice test of which 10.5% covers herbal therapy. The exam guide lists 83 herbal formulas. This means that about 21 questions cover all the herbal knowledge a candidate is responsible for. Additionally, it is entirely possible for an individual to know nothing about herbs and pass the examination. If we compare this to the NCCAOM examination which examines the same areas with 4 exams comprising 430 questions including a 100 question independent examination on Chinese herbology which the candidate must pass and which covers 160 herbal formulas. I think it is clear that there is little comparison between the examinations as tools for assessing knowledge and competency.

The NCCAOM exams assess entry level competence with an extensive and content focused exam that is, with respect to herbs, is five times as extensive as the CALE and covers twice the content. The certification process provides an independent national standard created by our profession that requires continuing education, recertification, and ethical conduct. No state, even those that have continuing education requirements, have comparable processes that extend to practitioners especially herbal practitioners, whatever jurisdiction they practice in.

I completed my Diplomate in OM (acupuncture, herbology, and biomedicine) in about 2004. It was inconvenient to do so, I was Director of the Graduate Program in Oriental Medicine at Touro College School of Health Sciences at the time, and typically teaching a class or two every semester, while managing the program. I made the time to study and worked with another colleague to prepare. I passed both the biomedical and herbology exams on the first try and probably did not spend more than 40 hours, if that, preparing for either of them. This is not to brag, this is just to say that a reasonably well prepared student of Chinese medicine could brush up and take them with only little trouble. I could easily have avoided taking either of them since neither was required in NY.

I took them because I felt that both nationally, and especially in states such as NY I had a commitment to support the integrity of our profession, to protect and signal my concern for my patients, and to set an example for my students. I still feel that way which is why I have remained a Diplomate for the last 28 years.

In states such as New York the value of Diplomate status to both the profession and to patients is exceptional. New York State does not require continuing education and, even now that the use of natural products is in our scope, we have no training standards nor examination standards in the law. It is for this reason that the recently inaugurated Shen Nong Society adopted the requirement of Diplomate in O.M. status for those New York State Licensees who will be listed on its register.

It has been suggested to me that completion of a Master’s in OM such as the MSAOM at NYCC or any other Master’s program that provides training in Chinese herbal medicine should suffice as evidence of entry level competency. While I believe we and many other programs offer strong herbal training to our students, I also know that we have some students who struggle with our outcome assessments and who fail the NCCAOM exams or simple do not take them. This is true of many programs as well, unfortunately, graduation from an accredited program, by-itself, is not a perfect marker of competence. It has been suggested to me that by insisting on this standard I was failing to support our graduates. I disagree. While I applaud and support all our graduates, I do not believe we, as a college, have any business exposing our students or patients to faculty and clinicians who have not demonstrated the ability to meet national standards for entry level competency. Instead, I believe that as a faculty it is incumbent on us to model our commitment to the very best standards of professional conduct and certification.

With respect to the DAOM (post-graduate doctorate) and the DACM (professional doctorate), as a member of the committee (1991 through 2000) that worked to create the standards for these degrees and as a member of at least one task force, I can say with absolute certainty and accuracy that neither degree replaces NCCAOM certification in any fashion. The DACM can be dispensed with immediately, it is essentially the Masters Curriculum transitioned to the doctoral level; the degree includes no further assessment of professional ability beyond the Masters. In theory, the DAOM is an advanced degree, but it is a non-standard one and one that no longer requires the completion of any herbal training at all (except for a three credit survey). Since the DAOM was designed to enhance clinical specialization beyond the Masters, research readiness and preparation for teaching, it never required instruction in specific curricular areas. Instead, one program might focus on geriatrics, another on gynecology, and yet another on orthopedics. There is no standard examination administered at the completion of either the DAOM or DACM to assess entry level competence and, in fact, some DAOM recipients will not be eligible for the NCCAOM OM Diplomate. Thus neither the DACM, nor the DAOM replaces the NCCAOM certification process.

It is probably necessary to speak to the Ph.D. as well. The Ph.D. is a research degree. The Ph.D. has not specified curriculum except that which qualifies the candidate to conduct research in their area of study. The Ph.D. is not a clinical degree, nor does it establish “competence” in any area except a very narrow band of research oriented study. Thus the Ph.D. cannot replace the NCCAOM certification process.

To sum up, the NCCAOM examination and certification process has no equivalent in the United States. The exam assesses education, entry level competence, continuing education, and compliance with ethical standards and does so on an ongoing basis through re-certification every 4 years.

The NCCAOM Dipl. OM has been the standard for all FLSAOM faculty who provide clinical or classroom training in Chinese herbal medicine since the first hires were made in 2003. Additionally, until recently, the only non-herbal trained faculty in our program maintained Diplomate status in acupuncture. As discussed above the NCCAOM standard is an assurance to our patients, to our faculty, and to our students of the professional preparation of the Diplomate holder. Unfortunately, there are no alternatives available.

I will remark, based on extensive personal experience, that there may be a few individuals who might assert expertise based on experience or an unusual education that they have excellent skills that do not require NCCAOM certification. There might be the occasional instance of that, but frankly, that ship has sailed. Individuals who have trained in TCM in China can readily secure certification and have been able to do so since the 1980s. When grandfathering was an option I wrote a letter or two in support of some luminous individuals who wanted Diplomate status without examination, but that was many years ago. I qualified for grandfathering in herbology, but I never considered it. I have also encountered individuals, some of them quite “famous” who have declined to pursue NCCAOM certification on the basis that it was in some fashion beneath them or did not assess their knowledge. In many of these cases the individuals in question were simply unable to document adequate training.

To be qualified to be NCCAOM certified and yet to fail to do so may be a choice for some professionals. However, in my opinion, for any faculty of this program to fail to demonstrate entry level competence in their profession as well as a commitment to continuing education and to professional ethics is inappropriate.

The purpose of the Diplomate status is to demonstrate to patients, colleagues, and to the students we teach that we have a commitment to transparent national professional standards, to continuing education, to professional ethics, and to independent validation of our skills. It is a critical standard for our school and for the profession.

I wrote this in the context of a discussion amongst our faculty and have slightly revised it to make it more generally applicable. I should stress that the views expressed here are entirely my own. These are not the official views of the Finger Lakes School of Acupuncture and Oriental Medicine of NYCC, nor of the New York State Acupuncture Board on which I serve.