FPD and ACAOM for the gold!

Posted 8:01pm February 22nd, 2010 by Lisafer 

In the new Olympic sport of Moving the Goalposts. Or is it Gaslighting? Hard to define, but it’s clear we have a winner! In this blog post, a recap of a groundbreaking performance, along with some commentary from this thoroughly embittered viewer.

Let’s go back to 2003, with a quote from the CCAOM Entry Level Standards Committee, History and Findings: “The Council of Colleges of Acupuncture and Oriental Medicine’s Entry-Level Standards Committee was formed in May 2003 and charged with the task of gathering information on potential changes in entry-level educational standards. The intent in creating the committee was to create an open process to gather feedback on possible changes to entry-level standards and to fulfill our vision by taking actions that would be open, transparent, welcoming, and without a preconceived agenda.” This seems to be where the public process officially started. That document also contains gems like this: “While concurrent Master’s and doctoral programs may co-exist in some states, most states pointed out that once a higher level of entry education is defined, the lower level is phased out.” 

You think you know what’s going on here, don’t you. Therein lies the subtle beauty of this performance! Let’s move on to 2005, when the ACAOM Doctoral Task Force issues their final report, and announces the first public comment period. “ACAOM has established a Doctoral Committee, consisting of the Executive Director and several
commissioners, to consider the public comment on the Task Force report as it works to develop
proposed accreditation standards for first-professional doctoral programs in AOM.
” And here is a quote from that Doctoral Task Force:

ACAOM Doctoral Task Force Guiding Principles
We undertake to help facilitate this process should it occur according to the following six principles:
1. Above all else, we will endeavor to do no harm.
2. We will endeavor to bring all communities of interest and voices in the AOM community into
this process and through it together without eliminating or excluding anyone.
3. We will respect all voices in the field and all traditions in the field.
4. We will provide clear communication about our discussions and the processes we propose to the
entire community throughout our discussions.
5. We recognize that our current curriculum leading to the professional degree in AOM and the
competencies that they represent support a valid First Professional Degree at both the current
masters and the proposed doctoral degree level.
6. We recognize that content of curricula will continue to evolve, as it always has, based upon the
need to support new professional roles which emerge for practitioners of AOM

Sounds pretty good, doesn’t it? Do no harm, bring everyone into the process, respect all voices, provide clear communication about our discussions and the processes we propose. A flawless set-up.

And now, the comment period. Other than the public meetings, the only way comments could be submitted during this period was through the ACAOM’s website. An extraordinarily bureaucratic, user-unfriendly website. My first clue that this process was not going to be “open, transparent, and welcoming” was when one of my patients, who was 77 at the time, got frustrated with the website and called the ACAOM to try to register her opinion. She said that she had trouble with computers, being 77 years old, and she wanted to give her comment; the Executive Director hung up on her. Loudly. Not accidentally. Nonetheless,  apparently enough comments got through, from enough young, computer-literate, nondisabled and otherwise privileged people, that in February 2008 the ACAOM adopted a “Resolution on First Professional Doctoral Standards”.

This part is very, very important. This is how Dictionary.com defines “resolution”:


1. a formal expression of opinion or intention made, usually after voting,by a formal organization, a legislature, a club, orother group.Compare concurrent resolutionjoint resolution.

2. a resolve or determination: to make a firm resolution to do something. 

3. the act of resolving or determining upon an action or course of action, method, procedure, etc.

4. the mental state or quality of being resolved or resolute; firmness of purpose.

Sounds firm, formal, authoritative and clear, doesn’t it? It sounds like something you might actually believe if you read it. Your belief is key to the spectacular athletic feat that is coming up. And here is the resolution:

In the collective and unanimous judgment of the Commission, there is currently insufficient evi‐ dence of consensus within the acupuncture and Oriental medicine communities of interest, which in‐ cludes state regulators and legislators, educators, and the practitioner community, to warrant imple‐ menting a first‐professional doctorate as entry‐level into the profession. Absent such consensus, the Commission lacks authority to make decisions on whether or when first‐professional doctoral standards, policies and procedures are adopted for purposes of entry into the profession.
Be it resolved that the Commission urges the acupuncture and Oriental medicine communities of inter‐ est, as the primary conveners, to continue to seek consensus by whatever means deemed appropriate regarding the issue of a first‐professional doctorate as entry‐level into the profession.
Be it resolved that once consensus is reached within the profession, the Commission will renew its ef‐ forts to develop and subsequently pilot standards, policies and procedures for first‐professional doctoral programs in AOM as entry‐level into the profession.

My next clue that this process was not “open, transparent and welcoming” came with an anonymous phone call, the gist of which was that there were not going to be any efforts at consensus-building; instead the “public comment period” had been mysteriously re-opened, with no effort to notify those who had made comments before — at least those of us who opposed the FPD. “They’re hoping to get a different answer than they got before,” said my source, who happens to be inside the CCAOM, the ones who got this Olympic snowball rolling in the first place. 

And yet, I couldn’t really believe it. That’s what makes this performance world-class. I’ve been in the profession fifteen years, and even I didn’t really think this was possible. In fact, my partner called the Executive Director of the ACAOM to confirm that we were going to be submitting our comments correctly. He was adamant that there should be no phone calls, no emails, only letters and faxes. OK, we said; the rules sound clear, we can play by them.  

And then, suddenly, emails were allowed. A few weeks later, the ACAOM explained that the “FPD” was NOT ACTUALLY AN FPD, merely a “PD”, a “professional doctorate”. All this concern about a potential change in entry level standards? So silly, when “the question of a ‘Professional Doctorate’ vs. ‘a First Professional Doctorate” is not a distinction that is important from the perspective of accrediting agencies” (Dort Bigg, email, Jan 4, 2010). What is everyone so hysterical about? This has nothing to do with changing entry-level standards!

Quick, look back up at the top of this post, so that you can experience the vertigo as the goal posts are moved! Do you doubt your own sanity, just a little? That’s good, you are experiencing the Olympic-level mastery of confusion to which many bureaucrats aspire, but which so very few achieve! Before you get your bearings, listen to this: “the Commission has purposely not designated or adopted a specific “definition” for determining consensus for purposes of its review of the professional doctorate.   The Commission has many communities of interest including educators/educational institutions, practitioners and practitioner orgs, state regulators and members of the public, among others and need to take the views of all communities of interest” (Dort Bigg, email Jan 4). 

The true beauty of this is that the word “consensus” DOES have a definition. A very simple, specific definition, actually. Here it is, according to Merriam Webster online: 

1 a : general agreement : unanimity <the consensus of their opinion, based on reports…from the border — John Hersey> b : the judgment arrived at by most of those concerned <the consensus was to go ahead>
2 : group solidarity in sentiment and belief

Let’s translate that email out of bureaucratese into English: if you purposely don’t adopt a specific definition of consensus, it means you are not using the definition of consensus that everyone else is using, the one that’s in the dictionary. It means that you don’t mean consensus at all. It means you have moved the goalposts. Be it resolved…oh, never mind. Resolutions are so inconvenient.

And now for the finale! Let’s look at the February 2010 ACAOM Decision on First Professional Doctoral Standards:

“The Commission received approximately 3000 letters and petition signatures on the subject…”

2039 of those represented opposition to the FPD. We know, because we counted them. We photographed their delivery (there’s another story there).

“Based on this review the Commission, in its exercise of professional judgment, is satisfied that there is
sufficient support to justify the further development of first-professional doctoral standards.” 

Let that sink in for a minute. Sufficient support. So much for consensus, so much for do-no-harm, so much for transparency. So much for resolutions and respect and clear communication.

You win, ACAOM. You win, AAAOM. You write the rules however you want, and you win. You’ve moved me deeply; I didn’t know I could feel appalled anymore, but I can. Your victory brings tears to my eyes. Really. John Weeks nailed it when he wrote that this is essentially all about the conflict between service to patients and status for the profession. The people who want to be called “Doctor” just want it. They’ll never stop wanting it. They don’t care what happens to anyone else. Because you know, a good way to do harm to a profession is to lie to the people in it. Set them up. Gaslight them.  

You know, the one thing I wonder? Why you ever asked for input in the first place. No, don’t tell me; I’ll never believe a word you say.

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