The undersigned are students, professors, licensed practitioners, clinic owners, and patients who are affected by the new NCCAOM testing regulations throughout the country. Year-round testing for pre-graduates is vital for the the acupuncture profession.

We implore you to not change the testing guidelines starting September 1, 2018 for acupuncture students. The lack of notice to these changes by the NCCAOM is unethical as students were only given three months notice of the new testing guidelines. In other professions, current students would be grandfathered in and the new regulations would apply to incoming students. These new regulations do not support the opinions of acupuncturists nor do they best serve the future generations of practitioners. Requiring applicants to have graduate transcripts and only test within four windows a year harms the profession and creates distress for students and school administrators.

The new regulations prevent current students from completing exams before graduation. Requiring graduate transcripts to sit for the exams hinders students from entering the profession promptly after graduation, creating a slower transition into work. The new regulations also impede job placement for graduates, affecting clinics and patients in need of practitioners nationwide.

The new regulations place students in uncertainty for eight weeks while exams are processed, leaving very little time to prepare for the next testing window if a retest is necessary. Not providing students with their exam scores immediately after testing impedes student success. The new regulations also create a period of contingency in applying for state licensure. Licensing can take up to six weeks, creating a period of 14 weeks from testing to licensure.

Students only have six months of student loan deferment from the date of graduation. Under the new regulations, students would not have enough time to pass multiple tests before they are required to make payments on their loans. This is a significant emotional, mental, and financial hardship to place on students who anticipated completing exams prior to graduation in order to enter the profession before loan payments are due.

The new regulations intentionally harm thousands of new graduates by inhibiting their ability to succeed as acupuncturists. These changes do not decrease processing time or save students money; rather, they produce an ineffective and costly process for acupuncture students to become licensed practitioners and impactfully serve their communities.