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New Time-Limited NCCAOM Certification Route for Active California Licensed Acupuncturists:

A Background Document for State Regulatory Boards


On February 1, 2019, the NCCAOM opened a new, temporary route to certification in Oriental Medicine called – Route 8: NCCAOM Certification for Active California Licensed Acupuncturists. This time-limited route will close on Spetember 30, 2021. Applicants who meet all eligibility requirements of Route 8 will be granted an NCCAOM Oriental Medicine (OM) Certification without the requirement of taking the NCCAOM examinations.

NCCAOM’s opportunity to offer this time-limited route was made possible, at this time, because of the CA Acupuncture Board’s (CAB) 2016 audit of the NCCAOM certification program in OM, as well as the 2016 CAB recommendation to Assembly Professions and Business Oversight Committee to recommend that the CAB begin using the NCCAOM exams for licensure, plus a separate CA state-Specific exam to cover all the content of the current CA Acupuncture Licensing Exam (CALE). At this time there has been no legislation introduced that will make the switch to the use of the NCCAOM examinations in CA.

In 2018, the NCCAOM submitted a proposal to the its accreditation organization, the National Commission for Certification Agencies (NCCA) to show how the eligibility, requirements, exam competency assessment CA licensing and relicensing requirements compared to the NCCAOM’s requirements.

Note, although the OPES Team conducted the audit of the NCCAOM examination development and administration program, as well as examined its psychometric data based on the 2013 NCCAOM Job Analysis study, the NCCAOM did not have the opportunity to conduct an audit of the CALE exam development components and outcomes and did not have an opportunity to see the CALE reliability, validity and fairness data. Therefore, the NCCAOM cannot directly attest to the psychometric reliability, validity and fairness, of the CALE.

After the evaluation of the NCCAOM exams, in July 2016, the CA Acupuncture Board voted to move forward to implementing the NCCAOM exams – please see CAB letter here:   Since this will require a statutory change, it requires legislation and CA  has not yet moved forward with introducing this legislation. We will hopefully have more progress on this topic in the next few months as we are tracking this initiative.  The NCCAOM’s hope is that California will accept NCCAOM exams the national standard as part of their licensure process as do all other states that regulate acupuncture using the NCCAOM modular exams.

NCCAOM Modular Exams Updated Regularly

The examination content outlines used for the comparative analysis are no longer be valid as the NCCAOM began to administer the 2020 certification exams grounded on the newly created exam content outlines based on the NCCAOM 2017 Job Analysis.  The 2017 Job Analysis was a national survey was sent to known licensed acupuncturists and NCCAOM National Board-Certified Acupuncturists™ of approximately 33,000 practitioners. There were 3,285 unique respondents to the survey, representing a response rate of approximately 10%, which is excellent for an online survey.

All states, other than California, that regulate acupuncturists use the NCCAOM national modular exams as part of their licensure process. The NCCAOM exams are even recognized by the Federal government as evidenced by the Veteran’s Administration adoption of the NCCAOM Board Certified Acupuncturists who took the NCCAOM modular exams.  All states, except CA, rely on the NCCAOM modular exams to ensure protection of the public. This is why the NCCAOM cannot guarantee that any state will accept the new CA Route.

The NCCAOM exams include four separate competency examinations that must be passed by candidates for certification in Oriental Medicine. The unique competency areas include Foundations of AOM, Biomedicine, Acupuncture with Point Locations and Chinese Herbology. Each area is tested separately and if one competency area such as Biomedicine is failed, the candidate does not move on to certification. They must retake and pass each exam module required for certification in order to certify. The CALE is a comprehensive exam and a candidate can fail a competency area, such as Chinese herbs, and still pass the licensure exam.

The CALE is a state licensure exam geared for CA practitioners with CA laws which is also included in the CALE, whereas, the NCCAOM exams are modular and based on national competencies validated through a national job analysis.  The NCCAOM national modular exams are updated at a minimum of every five years, following the NCCAOM Job Analysis. States may require all four certification/competency exams for licensure or may only require three exams. For example, if a state does do not regulate Chinese herbal practice, then the Chinese Herbology is not included as part of their competency assessment of licensee applicants. See the NCCAOM interactive map for all state licensing boards use of the NCCAOM exams or full certification.

NCCAOM Third-Party Accreditation

Unlike the NCCAOM’s ongoing third-party accreditation of its certification programs in Acupuncture, Oriental Medicine and Chinese Herbology by the National Commission for Certifying Agencies (an independent commission within the Institute for Credentialing Excellence), there is no such third-party oversight of the CAB’s acupuncture licensing program by a third-party accreditation agency. There is periodic oversight of the CAB by the Joint Assembly and Senate Business and Professions Legislative Oversight Committee.

The NCCAOM received approval by the NCCA, to move forward based several specific requirements:

  1. That the route was time-limited and would end, either when the CAB implemented the use of the NCCAOM exams, or once a new occupational analysis by the CAB resulted in the use of new CALE content outlines; and
  2. Anyone who had never been licensed by the CAB could apply for the route once it opened; and
  3. All routes of eligibility to become NCCAOM certified in Oriental Medicine (OM) were the same as the CAB’s requirements to become a licensed acupuncturist in CA; and
  4. All recertification requirements to become NCCAOM certified in OM were the same as the CAB’s requirements to become relicensed as an acupuncturist in CA; and
  5. Verification by NCCAOM that each applicant for the CA route have a free, and clear, active CA acupuncturist license;
  6. Verification that all applicants for the CA route have a CNT certificate on file with the NCCAOM that is not more than 6 years old; and finally,

All applicants for this route must sign an attestation acknowledging that this route may not necessarily be used to qualify for a license in another state.