The Treatment

What We Propose

The diagnosis is structural. The treatment must be structural. We are not proposing to dismantle the existing national licensure pathway. We are proposing to build alongside it, creating state-regulated alternatives that expand access, reduce debt, and bring the profession into closer relationship with the healthcare system it should be part of.

This proposal does not change scope of practice or lower the standard of care. We are not proposing that acupuncturists be licensed to do less, or trained to a lesser standard. We are proposing that there be more than one approved route to earning a license — routes that are rigorous, state-regulated, and held to the same clinical standards as the existing pathway. What a licensed acupuncturist can do in Oregon or Washington does not change. How someone becomes one does.

State-Regulated Licensure Pathways

Oregon and Washington both have the statutory authority to establish licensure pathways that do not depend solely on ACAHM accreditation and NCCAOM examination. We are advocating for rule changes — to OAR 847-070-0016 in Oregon and WAC 246-803-240 in Washington — that would create parallel pathways: rigorous, state-regulated routes to licensure that can coexist with the national pathway without replacing it.

Practitioners licensed through a state pathway would meet competency standards sufficient for safe, effective practice. The difference is in how those competencies are demonstrated and at what cost, not in whether they are met.

Evidence-Based Competency Standards Developed With Stakeholders

Any alternative pathway must be grounded in clearly defined, evidence-based competency standards developed with meaningful input from the stakeholders the current system excludes: employers, health insurers, managed care organizations, state agencies, and community health advocates, alongside educators and clinicians.

Dr. Bex Groebner, DAc, LAc and the OAA Education Task Force, led by OAA President Dr. Danielle Reghi and Research Chair Kelly Ilseman, are currently in active data gathering and stakeholder analysis. A full framework for competency-based pathway standards, including supporting references and precedents from other licensed health professions, will be completed by the end of April 2026.

Regional Accreditation and Articulation Agreements

Innovating training programs under a state pathway allows options for regionally accredited training programs that can maintain articulation agreements with regionally accredited institutions. This accomplishes two things: it ensures credits are transferable, protecting students who need to change programs or pursue additional training, and it opens the door to undergraduate-level delivery of foundational content, dramatically reducing per-credit costs without sacrificing rigor.

At least two ACAHM-accredited schools have already demonstrated that modular, work-compatible training structures are financially viable and clinically sound. The infrastructure for a different model exists; what has been missing is a licensure pathway that can receive it.

State-to-State Portability

A practitioner licensed under a state pathway in Oregon should be able to practice in Washington, and vice versa. We are advocating for coordinated rulemaking between Oregon and Washington, as well as other states in the region, that builds portability into pathway design from the start, so that state-regulated licensure does not fragment the regional workforce it is intended to sustain.

What Comes Next

The Acupuncture Workforce Alliance and the OAA Education Task Force are advancing these proposals through direct engagement with the Oregon Medical Board and Washington State Department of Health. We are in active stakeholder outreach, data analysis, and policy development. Our full treatment framework, including supporting evidence and specific rule language, will be published here by the end of April 2026.

Medicare recognition for acupuncturists is currently being pursued through federal legislation, the Acupuncture for our Seniors Act, which defines a “qualified acupuncturist” as someone licensed by a state. This language is fully compatible with state-regulated licensure pathways. We are monitoring this legislation closely and will ensure that state pathway design meets the bill’s qualifying standard. We are working on an analysis of insurance reimbursement implications will be included in our framework.