HEALTH PROFESSIONS COUNCIL
ADDENDUM TO THE RECOMMENDATIONS ON THE
DESIGNATION OF TRADITIONAL CHINESE MEDICINE

The Council, in its 1998 Report on the Designation of Traditional Chinese Medicine, made no recommendation about limitations on practice of TCM practitioners should a college be designated. The 1993 Report of the Council on the Designation of Acupuncture recommended practice limits.

In its 1998 report the Council states:

The risk of harm associated with the use of acupuncture needles was thoroughly discussed in the Council's 1993 Report on the Designation of Acupuncture. At this time, the Council sees no need to elaborate on that discussion and concurs with the conclusions made in the 1993 Report. In that report the Council said: "The insertion of needles below the dermis causes a risk of harm of infection and hemorrhage and the transmission of certain diseases. There is also a risk of puncturing an internal organ."

While the Council did endorse the 1993 Report on the Designation of Acupuncture in the 1998 Report on the Designation of Traditional Chinese Medicine, it did so only with regard to the risk of harm associated within the reserved act of acupuncture. The Council did not specifically determine whether the subject of practice limits should be carried forward for a combined college of acupuncture and TCM.

In light of the investigation of Traditional Chinese Medicine (TCM), reflected in the 1998 Report, the Council decided that practitioners who are trained in the full range of TCM therapies do not require practice limits. In the Council's view, a TCM practitioner who is educated and trained to practice professionally should know when and under what circumstances a referral of the patient should be made to another practitioner. The 1998 Report on the Designation of Traditional Chinese Medicine recommended that three reserved acts be granted to "TCM Practitioner" members of a college of TCM: TCM diagnosis; acupuncture; and the use of restricted herbs. In the Council's view, when a proper TCM diagnosis is made prior to the use of acupuncture by a member of the College who has been educated and trained in the full range of TCM therapies, practice limits are not necessary or desirable. Two reserved acts were recommended for "Acupuncturist" members of a college of TCM: TCM diagnosis; and Acupuncture.

The 1998 Report recognized that any new college of TCM will have as one of its objects under s. 16(2)(c) of the HPA to establish, monitor and enforce standards of education and qualifications for registration of its registrants. The Council also noted that the new college must:

deal with a variety of training programs in determining its registration criteria...additionally there are a significant number of practitioners in the province who were trained in other jurisdictions or in a family tradition. Many do not have a degree or certificate from a recognized educational institution. It is expected that determining educational credentials of potential registrants will present a challenge to a new college during its registration process.

The 1998 Report contained an extensive review of the educational programs available for TCM in British Columbia and concluded that the programs currently available offer at most a two to three year program, none at the doctoral level, and no standardized curricula is available. Prerequisites for entry vary from two years college preparation to a Grade 12 diploma.

The Council made reference in the 1998 Report to the educational system in China, which trains TCM practitioners at various levels of practice, including a doctoral level. The Council stated that it was not in a position to appraise the doctoral programs for TCM in China, however included an excerpt from Towards a Safer Choice: The Practice of Traditional Chinese Medicine in Australia (the Australian Report) commissioned by the Victorian Department of Human Services, New South Wales Department of Health and Queensland Department of Health: "TCM doctoral level graduates in China have full practising rights within all public hospitals and are recognised by the State." According to the Australian Report, TCM training course specifications are determined by the Chinese government, a wide variety of types and levels of education for TCM practice is available including secondary, post secondary, undergraduate and graduate levels and "graduates are then qualified to work within certain contexts and under specific limitations" depending on their educational preparation.

Based upon information received during the consultation process, the Council commented that "there are significant numbers of TCM practitioners practicing in British Columbia who have been trained in the Chinese system. It is also evident that there is a variety of educational resources available within the province of British Columbia and elsewhere in Canada for the training of TCM practitioners." The Council recognizes that wherever the training is received, the level of training is the important criterion for the new college in determining for which category of registrants a member may be qualified to practice: TCM Practitioner or acupuncturist.

The Council recognized the difficulties a new college would have with determining credentials and qualifications of its members. The new college Board would be empowered under s.19(1)(i) to establish classes of registrants. In light of this, the 1998 Report clearly contemplates two categories of registrants, when making Recommendation 7. The Council recommends that the title "Traditional Chinese Medicine Practitioner" be reserved for the exclusive use of registrants who are qualified in both herbology and acupuncture and the title "Acupuncturist" be reserved for those members of the College who are not qualified to use "TCM Practitioner" as their training is only in acupuncture.

In the 1998 Report on the Designation of Traditional Chinese Medicine, the Council identified three options to the Minister of Health for the structure of a College of TCM.

The Council recommended Option 2 and stated: "... The Council concludes that it is in the public interest to recommend the second option, namely that a new college of TCM be established to govern all TCM Practitioners and Acupuncturists."

With respect to the limitations on practice of Acupuncturists set out in the Council's 1993 Report, the Council recommends that the limitations continue for those registrants who qualify as Acupuncturists under the College of Acupuncture entrance requirements.

If and when Traditional Chinese Medicine Practitioners are established as a separate class of registrants under a combined College of TCM Practitioners and Acupuncturists, the limitations on practice be continued only for the reserved act of acupuncture. However, the Council is also of the opinion that the necessity of practice limits should be reviewed at an early opportunity once the College has completed its initial registration process, and the credentials of all practitioners have been assessed.

If the Minister of Health recommends a separate College of TCM Practitioners, the Council remains of the view that TCM Practitioners who are trained in the full range of TCM therapies should have no limits on their practice, including the practice of acupuncture.