We are collecting comments about the possibility of a second tier of licensure that would not include training in herbs or the ability to practice with them.  Here is what we have received so far; we will add more as they come in, even after the Town Hall.  Please feel free to add your two cents by commenting below or by emailing nmsocaam@gmail.com.  And please note that these comments are the opinions of the writers and do not reflect any official position on the part of NMSAAM’s board or membership. 


Hello NMSAAM members and colleagues,

Thank you for hosting this discussion with the community.  It’s the first time I have felt included in the discussion about tiered licensure since moving to New Mexico.  This month marks the 3 year anniversary of moving from Oregon to Carson, NM.  Thought I’d share a little about myself and my position on tiered licensure.

I am a naturopathic physician and licensed acupuncturist in the state of Oregon.  October 2023 marks my 10th year of licensure as an acupuncturist and January 2024 marks my 10th year as a licensed naturopathic physician. Currently, I’m in the licensing process for naturopaths here in New Mexico.  I would like to apply for an acupuncture license as well.

In addition to a doctorate in naturopathic medicine, I have a masters in acupuncture which did not include didactic training in single herbs and whole herb formulas.  In the masters program, we learned all the categories of herb formulas and patent prescribing which I do utilize in practice. I also have completed additional coursework as CME in single herbs and formulas which has helped me use formulas more safely and effectively in practice.  However, none of my training in herbs qualifies as acceptable curricula when applying to sit for the NCCAOM Herbal Exam.

Regardless, I practice acupuncture.  I have practiced acupuncture for nearly a decade now.  My herbal training has no relevance in my ability to practice acupuncture safely and effectively.  In Oregon, acupuncturists practice acupuncture and are licensed to do so regardless of their level of herbal training.  The NCCAOM herbal exam is not required in Oregon for licensure.

During my years in practice, I have worked as a locum tenens in two different practices for dual licensed ND/LAc practitioners.  Both doctors completed the MSOM degree which included didactic training in single herbs and compounding formulas. Both doctors passed the NCCAOM herb exam.  In both cases, the doctors very minimally prescribed chinese herbs (if at all) in their practices and, despite their additional training with single herbs and formulas, I treated their patients safely and effectively and could understand their clinical reasoning for any formulas they had previously prescribed for their patients.  I would say that the majority of the dual licensed ND/LAc practitioners I know minimally prescribe Chinese herbs if at all.  The acupuncturists I have known to really gravitate toward herbs, have turned their practice focus to herbs and rarely practice acupuncture.

In any event, I fully support acupuncture licensure for trained acupuncturists who are not able to sit for the NCCAOM herbal exam.  I fully support acupuncturists who continue to improve their biomedicine skills so that they can help patients get the best care and referrals when they need it.  All of us are crucial in helping patients be seen in the healthcare system.

I do not support acupuncture licensing for individuals who take a weekend class in acupuncture.  This is insufficient training and should not be classified as acupuncture in any way.

However, trained NADA detox professionals are necessary.  New Mexico needs these trained professionals.  I support certification for detox professionals to utilize the 5-needle/ NADA protocol in a variety of public health settings. One of my mentors wrote about their experience visiting a center on the border of Mexico where trained NADA/detox professionals are helping people with the 5-needle/ NADA protocol everyday.  He said (and I’m paraphrasing) that the folks trained with the 5-needle protocol who had been using this everyday were so skilled at ear needle insertion and technique that they far exceeded his skill level (in that specific protocol) even though he has been in practice as a DAOM/ LAc for multiple decades.  His humble observations speak loads.

There is room for all of us in this profession.  There are people all over the world who need our diverse skill sets.

Karen R. Peterson ND, LAc



Hello all, here is some input regarding the herb question:

We have one of the (few), best scopes of practice in the country.

We are (somewhat) considered primary health care providers.

Absolutely does the herbal competency have to remain mandatory! Why?

Otherwise we cannot be primary physicians- we need our herbal pharmacies to treat our patients. We even could use more training, for example in Classical Chinese Medicine and research literacy. To be and stay on par with our Western Medical colleagues. To be the best on-top-of things provider for our patients and deliver excellent health care. To not fall into the divide-and -conquer and fall apart as a profession. To not be reduced to “dry-needling” which we know there is no such thing.

This is totally fair to us as a profession, to our patients and all stakeholders.

Being a medical provider comes with a big responsibility, where we do not cut corners or offer less than a high and complete standard of care to our patients.

Offering only Acupuncture may even be neglect or misleading patients, and the public.

As a profession we aim to grow and expand our competence, knowledge, abilities, NOT reduce them. We are moving forward and have accomplished great steps and I encourage everyone to expand upon what we have so far.

Best to all.

Karin Schaufele, DOM



I am writing this letter to show my support for alternative methods of bringing more acupuncturists to practice in this state. The idea of a tiered licensure, which we already have with Rx, seems a good idea. L.Ac., that does not include herbal medicine, would serve the public and would not take away status or business from a more experienced DOM.

Western medicine practitioners have tiered licensure. For example, there are Physician Assistants. The nursing profession has different levels of experience and licensure.

As a provider in a rural town, it is difficult to find acupuncturists who are willing to come to rural areas to practice. If there were more acupuncturists, then the chance that a portion of them would enjoy small town life increases.

With the closing of SWAC, and no state oriental medicine schools to bring practitioners to this state, something needs to be done to increase pathways for qualified practitioners to come to our state.

Sincerely yours,

Jeanne Dixon, DOM


I’m looking forward to hearing and learning as much about this as possible. It seems strange to me that anyone would push for acupuncture w/o herbs as being more of an advantage when working with the Native American population or underserved areas.

Our outreach organization (Herbal Medics) literally started over 12 years ago by traveling with an herbal apothecary to Nicaragua, and then Mexico, and then all over the USA, to include Navajo Nation several times, to provide free herbal clinics for underserved communities that have requested us.

I can’t imagine herbs being any less than about 80% of any treatment I give, and I am running a teleclinic now – 100% herbal of course – but don’t understand how anyone can practice TCM without at least some if not a huge herbal component to it, after spending so long using 100% herbs in austere, post-disaster and remote environments. We literally have an entire program (Austere Medicine) that is based on doing this, in fact.

Anyway, I don’t know if what I’m saying is applicable to the issues, but based on what I’m understanding the proposal(s) to be, it seems like it might be.

I guess as long as it doesn’t take away from those who do the work to get a DOM, then maybe it doesn’t matter, but to me it seems like it’s barking up the wrong tree. If anything, practitioners should be focused on herbs first, needles second. I understand from the standpoint of insurance, this is not possible though too, and I don’t intend to work with insurance at all at this point. But maybe I will change my mind one day on that subject.

Sam Coffman, current DOM candidate


Dear Dedicated and Wonderful Folks Who Support Acupuncture in NM:

I have been licensed Doctor of Oriental Medicine in Santa Fe, NM, since 2002. I had a private practice for my first 10 years of practice, and then began working at We the People Community Acupuncture clinic in 2012. I ended up buying that clinic 2 years later, and worked for 8 years running the clinic and doing community acupuncture (until Covid came along).

I believe a tiered licensure would truly help more people in our underserved State to be able to have access to affordable healthcare, specifically acupuncture. It would also increase availability of potential jobs for newly graduated acupuncturists. And it would only benefit all the various communities in our wonderful State.

There is an extreme need for affordable acupuncture in the State of NM.  We have many underserved people in our State, especially with regards to healthcare. My clinic alone served over ten thousand patients over the course of ten years. We charged a sliding-scale fee of $15-$40, and had patients in recliners in one room together. This allowed patients to be able to afford a series of treatments for various ailments, which allowed for a better prognosis overall.

A tiered licensure option in our state would allow for more Community-trained acupuncturists to potentially open community clinics in NM, and be able to offer their services here at an affordable rate to more people in general. As it stands now, only DOMs can practice in NM. DOMs have a very broad Scope of Practice, including prescribing herbal medicines, which isn’t necessary to implement an effective community clinic.  A tiered licensure could offer different levels of Scope of Practice, which would need to be specified for each license. This would allow for currently practicing DOMs to continue with their Broad Scope, and newly Licensed Acupuncturists to have a separate and limited Scope of Practice comparatively.  They would each provide a necessary and separate service for our communities.

I am passionately dedicated to providing affordable alternative healthcare in NM, and believe this initiative would be a very helpful way to increase this availability.


Katy Whitcomb, DOM


     I am unable to attend either in person or via Zoom due to being at work during the time of the meeting. However, I feel my opinion will assist in giving a pertinent view of the reality of the state of acupuncture/asian medicine in New Mexico.
     I attended and graduated Southwest Acupuncture College in Albuquerque and graduated in 2005. At that point, my family and I relocated to WI where I had a successful asian medicine practice for 10 years. After 10 years, for more than a few reasons, but one of the big reasons being my wife’s health, we moved back to NM. Towards the end of my time in WI, in preparation of moving back to NM and since we’ve been back in NM, I have attempted to pass the NCCAOM Chinese Herbal Module 8 times – each attempt ended in a fail.
     This inability to practice in NM has proved to be detrimental to my family’s ability to thrive. My wife has a thriving therapy practice, however, due to her autoimmune disease she often needs time to take off and recover – we often get behind in bills and find it difficult to afford that time for her. I am working full-time at Lowe’s above minimum wage and it’s still not enough.
     To be clear, my passion is the asian medical arts and I have many plans with my spouse to create and run programs that incorporate assistance to US veterans, people with chronic auto-immune diseases and Women’s health issues, however, this has been put on hold, while I work to complete and pass the one last NCCAOM test necessary to practice in NM, which has been a huge financial drain due to the expense of preparing to take the test and the actual test.
     In my experienced opinion, the Chinese herb module represents an unnecessary hurdle for would be NM asian medical practitioners  and NOT 100% necessary for a successful and solid practice that upholds the values of do no harm and upholding the best of what asian traditional medicine has to offer (this can evidenced in other states where the Chinese herb module is not necessary to have a successful and safe acupuncture practice). I believe a different title designation such as “L. Ac” – Licensed Acupuncturist is sufficient and necessary addition for licensing in NM and upholds the NCCAOM’s mission statement* and would give a much needed boost to the representation necessary in NM to have a strong workforce and connected community of practicing/active/researching practitioners of traditional asian medicine as well as its economy.
Thank you for your time,
Miguel F Cardenas
1. *NCCAOM mission statement: https://www.nccaom.org/about-us/


I am opposed to creating a separate tier for an Acupuncture only license in New Mexico in part because of the following reasons;
1. The argument that it will bring acupuncture to rural areas has not proven true over the past 40 years. There are plenty of DOM’s who have had the opportunity to set up practice in rural areas and chosen not to. Almost always for economic reasons.
2. There is a greater chance of DOM’s setting up practices in rural areas if Medicaid and Medicare start to cover Acupuncture.
3. The Federal government always requires a national standard when they consider including a medical benefit like acupuncture. The POCA model aims to do away with national exams which is the ONLY method to demonstrate a national standard. We may not like this fact but it is how the federal and often state governments function.
4. By creating tiered levels of practice it undermines efforts for National coverage of Acupuncture. For example Acupuncture coverage under the Armed Services was only possible because of the NCCAOM exams and accredited schools that demonstrate there is a national standard.
5. This change would benefit a select few.
6. States find it difficult to regulate a tiered system.
7. New Mexico has been able to create the most robust scope of practice in the country because of its educational and exam requirements. This has been key to demonstrate to the legislature our ability to act as Primary Providers.
Kind Regards
David Canzone DOM



My name is Jenine Durland. I’m an unlicensed acupuncture student at Middle Way Acupuncture Institute in Washington. I’m in strong support of New Mexico expanding access to health care by adding a tiered licensure for acupuncturists without herbs.
I’m currently halfway through my acupuncture master’s diploma in Washington, a homeowner and resident of Santa Fe, and the Head of Google’s Accessibility Design program, which means that my job is to train Google designers to make technology that is accessible to billions of people. At its core, I believe tiered licensure to be an accessibility issue with deep implications for equity, race, and healthcare as a whole.
Adding critical health care professionals will support the work of currently licensed DOMs and allow programs like community acupuncture to begin. Acupuncture services are expensive and remain outside the means for much of the New Mexico population. No one is saying we don’t need more DOMs and trained herbal experts, but this does not and should not negate our ability to add another tier of health care professionals that will allow more affordable options for care. No one in my own family can afford regular access to a DOM, but they are able to go to community acupuncture for chronic conditions. And they get relief. And this is what we should be hoping for. This is NOT dilution, this is expansion.
I moved to New Mexico with the concurrent closing of Southwest College. In order to stay in NM, and also pursue Chinese Medicine, I have been forced to fly, monthly, to Washington, to study in one of the only national accredited programs that operates in an intensive format. In order to add a herbal certificate, I will need to move full-time to Washington.
My goal is to invest in building a community acupuncture health care facility in New Mexico that will provide low cost or free services to people in need. I already have NM-licensed DOM business partners for this. But if I can’t license in New Mexico I will practice in Washington or Colorado. Tiered licensure will make this a financial possibility and offer greater access to health care. Again, herbal medicine is incredibly important and powerful. We are arguing for another track and scope of practice to support health, as so many other states endorse.
Thank you,
Jenine Durland
Santa Fe, New Mexico
I vote no to making LAc’s equal to DOM’s.  It took long enough to achieve Dr. status for acupuncturists in this state.  I don’t want to roll it back.  If no herb exam = no license.  We don’t need to confuse people about our status.  Might as well have no well defined licensure and allow chiropractors, physical therapists and their dry needling, and nurses and physicians assistants to practice acupuncture (“no herbs”).

Thanks, more later.

Jonathan Gimbel, DOM