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Committee reconsiders clinical hours language; schools ask externships and internships be recognized
Summary
Licensing Committee members and school representatives discussed whether the board's regulation requiring 75% of clinical instruction in school-owned clinics should be revised to allow accredited internships and externships under school supervision.
The committee reviewed the board's clinical-education requirement and heard requests from several schools to allow internships and externships outside school-owned clinics to satisfy part of the clinical-hours requirement.
Staff pointed to the California Code of Regulations language requiring "at least 950 hours in clinical instruction, 75% of which shall be in a clinic owned and operated by the school." Schools and accreditation representatives said ACOM/ACA(H)M standards emphasize supervision and site qualifications rather than ownership.
Board counsel and staff reiterated the difference in language and said the board's regulation currently focuses on ownership. As one committee member explained, the ownership requirement dates back to earlier institutional-approval practices and "has nothing to do with this training requirement that we're talking about."
School representatives described phased clinical models (observation, supervised practice, higher-level supervised practice) and urged more flexibility so students could gain diverse clinical experience in external settings, including VA and hospital-integrative programs. Philip Young and other school leaders highlighted that outside placements can expand students' opportunities and community outreach.
But board staff and ACOM-accredited school representatives warned that internships and externships require formal oversight. Rob Hoffman (USANA University) said expanding off-site clinical hours "would require a tremendous amount of oversight because that's what it requires at ACOM. Site visits, applications, memorandums of understanding . . . it's a huge lift." Other speakers recommended schools prepare sample language and quality-assurance procedures for the board to review.
Committee members did not adopt a rule change at this meeting. Instead they asked schools and accrediting bodies to produce sample regulatory language, supervisory standards and assessment tools so the committee can weigh alternatives to the 75% ownership requirement in a future meeting.
