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Committee debates clinical‑hours, internships and externships; schools urge clearer supervision standards

5023778 · June 18, 2025
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Summary

Licensing committee reviewed the board’s 950‑hour clinical instruction requirement and a regulation that at least 75% of clinical instruction occur in a school‑owned clinic. Schools and accreditors said supervision and assessment — not ownership alone — should govern allowed internship/externship hours; no regulatory change was adopted.

The California Acupuncture Board licensing committee heard extensive comment on clinical‑education requirements, including whether the board’s regulation that 75% of clinical instruction occur in a school‑owned clinic should be revised to permit more supervised internships and externships outside school‑owned facilities.

Staff reviewed the current regulatory language requiring at least 950 hours of clinical instruction, “75% of which shall be in a clinic owned and operated by the school.” Several accredited‑program representatives and school leaders told the committee the stronger quality control element is supervision, site assessment and formal agreements — not ownership.

Rob Hoffman, representing Yo San/USAN University, noted the oversight burden for supervised externships: “it would require a tremendous amount of oversight because that's what it…requires at ACOM. Site visits, applications, memoranda of understanding — it's a huge lift.” He and other school representatives described phased clinical models used at their schools (observation, supervised practice, higher‑level supervised independent practice) and urged clear assessment tools, site‑visit protocols and memoranda of understanding if externship hours are to count toward the 950‑hour requirement.

Several school leaders and clinicians described successful postgraduate fellowship or residency‑style programs in which newly licensed graduates returned to school clinics for paid supervised practice; presenters said those models increase job placement and clinical competence. Philip (President) Young and other school representatives emphasized that externships can expand access to hospital or VA settings and improve students’ integrative‑medicine experience, but they echoed staff and accreditor concerns that quality assurance is essential.

Board staff and counsel noted the board’s regulation currently mentions ownership rather than externship/internship language; staff suggested the schools provide proposed regulatory language aligned with accreditor (ACOM/ACAHM) standards. The committee did not adopt new rules. Members asked schools and professional groups to draft language defining supervision, assessment and the conditions under which non‑school‑owned internships/externships could count toward clinical hours.

Ending

The committee left the item open for additional stakeholder proposals, asking accredited schools to provide sample language and supervision/assessment protocols for committee review. No formal action or vote was taken at the meeting.