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Public commenters propose converting tutorial program into 300‑hour clinical externship; committee notes as future agenda item

2547777 · March 11, 2025
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Summary

During public comment, speakers proposed modernizing the apprenticeship/tutorial pathway into a structured 300‑hour clinical externship with research components; the committee acknowledged the proposal and listed tutorial program modifications among future agenda items without taking action.

Several public commenters urged the board to revisit the state’s tutorial (apprenticeship) pathway and proposed a structured clinical externship to strengthen clinical training and research literacy.

Michael McCulloch, a tutorial‑trained acupuncturist with a PhD in clinical epidemiology, proposed converting the existing tutorial program into a 300‑hour clinical externship that pairs students with experienced licensed acupuncturists in supervised clinical settings. McCulloch described goals to increase hands‑on supervised patient care, introduce small‑group clinical research projects, and improve graduates’ readiness for community practice. He asked the board to consider the proposal in future rulemaking or program changes and offered to submit a written proposal for the board’s consideration.

Other commenters raised related education and qualification issues: Philip Yang and others asked the board to clarify transcript and credential evaluation standards for applicants, to review continuing education (CE) course quality and pricing, and to consider alignment between accredited and non‑accredited programs. Commenters also returned to ongoing concerns about dry needling and scope‑of‑practice boundaries and recommended the board address those matters in future agenda items.

Board staff responded that proposed changes to the tutorial program and the issues raised would be appropriate for a future agenda item; the meeting materials and the committee’s executive report would note the suggestions. No regulatory action or adoption occurred at the meeting; staff invited written proposals and said the committee would consider detailed proposals through the standard agenda and notice processes.