Review CAAA Decision Re: Temporary Registration sign now

March 7 2011

Attention: Daniel Mah
Edmonton, Alberta
Re: CAAA’s Position on Temporary Registration
We have received a copy of the CAAA’s position on temporary registration, and having reviewed that memo, the following concerns still apply.
We have noted your position that Restricted Licenses are no longer permitted and while we feel that such interpretation is consistent with the Regulation, we also feel that your position in regard to Temporary Registration being no longer permitted for graduated students is an affront to the education process that we have submitted ourselves to, especially given your change to the interpretation on such short notice, without internship/mentorship program in effect.
On careful review of Acupuncture Regulations Section 3(1) (a), (b) and (c), we submit that it is evident that graduates should, without a doubt, be ELIGIBLE for this type of registration, regardless of how it may have been used/abused in the past. Certainly, any interpretation of the Regulation has now become the common established practice for recent graduates, and it certainly had some significant bearing in our applications to attend college under this program. To now unilaterally state, subsequent to our entire college education being commenced and completed, that we are ineligible to practice in our chosen field of work until such time as we complete the board exam, is quite simply wrong and an abuse of power. It may have been fine if we were to either know these requirements prior to our commencing our education several years ago, OR if that exam were to be scheduled within a very short time frame subsequent to our graduation. Neither of those situations, however, is the case.
We were enticed to commence our education, under the previous policies wherein upon graduation we would be entitled to obtain a Temporary license to allow us to practice until such time as we could write our board exams. Now, on the eve of our exams, it is stated that we are to graduate, and sit in limbo being unable to practice or hone our skills, while we wait an inordinately long period of time to be eligible to sit our exam.
Lawyers, teachers, accountants, doctors, etc. all have intern programs to allow graduates to work and practice their skills while awaiting their time to write their board exams. Our professional body allowed all previous graduates this same type of liberty, giving recent graduates the ability to practice their craft, usually under some form of mentorship, while awaiting their board exams.
Comparably, students with equivalent education in British Columbia apply for student registration and certification in accordance with the College of Traditional Chinese Medicine Practitioners & Acupuncturists of British Columbia Bylaws which allows graduates to practice upon graduation before sitting the British Columbia Registration exam in March and is renewable as long as one has adequate education from an approved college 51(4) (b) CTCMA Bylaws (Feb.1, 2011).
It is now suddenly expected of us, without any reasonable notice, to have to pay our bills, our student loans, and our licensure fees when they come due, WITHOUT any ability to practice in the interim until you allow us the opportunity to write our board exams. This is a travesty, a mockery of the professionalism that our board should strive to achieve and an insult to the program of education offered by the University and approved by you, the CAAA, as an appropriate education for our chosen profession.
According to the criteria in Section 3(1) A person is eligible to be temporarily registered as a member of the designated health discipline of acupuncturist for a period of 2 years if the person:
a) completes the requirements of section 2(1) (a) and (f);
b) has within the 2 years immediately preceding the date of application, practiced as an acupuncturist for at least 500 hours; at least 250 of those hours must have been practiced in Alberta within 1 year immediately preceding the date of application, and;
c) has completed and submitted to the Registrar the applicable forms prescribed by the Minister, and has paid the applicable fees prescribed by the College’s bylaws 2(1).
A person is eligible to be registered as a member of the designated health discipline of acupuncturist if the person has satisfactorily completed (i) a program of studies that has been approved by the Board, or (f) provides evidence satisfactory to the Registrar of sufficient competence in and comprehension of the English language to be able to practice as an acupuncturist in Alberta.
As graduates we empathetically understand the position of the CAAA due to the abuse of this registration and the great amount of changes that need to occur to better our profession. We honour your work and efforts, but respectfully ask for the same opportunities as our predecessors, especially on such short notice.
According to your letter dated February 9, 2011, the new intention of the Registrar of the CAAA is to not grant temporary registration even though we meet the eligibility criteria in the Regulations, “UNLESS THAT PERSON IS FULLY LICENSED IN THEIR HOME JURISDICTION”. You’ve stated that on the basis of interviews with the registrar or his designate, “any or ALL temporary Registrations can be declined”. Based on this, it is apparent that you only intend to license foreign workers that have previously been licensed. You have made ZERO provisions for the interim licensure of your own graduates under the program that you have approved.
It is patently inappropriate that you expect us to graduate and then do NOTHING to be able to maintain our skills, or earn any sort of income within our field, while we await the sitting of our board exams which will not occur for several months. Furthermore, it is not guaranteed that all students will pass that board exam. If that was to occur, and without any form of student mentorship program or Temporary License ship issuance, any unsuccessful candidates would be expected then to take additional time, without practicing or the ability to hone skills, before being eligible to write the board exam again.
Being able to maintain our skills is important as evidenced by the fact that the board is governed by the Health Disciplines Act. We ask that interviews take place (as they are in the regulations) and that consideration for the granting of Temporary Licenses to recent graduates be fairly assessed based on our abilities and individual situations. Many of us have prepared to join the workforce and practice our skills while mentoring under an acupuncturist and member of the CAAA while waiting to take the “Provincial Exam”, Section 2(b) of Regulations.
In this transition year, no information on the date of the exam, preparation materials or cost has been released to anyone eligible to sit the exam to become fully registered. To graduate and then have no legal way to practice the skills tested on our Provincial exam is impractical and unacceptable.
If the Provincial exam date is in October (as it has been in the past); the CAAA is forcing this year’s graduates to be unemployable in their field for a minimum of 5-6 months. It is even more stressful knowing we will be the test pilot for a new examination. Being unemployable in a professional field that all graduates have attended a minimum of 4 years of post-secondary while we prepare to be the test pilots of a new examination format is more than upsetting.
No other professional association forces its graduates to wait to take their exam while offering no temporary registration option-making a blanket statement that any and ALL temporary registrations may be declined on no notice. If the regulations need to change, then we respectfully ask that either a grace period be implemented to the current graduates or that all applications are considered on an individual basis, or an intern/mentorship program be implemented.
We didn’t establish or abuse this system; in fact, we simply have been following the precedent established for student graduates under this program in the past. We would also ask that a date be set for this kind of a change, giving those following the registration some time to make alternate plans, along with giving the CAAA ample time to prepare an exam and allow graduates to take it in a timely manner to join the profession promptly.
We have looked forward to joining our profession and the committees that regulate it and are now told, just four months before graduation, that our new professional by-laws (which by-laws we were led to believe would be in accord with the Board’s practiced interpretation of the Regulations, which by-laws we aren’t sure how to access and which by-laws we are advised are not in effect until November 28, 2011) may prevent us from this.
Please find enclosed the list of students, faculty, and members of the CAAA, and practicing acupuncturists who this greatly affects negatively, all of whom respectfully ask that you review your decision and come to a solution that will benefit all involved.

Grant MacEwan University Students
c: Health Disciplines Act Review Board
c: Alberta Health Minister, Gene Zwozdesky

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Heather MacLeodBy:
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Petition target:
College & Association of Acupuncturists of Alberta

Petition community:
Acupuncture Students of Grant MacEwan University and other Educational Institutions, faculty, registered acupuncturists, patients that will not continue to see their student acupuncturist for they are unable to practice upon graduation (even while mentori


acupuncture, grant macewan acupuncture, temporary registration


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