Comment period for Traditional Medicine Model Extended
Traditional Medicines Congress
The comment period for a draft concept paper on a new model for the regulation of traditional medicines in the United States has been extended to June 30, 2006.
The draft document, “A Proposed Regulatory Model for Traditional Medicines: Guiding Assumptions and Key Components,” was released by the Traditional Medicines (TM) Congress, made up of nine national organizations,* last November. At least 70 comments have been received to date, but the TM Congress recently received requests to extend the comment period from a number of practicing herbalists.
“From its inception the TM Congress has intended to have as broad a circle of inclusion in the process as possible. This review stage of the work to date, where the feedback by interested individuals and organizations is essential to building support for the model,” commented Bryn Clark, Dipl.O.M., Board Chair of the NCCAOM, which is part of the TM Congress. “We encourage everyone with interest in preserving access to the Oriental medicine material medica to read the draft and provide comments to let us know how it can be improved.”
Three key areas of confusion that were apparent in the initial review process are now being clarified:
The TM Congress is not suggesting that herbs that are now marketed as dietary supplements under the Dietary Supplement Health & Education Act be required to be sold as traditional medicines. Instead, the vision of the TM Congress is to create an optional new category. As envisioned, products in this new category could be labeled with their traditional uses (including medicinal uses) so long as such products conform with traditional criteria such as dose and preparation.
The TM Congress is not attempting to influence the practice of medicine or the scope of practice of any therapeutic discipline. The TM Congress drafted its regulatory model to differentiate between products that are offered for retail sale and traditional medicines that are provided directly to a patient, for example, by an acupuncturist or an herbalist. The primary focus of the model is on the first of these, and attention has been given to the need to ensure that practitioners maintain direct control over traditional medicines that they produce for their patients.
The TM Congress takes no position for or against license requirements for practitioners. Licensing for health care practitioners of every discipline is regulated on a state-by-state basis. The TM Congress has expressed neither support for nor opposition to expanding licensure requirements for any of the practitioners that use herbs in their practices, as this issue is outside of the scope of the Congress’ purpose.
A Proposed Regulatory Model for Traditional Medicines is posted online at http://www.ahpa.org/05_1129_TMCongress_ProposedModel.pdf. Comments should be emailed to TMCongressFeedback@pobox.com.
* Acupuncture and Oriental Medicine Alliance (AOMA); American Association of Naturopathic Physicians (AANP); American Association of Oriental Medicine (AAOM); American Herbalists Guild (AHG); American Herbal Products Association (AHPA); Council of Colleges of Acupuncture and Oriental Medicine (CCAOM); Medicinal Herb Consortium (MHC); National Ayurvedic Medical Association (NAMA); and National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM).
The National Certification Commission for Acupuncture and Oriental Medicine (www.nccaom.org) was established in 1982 and is incorporated as a non-profit organization under Section 501(c)(6) of the Internal Revenue code. Over 17,000 Diplomates are currently certified through NCCAOM, which is a member of the National Organization for Competency Assurance and which is accredited by the National Commission for Certifying Agencies (NCCA).