The Good, the Bad, and the Ugly

With apologies to Clint Eastwood, I’m using the title of his classic Western to talk about three major announcements from the Federation of State Massage Therapy Boards, and what they mean to the rest of the profession. This all came down at the recent FSMTB Annual Meeting, held in Tucson on October 3-4.

The Good: FSMTB and NCBTMB reach an agreement on licensing exams.
Woo hoo! Praise the Lord and pass me the MBLEx! After six years of costly and damaging “exam wars” between the two organizations, NCB was unable to keep its market share of the entry-level testing business. As FSMTB’s exam revenue grew each year, NCB’s declined. NCB finally saw the handwriting on the wall and agreed to stop offering its national certification exams for state licensure as of November 1, 2014 – in exchange for an unspecified amount of money.

This is a huge benefit for the profession, as we can finally move towards having a single licensing exam that is under the direct oversight of state massage boards. (Only Hawaii and New York are still hanging on to their own state exams.) It means less confusion for students and massage schools, and a boon to portability of licensure in the future. This has been a long and painful struggle between FSMTB and NCB, and I for one am thrilled to see it come to a peaceful end.

The Bad: FSMTB adopts CE standards and license renewal recommendations.
Two years ago, FSMTB proposed a radical shift to the continuing education landscape, as outlined in their Maintenance of Core Competency proposal. The MOCC was slammed by organizations, schools, CE providers and individual therapists alike – and yet, the worst of it has made its way into FSMTB’s new continuing education and license renewal standards.

This is a classic case of “If it ain’t broke, then don’t try to fix it.” Overall, our existing CE system works reasonably well, so the last thing we need is yet another organization coming in with an agenda to transform and/or grab control of it. Last year, we suffered through an attempt by NCB to do just that. After a massive grassroots effort, NCB toned down most of the unacceptable changes they were trying to force on providers and sponsors of continuing education. They’ve been behaving themselves since then, and their CE approval processes have been operating more smoothly, although personally some of the classes they have approved are still an issue with me. I’d like to see some sort of designation for those of us who don’t practice or teach pseudoscience and don’t want to be lumped in the same category as those who do.

Now we have the FSMTB trying to flex its muscles. It’s like we just got King Kong calmed down, and now we have to do the same with Godzilla!

At the recent FSMTB Annual Meeting, state board reps passed a resolution from their CE Task Force to “implement a program that provides reliable, unbiased and appropriate vetting of continuing education providers and the classes offered to the consuming public.” That sounds high and mighty, but there is no reference to NCB and their existing national Approved CE Provider program in the resolution, and there was no mention of NCB when this resolution and the license renewal standards were presented to the Delegate Assembly for consideration. Did they think that no one would notice this sin of omission?
The LAST thing we need is another CE approval program! FSMTB could have easily solved their delegation of authority issue by entering into a partnership agreement with NCB to use their existing program. This should have gotten rolled into the exam deal between the two organizations, so that CE approvals could be consolidated.

It’s hard to believe, but the resolution was passed without any details on how FSMTB actually plans to vet CE providers and classes. Why should we trust that FSMTB can do this in an effective manner? They’ve been offering the MBLEx for six years now, and they still don’t have an online practice exam and exam study guide for massage students. The very worst of it is that FSMTB’s plan for CE and license renewal centers on “public safety”, while minimizing the role of CE for “professional development”. The problem is that there is no evidence that we have a widespread “public safety” crisis in our profession, so there’s no factual basis for what FSMTB is trying to do. (There are a lot of specific flaws in the CE standards and license renewal recommendations FSMTB has adopted. I’ll detail those in a future blog.)

What I can see from all this is a major threat to the existing CE provider and sponsor system in our field. FSMTB’s proposal is so completely out-of-synch with how CE is organized and delivered, and FSMTB stands to consolidate even more money and power if this model is adopted by state massage boards. We’re just coming out of a period where NCB tried to dominate the field. Now FSMTB is acting like they’ve picked up the NCB playbook and are trying to run with it.

The Ugly: FSMTB publishes the Model Massage Therapy Practice Act (MPA).
As I wrote about in my previous blog, the MPA was released after three years of behind-the-scenes work and two rounds of public comment. Most of its content is the kind of standard stuff found in all templates for occupational licensure. However, FSMTB really blew it in a number of key areas, and the final version contains both technical errors and some awful policy decisions. As FSMTB’s leaders had final say, the responsibility for correcting these fatal flaws rests on them.

Judging from how few comments were made on the three blogs I posted about the MPA, it looks like it doesn’t register as all that important. Wake up people! A model practice act is one of the bedrock components of a profession. It contains the Scope of Practice definition and other essential elements that influence both education and practice. If you haven’t taken time to read our new MPA, I urge you to get familiar with it and keep up the pressure on FSMTB to fix it. Remember that it doesn’t become law unless it’s adopted by a state legislature.

Let’s celebrate the Good, and get to work on the Bad and the Ugly!

Final Draft of Model Practice Act Released

The Model Practice Act was released in its final draft this week, after more than three years of work on it and two periods of public comment. The introduction does state that it will be an evolving document as changing times and circumstances dictate, but as of now, it still has many of the school owners on my social media pages up in arms.

The language requiring accreditation from previous drafts (Section 103(B) ) was modified to say “Approved Massage Therapy Education Program means a school or educational program that meets the criteria established in rule by the Board, at a minimum includes 625 Clock Hours, and is both authorized in the jurisdiction in which it is located and that reflects a curriculum acceptable to an accrediting body recognized by the U.S. Department of Education…” While the requirement has been downgraded to a suggestion, the comment section makes it clear that the eventual goal is required accreditation for one and all.

Personally, I have some mixed feelings on this. Accreditation is a process of quality control–to a point. (Disclosure: I am a peer reviewer for COMTA). Obtaining accreditation is not cheap, it’s rigorous and it’s time-consuming. It sends the message that you have voluntarily gone over and above what the state requires. Other health care professions require it. And therein lies the clincher.

There are no other health professions that I am aware of accrediting programs that teach psuedoscience, and many massage school programs, including those accredited by COMTA and other accrediting bodies–and in the case of community colleges, even the regional accrediting bodies–do. So what does that really mean? Is it really a hallmark of excellence when we accredit things that have no basis in fact, just because it’s tradition, and been around for a long time, even though it’s been shot down by science?

I am not a school owner, but if I was, I wouldn’t be hitting the panic button just yet. The FSMTB has no power of legislation and they can’t lobby. In order for accreditation to become the law of the land, that’s what will have to happen: it will have to become the law of the land, literally, through legislative changes. There may be some FSMTB member states who are gung-ho to see it happen, but remember, state boards can’t lobby, either. That is the domain of the professional associations. In my state, our AMTA chapter has paid a lobbyist for many years. Since the chapter fees are now optional, I have heard that he volunteered to continue working at a lesser fee, but I bet some of the state chapters have lost their lobbyist altogether, if they had one to start with. The wheels of government don’t turn that quickly unless they’re greased.

The MPA is a template for the states. It isn’t the law and it may never be. For the few unregulated states, should they finally get out of the Dark Ages and decide to regulate, this will be very time-saving for them. It isn’t perfect; nothing is. Obviously a lot of work went into it. Only time will tell what effect it is really going to have.

Model Practice Act Causing an Uproar

Disclosure: I am a peer reviewer for COMTA.

I have complained a lot about massage therapists sitting on their hands, not having any interest or involvement in governance, and not caring or being informed about what is going on until it’s too late to do anything about it. I can’t make that complaint about massage school owners in the past couple of weeks. I’ve never seen such a hue and cry over any other issue.

The Model Practice Act is on its second period of public comments, and I’m pretty sure the FSMTB is hearing from a lot of upset people. I had a few issues with the first draft, and I hear it got about 1300 comments. I’m willing to bet this one will get twice that, caused by a one-word change in the following definition, found in Section 103(B):

Approved Massage Therapy Education Program means a school or educational program that meets the criteria established in rule by the Board, at a minimum includes 625 clock hours and is both authorized in the jurisdiction in which it is located and is accredited by an accrediting body recognized by the US Department of Education. Education received outside of the United States must be substantially equivalent to the criteria of this Act and must be recognized by the jurisdiction in which it is located.

In the first MPA draft, this requirement for schools was stated as state authorization AND/OR accreditation. The removal of just one word here makes a world of difference, which has set the massage education community into a tizzy.

My Facebook is buzzing with comments from school owners, teachers, and other interested parties. Overwhelmingly, the feeling is that this is going to put a lot of schools out of business. There are also people that feel that we have about twice as many massage schools in the US as what are really needed, and that this has led to churning out too many graduates, which has led to a glut in the job market, and contributed to the proliferation of franchised massage (or maybe it’s because of franchised massage).

Rick Rosen is the co-owner of Body Therapy Institute in Siler City, NC, one of only two schools in our state that are accredited by COMTA, shared some of his comments on it with me:

There are two primary reasons this accreditation requirement is inappropriate and potentially damaging: First is the fact that about half of all massage schools in the U.S. are not accredited. In general, these are smaller proprietary institutions that only offer massage programs. It is doubtful that most of these schools could qualify for accreditation even if they wanted it, because of the lack of financial resources. Smaller schools that are undercapitalized are unlikely to be able to meet the financial ratio requirements of COMTA and the other accreditors, not to mention the initial and ongoing costs of accreditation.

These massage-only institutions embody the lineage of massage therapy and the healing arts, as contrasted with for-profit career colleges and publicly-funded community colleges where massage is one program among dozens (if not hundreds). Mandatory accreditation WILL cause many of these smaller schools to close, which would be a tremendous loss for our field.

Second, COMTA is the only specialized accreditor in the massage therapy field, and the only agency with competency-based curriculum standards. Institutional accreditation by the other six vocational accreditors and the seven regional higher education accreditors fails to provide a meaningful measure of quality assurance for the massage program itself.

Therefore, it makes no sense for FSMTB to include an institutional accreditation requirement in its Model Practice Act when such accreditation (in the case of non-COMTA-accredited schools) ignores the elements that are critical to producing a well-trained massage therapist. It is the integrity of the program’s curriculum, the competency of the instructors and the consistent application of admissions criteria that are the critical elements that make a sound massage therapy program — far more so than the financial and operational standards that comprise the bulk of institutional accreditation.

So, if roughly half the massage schools in the U.S. cannot qualify for accreditation, and the other half (minus the 67 schools and branch campuses that are under COMTA accreditation) are accredited under institutional standards that do not reliably produce skilled and employable massage therapists who last more than two years in practice — where does that leave us?

We need a regulatory structure for schools that can satisfy the minimum requirements of state massage statues for protection of the public, while preserving the ability of our smaller massage schools to exist. In addition, we need a mechanism to bring all massage programs under single set of programmatic standards to establish consistency of entry-level training that is impossible to achieve within the current system.

Rosen’s solution is for COMTA to add a non-accreditation level program approval to its scope, which would require the blessing of the USDE. In addition, all massage schools with institutional accreditation from other agencies would also need to seek programmatic accreditation from COMTA – a structure that is common in other regulated professions. The language in Section 103(B) of the MPA would then need to be changed to include programmatic accreditation OR approval by COMTA – along with approval or licensure by the educational authority in the jurisdiction in which the school operates.

There are a lot of other school owners out there that don’t feel any accreditation should be required at all, particularly owners of small schools who have long-standing, successful programs that have lasted for decades without accreditation. Accreditation is not cheap. It’s time-consuming to initially obtain, and time-consuming and expensive to renew. While I have heard many small school owners talk about the expense as a deterrent to getting accreditation, I’ve heard as many others say “I’m not going to have anyone telling me how I have to run my school.”

Sandy Fritz, who has owned a school (not accredited) for more than 30 years and is a well-known author and advocate for massage education, stated on her blog that accreditation was a good thing–and then it moved away from a process to determine excellence and became a hurdle to jump across to access the cash cow of financial aid.

Actually, institutional accreditation has always been about being a financial gateway rather than a hallmark of excellence. When COMTA came on the scene, it was the first accreditor to offer programmatic standards that were meaningful to massage education. Unfortunately, they’re also the smallest player on the accreditation field and have no real ability to affect the whole.

I can’t speak to the other accrediting agencies, for my experience as a peer reviewer for COMTA is that a school that seeks the accreditation is sending a powerful message: “I do more than the state requires me to do.” Accreditation involves an in-depth self-study, and documentation, documentation, documentation. If it isn’t in writing, it doesn’t exist. But that’s a good thing. It ensures that policies and procedures are in place that are for the good of the student, the good of the school, and the good of the profession.

COMTA has been criticized for including pseudoscience (energy work) amongst the things that are acceptable for curricula in accredited schools. Without have read the standards of the other accrediting agencies, my guess is that they do, as well. The NCBTMB condones it, the AMTA and ABMP both condone it, the FSMTB condones it, so COMTA is hardly the lone ranger. It just goes to show, once again, that massage therapy accreditation is not being held to the same standards as medical professions do with their accreditation, which is why we’re still a vocation and not a profession.

The period of public comment ends on August 15. If you want your voice to be heard, you should seize the opportunity by clicking here.

 

Expanding Our Scope, Protecting Our Future

There have been numerous attempts to come up with a good working definition of  massage therapy. While I certainly appreciate the effort that has gone into them, in my opinion, most have fallen short in one way or another. Part of the problem is that massage therapists are independent-minded and are harder to organize than a bunch of cats. If you look at the 44 state massage laws that currently exist, you’ll find 44 different versions of what is called a scope of practice definition. Add to that the newest definitions found in the MTBOK and the ELAP, and we’ve got a murky mess that makes it nearly impossible to achieve portability of licensure. In fairness to the creators of both of those documents, which were collaborative efforts with support from all of the professional massage organizations, they were put out for public comment, which really didn’t amount to a ripple in the general scheme of things. My attitude is, if you didn’t take time to comment, then don’t gripe about the results.

We arrived here because there was no common template that was used during the rush to get state massage license laws passed over the past 15 years. Licensure standards are much more consistent in other healthcare professions because each one has been working from something called a Model Practice Act (MPA). I’m wondering… where can we get one of those?

Well, after nearly a decade after it came onto the landscape, the Federation of State Massage Therapy Boards has finally come up with their own MPA. They’re wrapping up the open comment period on the first public draft of this document, which has been posted to the their website. Much of it is run-of-the-mill legislative kind of language, but some sections really need further work. I’ve sent them my comments, and I hope you have too.

What I’m most concerned about in the FSMTB Model Practice Act is the scope of practice definition. As presented, it could restrict what massage therapists are allowed to do in their practices in the future. That’s a giant problem. If we define ourselves in a narrow way, other healthcare providers and business interests will ensure that we stay in our own little box.

Fortunately, I just heard from my North Carolina colleague Rick Rosen on this subject. He has developed what I think is a much more appropriate definition that strengthens and clarifies the diverse range of massage therapy practice in a way that expands possibilities, rather than shrinks them. By the way, Rosen was one of the co-founders of FSMTB, and was also the founding chairman of our state licensing board in NC, where he contributed to the writing of its laws and rules. Here’s what he said in his comments to the MPA Task Force:

“I am concerned that the definition set forth in Section 103 of the MPA is potentially limiting, as it characterizes the work performed by licensees as only that which relates to the manual application of techniques to the soft tissues of the body. Massage therapists are much more than pressure-delivery technicians. For example, they interact with clients in varied ways and provide assessment, treatment planning, and make recommendations for changes in a client’s ergonomic usage and movement patterns that can reduce chronic muscle tension. In addition, massage therapists can work with body awareness to assist clients in reducing stress and developing a healthier sense of self.”

“During the start-up phase of FSMTB in 2005, we looked carefully at the structure of board federations in other health care professions. I remembered from that research that most health care professions had robust and extensive scope definitions, as compared with the relatively one-dimensional definitions found in state massage practice acts.
With that in mind, I accessed the current model practice acts from the fields of nursing, physical therapy and occupational therapy. Using these templates as a guide, I developed a new definition that is broadly inclusive of the range of treatment models in our field, and establishes an expanded scope that more accurately represents the major areas of application in clinical practice.”

With that said, I’m sharing the full text of Rosen’s proposal for a new scope of practice definition:

PRACTICE OF MASSAGE THERAPY. A healthcare service of the healing arts provided to clients by a person who is licensed pursuant to this Act.

(1) The practice includes:

(a) Assessment of the functional and structural characteristics of the myofascial network and related systems of the body through tactile, visual and verbal methods;

(b) Treatment of the myofascial network and related systems of the body using manual methods, or by mechanical or electrical devices or tools that emulate or enhance the action of human hands;

(c) Active or passive movement of the body within the normal anatomical range of movement;

(d) Application of lubricants and other topical agents to the skin;

(e) Use of hydrotherapy and other adjunctive methods to produce therapeutic effects;

(f) Client education to facilitate body awareness and self-care;

(g) Treatment planning, communicating or collaborating with massage therapists and other licensed healthcare providers, and engaging in research, teaching and administration.

(2) Primary areas of application for massage therapy include:

(a) Wellness/Stress Reduction: treatment that supports the general health and well-being of the client, facilitates the relaxation response, addresses patterns of chronic tension related to stress, reduces pain and discomfort, promotes a more positive sense of self;

(b) Corrective/Rehabilitative: treatment that addresses specific symptoms or conditions, provides rehabilitation from the effects of injury, trauma or surgery

(c) Performance Optimization: treatment that improves the performance of specific activities or occupations, facilitates postural alignment and more efficient ergonomic patterns of use;

(d) Palliative: treatment for clients in recovery from illness or in the end stage of life that focuses on providing psychosocial support and relief from discomfort;

(e) Integrative: treatment that promotes awareness of the connections within the physical, cognitive and emotional aspects of the client, as well as treatment in conjunction with other licensed medical or mental health providers in a coordinated plan of care.

(3) The practice does not include:

(a) The diagnosis of illness or disease;

(b) Medical procedures, high-velocity low-amplitude chiropractic adjustive procedures, or prescription of medicines.

(d) The use of modalities for which a license to practice medicine, chiropractic, nursing, physical therapy, occupational therapy, acupuncture or podiatry is required by law; or

(d) Sexual activity of any kind.

I think Rosen has nailed it here. Without going beyond what we should do, this is more inclusive and a much more accurate description of what we do actually do. This more inclusive definition could save us headaches down the road if we are challenged by other professions for infringing on their scope of practice.

Today, June 15, is the last day for public comment on the MPA. Please pass this around… this should be the start of some interesting and important discussion. There’s nothing less than the future of the massage therapy profession at stake, so we have to get this piece right! Don’t sit on your hands. Take the time to comment, and if you don’t, then you are giving up any right to complain about it after the fact.

FSMTB Releases Model Practice Act

The Federation of State Massage Therapy Boards released the Model Practice Act a few days ago, just after the third anniversary of the announcement they had formed a Task Force of 8 state board members to work on it. I just had the time to read it in its entirety today, and as a former state board member and former delegate to the Federation myself, I appreciate the huge amount of time and effort that went into it.

I didn’t find much that surprised me. Last week when this was first released, I saw some rumblings from educators and school owners about the requirement for massage therapy programs to be 625 hours. As the publication says, it is consistent with the 625-hour recommendation of the recently-released ELAP (Entry-Level Analysis Project) that was a collaborative effort supported by all of the national massage organizations. Since there are currently more than two dozen states that still have 500 hours as their entry-level requirement, that’s going to require some major changes. Many smaller schools would probably go out of business rather than comply with the change.

The document does not state the name of the NCBTMB or any other entity’s exam in the context of eliminating them, but the definition of “examination” is given as a standardized test or examination of entry-level massage and bodywork knowledge, skills, and abilities that is developed and administered by the Federation of State Massage Therapy Boards. That means the MBLEx, period. About 40 states are currently accepting both the MBLEx and the NCB’s licensing exams. There are also a couple of states that have their own exam–and require much more than 625 hours. I don’t see that those states will want to back up and adopt this.

The MPA does seem to support portability in a good way. There are provisions for therapists participating in planned out-of-state events, temporary assignments such as with traveling sports teams, etc.,and emergency response disaster teams without requiring jumping through hoops. It would also seek to make the title of each state’s act the _____Massage Therapy Practice Act, leaving the term “bodywork” and any other terminology out of it. Licensees would be designated “LMT” (Licensed Massage Therapist) uniformly across the states.

One thing that I was not crazy about was the protocol for choosing board members. The MPA states that 7 members are to be appointed by the governor. I would prefer to see that power spread around a little. I wouldn’t want to see governors of any political party appointing only the people for their own party, for example. In my state, the appointees are made by the governor, the speaker of the house, and the senate pro tem. I think that or something similar is a little better balance of power, personally; even if they do randomly turn out to all have the same party affiliation.

I also wondered about the discrepancy in defining “clock hour” as 50 minutes of instruction and “contact hour” as 60 minutes of instruction. The NCBTMB has traditionally allowed 50 minutes of instruction as a contact hour for the purpose of continuing education.

The states are also still left with more autonomy than I expected. There’s plenty left in their hands, so to speak, with the usual statements about how the board may adopt, amend, and repeal rules. There is also a licensure by endorsement stipulation and a grandfathering accommodation.

There are only five states left without licensing. It would certainly be to their advantage to have this right out of the gate and avoid having to reinvent the wheel. As for the other 45 states that are already regulated, I don’t see that there will be a mad rush to adopt this, unless what they currently have isn’t working for some reason. We have to remember that the FSMTB is not a regulatory body in and of itself, but a coalition of regulated states. They can’t force the MPA on any state, nor are they trying to. It is a blueprint, a collection of suggestions for how to make the states more uniform in the regulation of massage. Too bad it didn’t exist a few decades ago before most of the states got on the bandwagon.

I don’t have any harsh criticisms of the document. Personally, I like the concept of raising the minimum requirement to 625 hours, but then again, I’m not a school owner that would be affected by such a thing. My final analysis: kudos to the people that worked on it. Things like this that are done by volunteers always come under a rash of criticism from people who disagree with the product.

 

 

ELAP: Now that I’ve Read the Whole Thing…

I spent most of my spare time during the past week reading the Final Report and the Entry-Level Education Blueprint of the ELAP. Again, I will offer my appreciation for the collaboration of the Coalition and the team that actually performed the work on this. It was a big project and obviously, people took time away from their own pursuits to participate in it.

Now that I have read the whole thing in its entirety, I have a few observations on it. I quote from the Coalition statement:

We aspire to have this report influence several profession audiences:

• the Federation of State Massage Therapy Boards, which can use The Core as it builds guidelines for a model practice act;

My comment on that: The press release announcing that the FSMTB was going to create a Model Practice Act first appeared on April 1, 2011. In a letter I received dated Jan.31, 2014, FSMTB Executive Director Debra Persinger stated that the Task Force is currently completing the final revisions before releasing it for public comment.

It’s just my opinion that the ELAP will be a last-minute inclusion in that, if it does in fact get included.

• state licensing boards, which can use The Core in setting education requirements for licensees;

My comment on that: What is the Model Practice Act doing, if not that? It seems very possible that this is a duplication of efforts. While there are of course other things included in a practice act, one of them is spelling out the hours of required education. I don’t know any state board that goes much beyond setting the total number of required hours, and how that should be broken down in a general list of required subject matter. Not to mention changing a practice act requires legislative action.

the Alliance for Massage Therapy Education, which can refer to The Core in creating teacher training standards and curricula;

My comment on that: Aha! And therein lies the clincher and the biggest issue I have with it. Since I couldn’t say it any better myself, I am going to share the comment that Rick Rosen left on my FB page:

“The critical missing element that will prevent the ELAP Core Curriculum from being implemented on a wide scale is the lack of teacher training in our field.

I simply cannot fathom why the cash-rich organizations in our field (AMTA, ABMP, FSMTB) would spend significant sums of money on a curriculum development project, while they continue to turn their back on providing the financial support needed to carry forward the Alliance’s National Teacher Education Standards Project. Without this long-term investment in teacher development, educational outcomes and the quality of massage therapy services delivered will remain inconsistent at best.

My comment on Rosen’s comment: Nailed it on the head. And it would be another interesting research project to determine what the average training is of teachers in massage schools across the US.

I will repeat Rosen’s sentiments by saying I would like to see all the organizations give this kind of support to the Alliance for Massage Therapy Education and their National Teacher Standards Education Project. 

The Alliance is the youngest organization out there, and does not yet have the kind of cash reserves built up to move this project along at a better pace. The fact is these kinds of projects do require money in order to come to fruition. The Alliance membership is made up of educators and industry partners, and will never have the kind of membership numbers enjoyed by the other organizations by virtue of that fact. I can visualize the ELAP being very useful to the teacher training project–but they need the money to make it happen. I urge our other organizations and industry supporters to put your money into this project.

• the National Certification Board for Therapeutic Massage & Bodywork, which can use The Core as it identifies beginning vs. advanced knowledge and skills for its Board Certification credential;

My comment on that: The Board Certification exam is already out there and is still practically new. I don’t see any major revisions taking place on it any time soon. The NCBTMB is using their “old” certification exam for their entry-level licensing exams, and has been for years. As a certification exam and a licensing exam should require two different job task analysis surveys and one should not be interchangeable with the other, they are already in muddy water, and I don’t really see how this will clear it up. And, as is the case with the MBLEx, the exams that the NCB is using for entry-level licensing are geared to a 500-hour education requirement. Again, this would require major changes to that as well.

• professional membership organizations, which can use The Core in shaping membership criteria;

My comment on that: Pay the money, show proof that you are either a student or a licensee or a practitioner in an unregulated state, and boom! you’re a member. Within the past few months, myself and others made well-documented complaints about an unethical practitioner who was scamming fellow massage therapists and try as we might, we could not get her removed from the membership rolls of AMTA or the massage listing service. She has now finally been removed, after it was reported that she was also scamming her clients. Or she just didn’t pay her membership renewal fee. Either way, she’s no longer listed, but it took months to get any action on that front.

• the Commission on Massage Therapy Accreditation, which can use the Core in evaluating massage and bodywork curricula for programmatic accreditation;

My comment on that: COMTA has had their competencies spelled out for years. The basic difference I see is that ELAP is spelling out the number of hours to be spent in each subject matter area.

• other accrediting organizations, which can use The Core in shaping their accreditation criteria;

My comment on that: COMTA is the only accreditation organization devoted to massage therapy (and they now also include asthetic programs). The other accreditation programs I am aware of approve of all kinds of schools and programs and use the same evaluation criteria for a massage program as they would an engine repair program. I don’t realistically see it having impact on these types of accrediting agencies, although it would be nice if it did.

• school owners, administrators and faculty, who can use The Core to strengthen or validate curricula and to adopt consistent learning outcomes;

My comment on that: I wholeheartedly agree. I encourage all school owners, administrators and faculty to read this document…and I know the majority won’t take the time. I have seen the prevailing attitude of “I’m not going to let anyone tell me what to do at my school,” when I have tried to promote COMTA accreditation (disclosure: I have been a COMTA peer reviewer). It doesn’t matter if it would vastly improve their existing program. Stubbornness is hard to overcome.

• and potential massage therapy students, as they consider where to enroll.

My comment on that: I would be shocked to know that any potential student is ever going to read the 527- page document to help them choose a school. Just my opinion.

More of my unsolicited opinion: I am not critical of this document on the whole. I think it spells out a good foundational education for entry-level massage therapists as it was meant to do, and it requires 625 hours to do it in.

There are still 26 states here with a 500-hour minimum requirement. While it is very true that there are many schools that exceed their state’s hour requirement, there are also a large number of school owners that are determined they are not ever going to do more than the state requires. Neither do I see it having much effect, if at all, in states that already have higher requirements for education.

The ELAP report states that a 2012 survey showed schools are teaching an average of 697 hours. Still, if this were to be legally adopted, which I think is a long shot at best, it would undoubtedly put some schools in the position of “cooperate or close down,” which in the general scheme of things, might not be a bad thing, if their students are not truly well-prepared.

I am just of the opinion that being prepared to pass an entry-level examination, and being prepared for the real world of massage, are two very different things. It also isn’t about hours, per se, but about competencies–a statement, in fairness, made in the ELAP–but it does take a certain number of hours to teach those competencies, and this is what the work group decided on.

Bottom line: I like it, but I do think that in spite of the Coalition statement of support, that there has been some unnecessary duplication of efforts on some of their parts here, and that a good curriculum can only be effective with good, well-trained teachers. I’d like to see an equal amount of time, money, and effort spent on the National Teacher Standards Education Project. 

 

 

ELAP Final Report & Entry-Level Education Blueprint Released

The Entry-Level Analysis Project Final Report and the Entry-Level Education Blueprint were released today, and it’s a whopper…266 pages in the Report, and 527 pages in the blueprint. Obviously, I haven’t read that all this morning. I do want to take the time to express my appreciation for the collaboration among the Coalition (ABMP, AFMTE, AMTA, COMTA, FSMTB, MTF, and NCBTMB) and to Anne Williams of ABMP in particular, for spearheading the project. Both documents were co-authored by the ELAP workgroup, which included Pat Archer, Clint Chandler, Rick Garbowski, Tom Lochhaas, Jim O’Hara, Cynthia Ribeiro, and Anne Williams.

According to the Report, at the initial meeting of the Coalition in 2011, two pressing issues were identified: the inconsistent quality, depth, and focus of entry-level massage programs, and the lack of licensure portability from state to state.

The big recommendation is that 625 hours of education are needed just to give students the core basics that they need for entry-level competency. According to the report, currently 28 states only require 500 hours; 7 require between 570 and 600, and 10 states require more than 625 hours. In my opinion only, no matter how wonderful the Blueprint, those states that already have higher standards won’t be inclined to dumb it down for the rest. New York and Nebraska, for example, both have 1000-hour requirements. I don’t see portability happening there–ever–unless every other state decides to come up to that level. However, the Report does reference a 2012 study that states the average massage program in the US is 697 hours–so maybe even in the states with the 500-hour requirement, there is a tendency to do more than required–and that’s nice.

For those schools that are less than 625 hours, this recommendation would undoubtedly increase financial costs to the owner that would have to be passed along to the student.

The shocking news, to me, is the statement that 40-50% of graduates are leaving the field within two years of graduation! I would be interested to know exactly how those figures were arrived at.The Report cites unrealistic expectations about the physical demands of massage and compensation, and the evolving life circumstances of 20-somethings. I’m personally not sure how relevant the 20-somethings are; it’s been my own experience in the past 15 years that there are as many middle-aged people (whatever that is, nowadays) that take up massage as a second career as there are young people who jump in right out of high school.

The workgroup would like to encourage everyone to pay more attention to the core curriculum than the hours. According to the document, this can serve everyone:

  • The Federation can use it as a guideline for the Model Practice Act
  • The state boards can use it in setting hours for education
  • The AFMTE can use it in setting teacher standards
  • COMTA can use it in evaluating massage and bodywork criteria for accreditation
  • the NCBTMB can use it for identifying entry-level vs. advanced knowledge for Board Certification
  • Professional membership associations can use it in shaping membership criteria
  • School owners, administrators and faculty can use it in validating curricula and adopting consistent learning outcomes
  • Potential massage therapy students, as they are deciding where to enroll.

There is, within the document, the subtopics of Eastern bodywork, TCM, concepts of qi and all the accompaniments to that, with the caveat that schools may choose to integrate that according to their own philosophy. The focus is on the application of Shiatsu, tui na and Thai massage, which I will not argue the efficacy of, without personally buying into the theory behind them. I’m not going to have this argument here because it wears me out, and frankly, I’m outnumbered.

There is no doubt that a huge amount of work went into this project. Personally, I gave a lot of feedback on it during the calls for comments that happened some months ago, as did several other educators I know. I wasn’t crazy about this idea when it was initially introduced, and I was further distressed by the way the review and comment process was set up…I didn’t think it was good to have such a piecemeal approach to it, but in reality, I feel that the chance that many more people would have responded to the whole thing is probably relatively slim…it would have been just as long in any case. Anne Williams stated during one of the presentations on it that I attended last year that it isn’t perfect, but what is? I sincerely do commend everyone who gave of their time and effort on this huge undertaking. I plan to say more about it after I’ve read every page.

 

CE: No Approval is Better than Faux Approval

This is hardly the first time I’ve had gripes about the state of continuing education for massage therapists in the US. I’m not happy, and I haven’t been happy for a long time. I’m a CE provider myself, approved by the NCBTMB. That approval is accepted in many places, but there are some states that run their own CE approval processes. Sometimes, the cost and the amount of paperwork just can’t be justified to teach one class that may or may not fill. The CE environment, at least in my state of NC, is also very competitive. It seems there’s a provider on every corner here.

I’ve been distressed with the NCBTMB as an approval body for a long time, due to the total claptrap that they have approved. I also didn’t care much for the MOCC plan proposal from the FSMTB, which would have made all CE voluntary, except those classes that are about public protection, put forth by them on their website. I feel that has the potential to put a lot of good CE providers out of business.

I think it’s time to do away with two prevalent myths that have been used as the rationale for CE regulation: one, that the public is being seriously harmed by massage therapy, and two, that the current CE approval processes are able to provide quality assurance. It’s impossible to guarantee the competence of CE providers or the quality of their courses when it may not be there to begin with. Our field will never advance, and we will not be taken seriously by other health care professions if we continue to operate under these false pretenses.

I recently called for the other organizations to pool their resources to get the NCBTMB written out of the exam requirements in all states. North Carolina set an important precedent for that five years ago by choosing to accept only the MBLEx (except for a limited use by out-of-state applicants). This has simplified the testing process for schools, graduates and that board, and put the regulatory program on solid legal ground.

Rick Rosen has proposed a couple of alternative solutions for CE regulation, the first of which was a National Registry. He has now tweaked that into new template entitled Model Continuing Education Regulations: A Streamlined and Simplified Approach for State Boards.

I don’t agree with Rosen on everything, but I think this is a good plan. Ultimately, I would like to see states refuse acceptance of CE that is not science-based (other than classes such as marketing, ethics, etc.) one of the points Rosen and I disagree on. However, I’m being realistic when I say that probably is not going to happen in my lifetime.  

My main beef here is that  state boards need oversight of what they accept for CE, and they need to have control over entry-level examinations. As long as the NCBTMB is written into state statutes and rules, the regulatory boards are forced to blindly go along with whatever NCB does. As Rosen has pointed out many times in the past, that is an improper delegation of authority—and I definitely agree with that. FSMTB is not even following the advice of its own legal counsel in getting state boards out of this troubled relationship with NCB. Instead of hanging on to so-called “licensure” exams and a failed CE approval program, I would prefer to see the NCBTMB developing specialty certifications, which IMHO is what they should be doing.

It all boils down to this: no approval is better than faux approval. For all that it currently means, we could just do away with CE approvals altogether let the market deal with the good, bad and everything in between. As long as Flower Faerie Healing is acceptable for CE credit, that’s pretty much what we have anyway—except we’re paying for the privilege.

Here’s the Rub

A couple of different things are bugging me today, so here’s the rub: The NCBTMB referring to their licensing exams as certification exams. There was a period of time when the licensing exams were referred to as the NESL–National Exam for State Licensing.

National Certification, as it previously existed, was retired on Dec. 31, 2012. People who are currently Nationally Certified under the old paradigm have until 2016 to comply with the requirements for the new Board Certification, or lose their “old” certification. I’m not sure of the date that the NCBTMB decided to drop the term “NESL” which indicated a licensing exam as opposed to a certification exam, but now that they have dropped that and are just referring to it as the NCETM/NCTMB, to me it is confusing the issue of what certification is–and is not. I spoke my mind about this yesterday to Steve Kirin and Leena Guptha, and they promised to take this under consideration. As Leena pointed out, they have a lot of things that have gone wrong over the years, and they can’t all be rectified overnight. I do hope they change back to the NESL…in reality they are the same exams, but using the NCETM/NCETMB acronyms has lead people to believe they are Nationally Certified, when in fact they are not–they have simply passed a licensing exam given by that Board, but it is not a certification.

In another development, AMTA sent out a press release this week announcing their new policy of making chapter fees optional. Previously, each chapter has charged whatever they deemed fit for their members to pay. In my state of NC, that was $15…an amount that I found quite reasonable because our chapter rocks! We have a very active organization.

I heard through the grapevine a month or so ago that this had happened, so I went to the source. In a conference call I had with Bill Brown, Winona Bontrager, and Chris Voltarel, they confirmed that the Board of Directors had made this decision in an executive session at the annual convention held in Dallas/Fort Worth, which I personally felt was improper, but they stated to me that it was not improper because direct competitors were present in the open board meeting. I assume they meant representatives of ABMP. I accepted that explanation. The fact is, ABMP is trouncing AMTA when it comes to the membership numbers. AMTA has been around for 75 years. ABMP has only been around for 27 years, and according to their website, they have over 80,000 members. AMTA claims to have about 56,000, the last I heard, but I have heard rumors of lower numbers.

However, I did inform them that I had also heard that Chapter presidents were upset about it, and that a petition was rumored to be going around protesting the decision. The response was “we’ll cross that bridge when we come to it.” From my reports, the petition does exist but has not yet been sent to AMTA. Other than people grumbling about it on FB, there hasn’t been much said–maybe because most people just didn’t know. I made another phone call this week and complained because they hadn’t put out a press release, and that I thought the membership ought to be informed. Communications Director Ron Precht told me that members were being informed at renewal time, so they hadn’t put out anything about it, but apparently they changed their minds.

I posted the press release on my FB page a couple of days ago, and immediately got a few comments from people wondering if the chapters were going to suffer because of this move. I confess I am wondering myself. I hope not, but I have my doubts about the wisdom of this move. I reported on AMTA’s financial health a few weeks ago, and while they’re certainly not in any financial trouble as a national organization, I can’t speak to the financial health of the individual chapters.

One thing I can speak to is the fact that chapter money is used to pay lobbyists, among other things, and we need government representation now more than ever. The ACA stands to have an impact on the massage therapy profession. There are other things swirling from several fronts that could require legislative changes in many states, such as the Model Practice Act the FSMTB is working on, a continuing education paradigm shift that may or may not happen, and other things that government relations representation is clearly needed for. Although most chapters have a government relations representative, those folks are volunteers, and in all likelihood the vast majority does not have the same political savvy as someone who lobbies for a living. Here in NC, we were paying our lobbyist $20,000 a year the last time I looked. Experienced government relations people need to be on the scene anytime a sunset period is coming up, or anytime statutory changes are being considered. I don’t think the national office has the manpower to be everything to every state when it comes to that.

AMTA states in the press release that they will offer several new services to chapters, so they won’t be part of chapter expenses. And, if a chapter finds that it needs additional financial assistance to maintain necessary and high-caliber services to members, the National Board will look at providing funding. I hope they look hard at paying our lobbyists and not allowing crappy legislation to take over–particularly sunsetting a practice act.

One of the questions that arose on my FB page was what would happen to the huge donation AMTA makes to the Massage Therapy Foundation every year….usually that’s in the amount of $450,000. If they’re not taking it in, I don’t see how they can give it out. I certainly do not want to see the support for the Foundation fall by the wayside.

There are a number of people out there who aren’t going to pay any kind of fee that’s optional. On the whole, though, I think a lot of devoted AMTA members will continue to support their state chapters.

As a member, I have to say that I don’t think this was handled in the right manner. My own opinion is that instead of an executive decision that was made and then foisted upon us, the membership could have been surveyed, or at a minimum, the state chapter presidents polled. My guess is this we haven’t heard the last of this. I’ll take bets they’ll have to back up and punt.

Report from Seattle and Some Further Explanation

I was invited to Seattle by Dr. Ravensara Travillian to speak at a fund-raising dinner this past Monday night, to kick off her efforts to get a university-level certificate massage program started. Dr. Christopher Moyer was the other invited speaker, so I felt like I was, as we say in the South, “in high cotton.” I had a great time visiting with Ravensara and her husband Iain, and Christopher.

Most of our visit was spent discussing the project. Raven invited me on the basis of my knowledge of regulation and legislation, of what our massage organizations are up to, and the state of massage therapy education in the US. Prior to my going out there, I contacted some of our leaders to make sure I had up-to-date information on what’s going on with them. In fact, this week the Coalition (previously referred to as the Leadership Summit) is taking place in Florida…the CEOs/EDs and Chairs of the Boards of ABMP, AFMTE, AMTA, COMTA, FSMTB, NCBTMB, and the MTF are coming together to discuss the state of the union, so to speak.

I truly enjoyed seeing old friends and meeting some new ones that I had previously only met on FB, and some I didn’t know at all. I appreciate the fact that they came to hear more about this initiative. Good conversation was stimulated, good questions were asked. The speakers were videoed and that will be released in a day or two, so I’m not going to rehash everything that happened there; I’ll share the video when it comes out.

I particularly appreciated the presence of Bodhi Haraldsson, who is the Research Director at the Massage Therapists Association of British Columbia. Bodhi was appalled at my report on the financial status of MTs in the US, provided to me in the form of the Annual Report from the FSMTB. Their information was obtained by a survey of MTs in the member states, and compiled from surveys that were sent out by the AMTA and ABMP to their members, and the NCBTMB to their certificants. All in all, about 200,000 MTs were surveyed. The piece of news that shocked Bodhi was that 61% of MTs in the US say that they cannot support themselves/their families with their income from massage.  Only 2% of therapists surveyed stated that they make over $70,000. According to Bodhi, the five busiest therapists in his own clinic make more than that. Personally, I think that’s a direct reflection of the high standards of education and the devotion to research practiced by our neighbors in BC.

Ravensara’s plan to take massage education up another notch has been criticized by people who don’t understand what it’s about. No one is going to be forced into getting higher education. Since I said this was the report on Seattle and a little bit more, I’m going to seize the moment to repeat a little of what I said there and go a little in depth about the environment of massage. There seems to be a lot of confusion about many different things that are currently on the horizon. One of them is the Affordable Care Act, which contains the stipulation allowing massage therapists to direct bill insurance as long as they are licensed as health care providers in their state. I see the comments all the time that “I don’t want the government telling me what to do.” “I don’t want to get bogged down by the insurance companies.” The ACA does not mandate that anyone has to file insurance. If you want to run a cash practice, you can carry on as usual. Those who don’t want to participate in insurance billing should not interfere with those of us who do.

Another thing that seems to be confusing people is the ELAP (Entry Leval Analysis Project). As I have stated on my blog on several occasions, I had issues with the way that project was rolled out and the way it was presented. However, I do think it will turn out to provide valuable information, and we’ll all know on December 16, which Anne Williams of ABMP informed me will be the unveiling of the 776-page document.

I have seen school owners stating that they didn’t want more regulations telling them what to do and how to run their school. Again, this seems to be a point of confusion. The ELAP is a research project. Period. It is not regulatory in any way. No one will be forced to adopt whatever policy recommendations might come out of it, because they will be just that–recommendations.

AMTA, ABMP, and the AFMTE all have benefits and annual conferences for educators. They have projects going on to educate teachers in research literacy, as does the MTF. AMTA has teacher-track classes and research-track classes at the annual convention. ABMP has an upcoming class in teaching the teachers to write core curriculum. None of these organizations are regulatory. They can show you how to write your core curriculum, suggest what should be included in it, and show you how to teach research literacy. They can’t make you do it, or make you do it their way.

COMTA, which is a strictly voluntary accreditation body and the only one that was founded for the specific purpose of accrediting massage therapy, although they have now also taken in aesthetic accreditation, spells out standards for excellence in education. I hear from school owners that they don’t seek the accreditation because they don’t want anyone telling them how to run their school. The Standards are on COMTA’s website for anyone to see, and I think it would behoove any school owner to do their self-study report to see how you stack up. COMTA does not limit what you can teach to evidence-based modalities, which personally I find unfortunate, but if you’re using that for the argument against it, you’re wrong. If you are teaching belief-based energy work at your school, you’re free to carry on. They want to insure that you are teaching what you say you are teaching and that you are including the subject matter that matters to massage. They spell out standards for good record-keeping, good financial practices, insuring that teachers are competent to teach their subject matter, having and abiding by policies and procedures, and other such things, and they ask you to document it in writing. COMTA is not a regulatory organization. There are other accreditation bodies out there that take in massage therapy, among other things, and they are not regulatory, either. It’s a voluntary process that allows you to say “Here are the standards we have chosen to meet.”

Even the Federation of State Massage Therapy Boards is not regulatory, in and of itself. They are an association of the boards in regulated states. They are soon to unveil a Model Practice Act that they have worked on for the past few years, and they would like for the states to adopt. Notice I said “they would like for the states to adopt.” The purpose of that is to make practice acts uniform and facilitate reciprocity. It could require legislative changes in every state that already has a practice act, should the member states chose to adopt it. I don’t look for that to completely happen in my lifetime. I do imagine it will be discussed this week by the Coalition, along with the ELAP and other issues they are considering.

A couple of months ago, I sent the leaders of all the organizations my blog urging them to pool resources to get the NCBTMB written out of the statutes in every state. I am hopeful that topic will be discussed as well. The NCBTMB is not a regulatory organization–but their exams are written into the statutes in many states. That represents an improper delegation of authority; there is no government oversight and no public accountability there. This is not a vendetta against the NCBTMB; it is an attempt to rectify something that has been wrong all along.

Now I’m down to the function of state boards. I constantly get complaints from people about how long it is taking them to get their exam scores or get their license. There is no true reciprocity in the United States. The fact that you have a license in one state does not include any kind of guarantee that you’ll get one in a different state, regardless of how long you may have been practicing. Most state boards have it stated on their websites that processing out of state requests takes longer. My own experience in serving our state board for five years was that many times, a license is held up because the applicant failed to provide a piece of documentation. Sometimes, the holdup is that they have to check out your transcript to make sure your education in the state your are coming from stacks up to the education required in the state you are moving to. If it doesn’t, you can be denied a license. If you are lacking the documentation, you can be denied a license. They cannot take anyone’s word for it that “I have this, I have that.” If you don’t have the required paper trail of evidence, you’re not going to get it, period.

State boards are the ONLY regulating bodies in massage. They are the ONLY ones who can tell us what to do. The other organizations can suggest. The other organizations can lobby legislators to get laws passed or changed–and state boards can’t. State boards exist for one purpose: public protection. They are not here to serve the interests of massage therapists. They are not here to cater to us or to cater to schools. They exist to license therapists, to spell out the requirements for getting a license, to spell out what they expect from schools, and to deal with complaints from consumers.

I hope that clears up a few things for people. I see misinformation spread around on social media all the time, and all that does is perpetuate misinformation. If you are a massage therapist, you are obligated to know the law in your state. If you are planning to move somewhere, you need to learn the law in that state, prior to packing up and going there. I’ll go further and say that a board member recently said to me “I don’t know the bylaws and rules the way you do.” If you’re going to serve a board, then it’s your business to know them up one side and down the other. Ignorance is not bliss and it’s not an excuse, either. You can’t uphold the rules if you don’t know what they are. The burden is on you.