College of





of British Columbia


September 1, 2020

Thank you to everyone who logged on to the virtual Annual General Meeting (AGM) on September 1. We are happy to say that 338 people participated in this important event, a clear indication of the wide interest taken in the profession and the affairs of the College.

As you will recall, registrants were invited to submit questions in advance of the meeting. We received six questions before the AGM and participants will have heard the responses to those during the meeting.

A further two questions were received during the meeting and we are happy to provide answers to those additional enquiries as well.  Registrants are interested in the management of their practices during these pandemic times, in issues related to the College budget and, a more recent development, the prospect of amalgamation of health profession colleges in BC.

For the benefit of attendees, and for those who were not able to join us for the AGM, we provide the answers to all eight questions below. We trust you will find the answers useful.

Question 1: Does CTCMA have any grounds or basis for challenging the Physiotherapists’ use of the term ‘medical acupuncture’ in that the TCM acupuncture training is more extensive and thorough than that received by Physiotherapists.

Answer: Physiotherapy needling practices go by many names, medical acupuncture (or neurofunctional acupuncture) being one of them.  The College of Physical Therapists of BC (CPTBC) uses the term ‘dry needling’ that refers to similar practice and is not the same as traditional Chinese acupuncture.

Dry-needling or ‘needling’ in general in the context of physiotherapy practice, is a relatively new treatment designed to treat muscular pain, most often in the context of sports injuries. Most physiotherapists offering this procedure display a notice stating that they are registrants of CPTBC and not CTCMA, as they themselves recognize the potential for confusion. Additionally, the title Registered Acupuncturist is a reserved title for registrants of the CTCMA, thereby adding another layer of distinction between the two practices.

While both health professions are highly regulated in their respective areas of practice, there is no question CTCMA registrants have unparalleled training in the theories and practices of traditional Chinese acupuncture. This does not mean however that we ‘own’ the rights to the use of acupuncture needles or how they are used by other healthcare professionals. In British Columbia, the use of traditional Chinese acupuncture to treat disease (physical or otherwise) requires a TCM diagnosis, and that skillset/expertise is one that every registrant of this College possesses.

Acupuncture has been used for thousands of years, involves whole body/person treatment to treat disease of all types, and is backed by solid and definitive research. Conversely, dry needling and other non-TCM based needling practices are anatomically focused and is generally considered to be limiting practices, that are still rather new, and research remains limited. What research there is shows some potential as a treatment for pain relief with few side effects. Still, definitive large-scale studies are lacking.

The CPTBC reports on their website that these decisions have been made:

  1. Two years of recent physical therapy practice is requited prior to using dry needling in practice.

  2. A short list or programs approved as foundational for safe and effective dry needling practice has been identified.

  3. A standard of practice for dry needling is in development.

  4. The requirement for continuing competence in dry needling is approved in principle.

CTCMA awaits the completion of this work, particularly the development of a standard of practice, before making an assessment as to whether there exists ample clarity distinguishing the two procedures.

Question 2a: If the existence of TCM in BC is in the public interest, what is the role of CTCMA in its development, beyond educating, monitoring, and ensuring compliance among practitioners?

Question 2b: Given that the public interest is consistent with that of practitioners, does the CTCMA default to the interest of the public, or to that of safeguarding the interests of practitioners?

Answers 2 a & b: This College is the professional authority that regulates the practice of traditional Chinese medicine (TCM) and acupuncture in British Columbia. We are a self-regulatory body operating under the auspices of the provincial government and through the Health Professions Act (HPA), the Traditional Chinese Medicine Practitioners and Acupuncturists Regulation, and College Bylaws.

The College serves and protects the public interest. It regulates and ensures the fact of safe, ethical, and quality TCM and acupuncture practice in British Columbia. We are committed to protecting the public by setting requirements for individuals to enter the profession and practice, govern our registrants in accordance with the legislative framework and are responsible for developing and maintaining disciplinary processes and procedures for evaluating the ongoing competence of registrants.

Our registrants are committed to put public interest over their own. The commitment to their profession, and the College’s support for them in that commitment, is the foundation of the TCM and acupuncture professions’ ability to self-regulate. The privilege of self-regulation comes with the responsibility to keep our house in order.

The associations work for registrants’ interests as practitioners. Associations represent the TCM and acupuncture professions to government, employers, and other organizations. They help develop social programs for members. They support research designed to advance the profession and they work with various organizations to promote it. Associations focus on professional activities, promotion of the profession, and advocacy, including professional image. Associations are self-governing with a board of directors comprised of members; they are not governed through legislative authority. Membership in an association is voluntary.

Question 3: With many acupuncture practices having been closed for a period of time, and now reopened in only a limited capacity, will there be any consideration given to the number of hours needed to maintain registration?

Answer: As stated in Section 57 of the College Bylaws, the conditions of registration renewal are as follows:

57  (1) A full or grandparented registrant who wishes to renew his or her registration must

a) complete 50 hours of continuing education every 2 calendar years that meets the criteria established by the board, and

b) practice acupuncture or traditional Chinese herbology or traditional Chinese medicine at a minimum level (200 patient visits during any consecutive 24 month period) within the last 4 years.

Due to the COVID-19 pandemic, many registrants had to close their practices. Most have now resumed practicing in a reduced capacity. However, the condition (b), stated above, is for a four-year period. Given that the pandemic has affected practices for less than a year, the impact on a four-year period is unpredictable.

Question 4: Can you explain for us the doubling in office rent and 32% increase in wages between 2019 and 2020?

Answer: The College’s offices have moved from 8th Avenue to “The Hub” in Downtown Vancouver. Our new location at 200 Granville Street is in the heart of the city with easy access to transit and the Waterfront Skytrain Station. We are now sharing space with 10 other colleges established under the Health Professions Act.

Along with more space, this new arrangement provided us with greater access to tools and resources, allowing us to create efficiencies and align with other colleges on our shared commitment to public protection.

The efficiencies gained will be realized in a reduction in operation expenses. Specifically, the following services are now included in the rent:

  • Basic utilities (heat, light, power, cleaners, etc.)

  • Office services/management support

  • Centralized reception services

  • Meeting room and arrangements

  • Mailing and couriering including postage and courier costs

  • Secured internet connection

  • Generic office supplies and printing

  • Office recycling and shredding services.

In term of the increase in wages, there has been reclassification of expenses from the “Committee: inquiry, discipline and insurance” expense account to the “Wages and benefits” account. An increase of $195,155 in the “Wages and benefits” account is largely offset by a reduction of $111,614 in the “Committee: inquiry, discipline and insurance” account.

The College has also increased its capacity on the compliance team due to an increase in the number of complaints the College is continuing to receive. In the period April 2018 to March 2019, 24 complaints were received and processed while 39 complaints were received and processed in the period April 2019 to March 2020.

Question 5: Has the College given any consideration to reducing registration fees given the difficulties many TCM clinics have been experiencing due to the pandemic?

Answer: The College understands that this is a challenging time for all British Columbians. Since the registration fees are set out in the College Bylaws, the fees cannot be changed without public consultation and a legislative filing period with the Ministry of Health. Given the complexity of doing so, the College decided to offer an installment payment plan for the 2020 registration renewal fees for registrants who are experiencing financial hardship.

This plan enables registrants to pay their registration fees in two installments – the first one due on June 30th and the second one due on September 30th. This information was communicated to registrants through email, website posting and social media during March and April 2020. To date, over 180 registrants have taken advantage of this installment plan.

Given that many registrants have resumed practice since Phase 2 of the BC Restart Plan, we hope that these arrangements will be sufficient to help registrants through this difficult time.

Question 6: Has the Center for Personalized Education for Professionals (CPEP) been used as the basis for discipline instead of the Health Professions Act (HPA)?

Answer: For those who may not know, the Center for Personalized Education for Professionals or CPEP is a non-profit organization providing competence assessment and intensive education services to physicians and other healthcare professionals. As an unbiased, independent non-profit, CPEP offers fairness to participants and credibility to referring organizations.

The Inquiry Committee is responsible for carrying out the duties prescribed to it under Part 3 of the Health Professions Act. The Inquiry Committee does not utilize CPEP as a basis for punishment but rather as a remedial education course where appropriate, pursuant to section 36(1)(b) of the Health Professions Act. Below is an extract of that section of the Act:

36(1) In relation to a matter investigated under section 33, the inquiry committee may request in writing that the registrant do one or more of the following:

      (a) undertake not to repeat the conduct to which the matter relates;

      (b) undertake to take educational courses specified by the inquiry committee;

      (c) consent to a reprimand;

      (d) undertake or consent to any other action specified by the inquiry committee.

Question 7: What will the College be doing to promote the role of TCM in healthcare, particularly given the continuing challenge posed by COVID-19?

Answer: Promotion of the role of traditional Chinese medicine in the context of healthcare overall is the responsibility of the TCM associations and relates primarily to the promotion of the interests of the profession.  Any questions in this regard would be best addressed to one of the associations.  The College, by contrast, is the self-regulated professional authority that regulates the practice of traditional Chinese medicine and acupuncture in BC in the public interest. The College is responsible for:

  • determining and administrating registration

  • setting standards of practice

  • recognizing education programs

  • maintaining a searchable register

  • addressing complaints.

The College serves and protects the public interest and operates under the auspices of the provincial government and through the Health Professions Act, the Traditional Chinese Medicine Practitioners and Acupuncturists Regulation, and College Bylaws.  Through our public media campaign, the College has worked to raise the public’s awareness that TCM is a regulated profession.

Question 8: What can the College report about the upcoming amalgamation of colleges? How will the unique nature of the TCM profession be upheld given that other health professions are also facing amalgamation?

Answer: The College understands that this is a topic of concern for registrants. On August 27, 2020, updated information announced by the Minister of Health was posted on the College website. Interested registrants can read the recommendations from the Steering Committee of the Ministry of Health here:

The College is considering these recommendations but does not have further information to report at this time.  We are assured that there will be no substantive change compelled until new legislation has been developed following debate in the provincial legislature. This process could take some time. In the meantime, we continue to work in the interest of public safety as required by our mandate.