NHAAMA’s Official Position Letter on SB290​

Make your voice heard!

The recent hearing on Auriculotherapy in the state of New Hampshire:

March 7, 2022  

To the members of the House Committee:  

The members of the NH Acupuncture and Asian Medicine Association (NHAAMA) ask  you to vote NO on SB290 pertaining to the deregulation of auriculotherapy. It is our position that passing this bill will have negative and hazardous implications for those seeking and receiving  treatment from untrained individuals, and this bill is not needed.  
By way of background, “auriculotherapy” is acupuncture delivered to the ear. State law defines Acupuncture as a “distinct, dynamic, and continually evolving system of health care that  diagnoses and treats illness, injury, pain, or other conditions by controlling and regulating the  flow and balance of energy to restore and maintain health.” See RSA 328-G:2 VIII. Auricular  acupuncture is a widely accepted acupuncture system, a modality for diagnosis and treatment in  complementary and integrative medicine. Auriculotherapy can be applied as treatment for an  array of medical conditions. Since 2017, a subset of auriculotherapy aimed at detox treatment  has been permitted to be performed in New Hampshire by “acupuncture detox specialists” with 1 specified training under the supervision of an acupuncturist. See RSA 328-G:9-a. Whether it  be detox treatment or treatment for some other medical condition, auriculotherapy is a medical  procedure aimed at treatment of “disease, disorder, infirmity or affliction.” The National Institute  of Health, World Health Organization, Center for Medicare Services, Veteran’s Administration,  and private insurance companies do not distinguish auricular acupuncture from acupuncture. All  are billable as medical procedures with ICD -10 codes and CPT codes specific to acupuncture.2 
SB 290 begins with the incorrect premise that auricular acupuncture is an unregulated practice. There are national and statewide standards for training and certification in auriculotherapy. Today Licensed Acupuncturists, Physician Medical Acupuncturists, and Acu Detox Specialists log hundreds of hours of hands-on and classroom training, which is required by state law. Auriculotherapy is a well-regulated practice that is working for New Hampshire.  
SB290 goes on to authorize persons who have no training in auriculotherapy to perform this variety of acupuncture so long as the person does not “purport to treat any disease,  disorder, infirmity or affliction.” Such a provision begs the question: why would an unlicensed  person with no acupuncture training needle a person’s ear, if not for some perceived health  benefit? What exactly is SB290 aimed to do? Is it enough that the unlicensed and untrained  person be educated in using clean needle techniques? The answer is “no,” clean needle  techniques are not enough training, and of course unlicensed auriculotherapists will infer that  their therapy is therapeutic.  
On a related note, if passed, SB 290 would effectively repeal RSA 328-G:9-a which is already working to allow non-acupuncturists with training and supervision to perform auricular  acupuncture effectively and safely for addiction treatment as Acu-Detox Specialists. Auricular acupuncture is being recognized and promoted by the recovery community because of its effectiveness. Those that are providing the results are trained in specific protocols and techniques. Why would anyone become a detox specialist with training and supervision, if SB290 allows anyone with clean needles to perform auriculotherapy?  


NHAAMA believes it is a mistake to allow anyone of any age, educational level, and  criminal background to provide a medical procedure to the public without proper training and  certification. SB 290 fails to emphasize effective and safe treatments. When the general public  receives treatment below the standard of care, there is an increased potential for harm. Allowing  an individual the right to needle an ear without knowing how to needle, when to needle, when to  treat, and most importantly, when to not treat (i.e., medical red flags) is wrong. A consumer may  consider treatment by an untrained provider of equal value to a skilled practitioner when, in  reality, they are receiving unnecessary, substandard care delaying the care the individual truly  needs and deserves.  
In October, 2021, the NH House issued a Declaration recognizing Acupuncture and  Oriental Medicine Day, and wrote that acupuncture has been used for thousands of years to diagnose and treat illness, prevent disease, alleviate pain, and improve individual well being, and  acupuncturists are dedicated to the highest standards of professionalism, quality of care, and  personal commitment to patients through credentialing, education, and dedication to othersThe NH House Declaration is accurate, and unlicensed, unregulated auriculotherapy shouldn’t  be a part of the New Hampshire way. SB 290 is unnecessary. Please vote NO

 Acupuncture Detox Specialists are not licensed acupuncturists. 1 CPT codes 97810,11,13,14. 2 {C2382123.1