Dear Ms. Phinney:
It has been brought to my attention that that Board of Chiropractic and Massage Therapy Examiners is considering changes to Maryland's massage therapy regulations. As a Licensed Massage Therapist I find the elements of the proposal dealing with continuing education to be deeply disturbing.
The most troubling change is that which requires the State Board of Chiropractic and Massage Therapy Examiners to pre-approve all continuing education courses. Under this plan, the board will no longer accept courses that are approved by the National Certification Board for Therapeutic Massage and Bodywork (NCBTMB) -- even though NCBTMB certification is the dominant credential used for licensing in the first place. (Certification from the National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) is also recognized for licensure, and as an Asian Bodywork Therapist I believe that is very important.)
This will reduce the quality of continuing education available to LMTs in Maryland. I have received much of my continuing education at the national conventions of the American Organization for Bodywork Therapies of Asia (AOBTA), traveling as far as California to receive instruction from the best teachers available. AOBTA is an NCBTMB certified provider, but if each individual state were to require approval of continuing education courses, such national providers would find it difficult or impossible to continue.
The proposal states that it "has no economic impact" and "has minimal or no economic impact on small businesses." This is a stunningly inaccurate statement. Many, if not most, massage therapists work for small businesses or are sole proprietors themselves, and continuing education makes up a significant outlay. And this proposal would heavily impact continuing education providers both in Maryland and across the nation.
This proposal is not in the best interests of the public, and I strongly urge DHMH to reject it. Thank you.
Very truly yours,
Dipl. A.B.T. (NCCAOM), AOBTA-CP, LMT