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04 January 2005
Is the NCBTMB Nomination Process Railroaded?
A letter by current NCTMB Board of Directors member Elizabeth McIntyre is raising more questions on whether the NCBTMB is open to multiple opinions and serving the public interest or is railroading a particular agenda. McIntyre is in the unusual position of a current board member, wishing to be re-elected, who has been informed by the nominating committee that she does " not meet the current criteria for consideration". In her letter, she requests letters of concern to the other board members. There is a link at the bottom of her letter that will start such an email. Here's a repeat of that link: Email the NCTMB Board. Another context to this is that I'm aware of at least two, highly qualified practitioners, who have had similar responses in the past to submitting for nomination. Because the use of the NCE has been mandated by a number of public agencies, public trust demands that NCBTMB exercise a high level of accountability and transparency in their dealings.
31 December 2004
Year End Hearts & Roses
This seems the time of year to offer a few bouquets of hearts and roses. The first is to Ro and Mani Abreu for their ongoing shepherding of the Yahoo-Groups Body_Work list. The list was started by Greg Tobias in March 1996. The helm was assumed by Ro and Mani when it was moved in April 1999 to what became Yahoo-Groups. Ro and Mani have kept things together, working and growing as an online community with a minimum of fuss and fury — a delicate art.
A second bouquet goes to the staff of Associated Bodywork & Massage Professionals (ABMP). I had the opportunity to tour their place in Evergreen, CO over the Thanksgiving break. They are a small and dedicated enough group that there is a lot of personal investment and pride that shows through in their joint efforts as a service bureau and publishing house. Given that ABMP president Bob Benson, executive vice-president Les Sweeney, and one staff member constitute the legislative arm of ABMP, I'm amazed at how far they stretch; they don't have the head-count or the horses of the proverbial cavalry and thus have to largely leverage off of local groups. Beyond the above, the bouquet comes for practicing the transparency talked about in a recent Harvard Business School "Working Knowledge" article on building trust. In the understated praise of Minnesotan English, if you're considering ABMP, you could do worse.
A bouquet goes to several of my colleagues in the Sports & Deep Tissue program at the McKinnon Institute. Rob McClure has been a solid rock both in teaching and in tracking teacher scheduling. Jason Garcia, joining in this fall, has stepped into our progression of classes with grace, smoothness, and a touch of style — perhaps carryovers from the Salsa dancing he also does. Finally, a thanks to Laura Clegg for her teaching and teamwork. It's with joy mixed with sadness that a bouquet goes her way as we lose her to marriage and Maryland, a place where hell may yet freeze over before she can practice and teach massage again.
A bouquet of hearts and roses to my colleagues and connections in the California Alliance of Massage and Bodywork Schools (CAMBS). From my perspective as a "loose cannon", I've been heartened by their balance in advocating for the business respect due private massage schools while working to provide students will value and respect for their time and money. As with ABMP, a bouquet for transparency and open communication.
A final hearts and roses to my coauthor Jeff Forman, developer and coordinator of the De Anza College massage program. While Jeff and I share a dedication for good education, we also have somewhat different viewpoints. My appreciation to Jeff for his contributions and for his patience in working with a difficult person in the writing of our recent report.
An ending note on the wide-spread devastation in Asia as well as on the less public tragedies that seemingly random events inflict on families and communities. Do what you can via dollars, euros, or just being there with the shoulder or arm for someone to lean on. I note that amazon.com is again coordinating contributions to the Red Cross. An extra bouquet of hearts and roses to them.
My best for the New Year to all!
A Book Well Worth the Looking
The day after Christmas, we were at a physical bookstore indulging my
two son's need to offload some Christmas gift money before the retail neutrons
started a critical chain reaction. This also gave me a chance to just browse
and see if the unexpected could find me. What turning up was a delightful
visual tour through anatomy and physiology. If you want a review but tend
to mentally wander off from the over use of words, take a look at "The
Architecture and Design of Man and Woman — The
Marvel of the Human Body Revealed, by Alexander Tsiaras and Barry Werth,
ISBN 0-385-50929-4. It tackles both the structure and the beauty of what
we are made of. Also check the author's web site, Anatomical
Travelogue, Inc.
More on Public Accountability
In the June/July issues of ABMP's Massage & Bodywork, David Lauterstein contributed an article with the following comments about current activities of the "National Certification Board for Therapeutic Massage and Bodywork", NCBTMB.
Am I going crazy? Or has the National Certification Board for Therapeutic Massage and Bodywork (NCBTMB) lost its way? You decide. Recently the NCBTMB launched a "National Massage Safety Week." The dubious and self-serving implication was that anyone who was not nationally certified was not "safe." I can scarcely imagine a more ill thought-out campaign.
A massage safety week seems to follow on such other weeks as fire safety week, child passenger safety week, farm safety week, and playground safety week. All of these weeks are stressing the importance of awareness and conscious thought toward minimizing hazards while performing activities that contain significant inherent pontentials for serious injury. The dubious aspect for massage is that the potential for serious injury from massage is exceedingly remote. The greatest danger in massage practice is likely from uncautious use of candles, a topic already covered under fire safety week. From the activities of the NCBTMB, the conclusion I have to draw is that they are far from a neutral agency for credentialing based on need and defined outcomes but rather a private agency promoting their own interest and pushing a particular agenda for the massage profession.
As a private organization that also is being used as an agent of the state, self-promotion raises serious questions of conflict of interest with the NCBTMB. This was brought out in last time's posting by the quote from CPIL. The area of anti-trust mentioned in that quote is also a theme in papers on limits of state action immunity and on legal issues affecting accrediting bodies, both available in the resource briefs maintained by the Council for Licensure, Enforcement, And Regulation (CLEAR). CLEAR also maintains a resource brief on job analysis that sets forth the role of such analysis in terms of licensing exams and distinguishes this use from more general issues of business. NCTMB continues to muddy the different roles together; a tendency not in the public interest.
A board must understand the purpose of licensing examinations in order to appreciate the scope and content of a job analysis. The sole purpose of a licensing examination is to identify persons who possess the minimum knowledge and experience necessary to perform tasks on the job safely. By contrast, the purpose of academic examinations is to assess how well a person can define and comprehend terms and concepts; and the purpose of employment selection examinations is to rank order individuals who possess the qualifications for a job.
Licensure-related job analyses differ from traditional job analyses in a number of ways. The most important aspect of licensure-related job analyses is the focus on the critical competencies required to protect the public rather than on responsibilities and knowledge necessary for successful job performance. Activities related to professional development, supervision, in-service training, or business practice are usually left out of the job analysis because they are related to successful job performance rather than public protection.
28 December 2004
Public Accountability
Last posting, we mentioned the Center for Public Interest Law (CPIL). They present a consumer-oriented picture of regulation both in their paper A Theory of Regulation and in their testimony before the Little Hoover Commission's review of the Acupuncture Board. Both the theory paper and the testimony are well worth the read. As noted in passing last time, the CPIL has also commented on the legal issues presented by privatization of state action and responsibility. Here's the quote from the CPIL response to the California Performance Review.
Turning over economic allocation to a market and removing
or lessening state intervention is one thing; delegating police power to
a functioning cartel is another. Prudence dictates caution in the deferral
of any publicly related decision to private “accrediting entities.” The
body of evidence in American unfair competition and antitrust law pertaining
to the market and consumer abuses flowing from cartel practice is considerable.
Deferral to private coordinating bodies is not deferral to a market, but
to a combination of competitors. Such
delegation, where recommended by the Report, should be blue-lined out of
the next serious draft of recommendations. This further refinement is best
accomplished by drafters familiar with market dynamics, antitrust and white
collar crime abuses, and the body of law known as “state action immunity” from
federal antitrust exposure. The last element is a practical necessity given
the violation of federal antitrust law implicit in the delegation of public
powers to private sources. Note that under the “state action” doctrine
allowing states to carve out and authorize restraints of trade that would
otherwise violate federal antitrust law (entitled to supremacy), states
must both affirmatively and specifically articulate the restraint to be
allowed, and must exercise “independent state supervision” to
assure that there is no improper delegation of market exemption to private
parties. See the leading case of Parker v. Brown, 317 U.S. 341 (1943);
see detailed discussion in Papageorge and Fellmeth, CALIFORNIA WHITE COLLAR
CRIME (Lexis 2002) at Ch. 2.14 See the Negotiated Rulemaking Act of 1996,
5 U.S.C. § 561 et seq. particularly to organized private bodies not
subject to effective market check.
Here my white paper on the issue presented by the state mandated use of national certification exams. There may indeed be a valid legal basis for concern about effective delegation of eligibility requirements to a private body. Particularly pertinent is the statement of such delegation requiring exercise of "independent state supervision". That sounds like a state could still be held accountable to the public for hearings involved with any eligibility change, even with changes stemming from the action of a private body to which a state function has been delegated. Even if just an exam is used, not an entire certification process, an exam predicated upon changed prerequisites is a de facto change in eligibility to license.
Ethics and Nondisclosure
On the ethics front, the New York Times has an article titled A Young Doctor's Hardest Lesson: Keep Your Mouth Shut.
26 December 2004
MPS Restart
I haven't written for a while, but the Massage Politics Sheet is not abandoned. One of the reasons I haven't been writing here was a report on the Status and Trends in California Massage Education that I've recently written with Jeffrey Forman, coordinator of the DeAnza College Massage Program. This report covers a range of issues from current norms in the provision and use of massage training in California to more general issues of outcome oriented guidelines for advanced work and for inclusion of applicable massage subpractices within the health care system. This report will be the precursor for a series of more focused peer-reviewed papers to be drawn and expanded from it. As it stands, it has been sent to the Senate and Assembly Business and Professions committees, the Department of Consumer Affairs (DCA). The nongovernmental Center for Public Interest Law (CPIL) has also been notified of its existence. The CPIL is a watchdog agency for consumer interests in state regulation (also see below). The report will hopefully thus serve as and objective base for considering massage regulation in the public interest while being minimally intrusive to existing practitioners and schools.
January Hearing by the California JCBCCP
The massage political process in California is restarting with the new year, as is the Massage Politics Sheet. There will be an informational sunrise hearing before the Joint Committee on Boards, Commissions and Consumer Protection (JBCCCP) on Thursday, 6 January 2005. According the the schedule on the JBCCP web site, sunrise matters are one of several issues to be considered between 9am and 4pm. The hearing on massage regulation is to be held in John L. Burton Hearing Room (4203) and will last 90 minutes.
Review of Actions by the Medical Board of California
A news report in last Tuesday's (24 December) San Francisco Chronicle covered the release of a review report severely criticizing the Medical Board of California as being both slow to act in the public interest and secretive. The report was written by the nongovernmental Center for Public Interest Law (CPIL) acting as an independent, consumer-oriented monitoring agency. The CPIL has also recently commented on the California Performance Review (CPR), a plan by Governor Schwarzenegger's administration involving to consolidate or eliminate a number of state boards and agencies. The CPIL has also been involved in numerous other sunrise and sunset hearings. Attached the the CPIL testimony on the Performance Review is an earlier CPIL paper setting forth a theory for regulation That paper is also available separately. One of the items of note in CPIL's response to the CPR was a concern (page 11) on privatization of public accountability. The issue has been seen here before in terms of public accountability lost by any involuntary (i.e. mandated) use of certificaton exams.
03 September 2004
A Viable Outcome from Sacramento County
There was a small planning meeting for Sacramento County on August 24th. The outcome that I hear is that Sacramento County will remain with a requirement for 125 hours of training from a state approved school and add a requirement of passing a locally created exam. The exam would contain about 100 questions from a larger pool of questions obtained from local schools.
The sheriff's department is to research how to implement the exam, using outside agencies to proctor the exam and to offer it once a month. Once such details have been researched, the planning group will then present a proposal to the Sacramento County Board of Supervisors for their approval, and if they are in agreement, there will be another public meeting for massage therapists to give their input.
Given that initial talk was for requiring 500 hours, passage of a national certification exam, and graduation from an accredited school, Sacramento County can be commended for listening and responding to input from the massage profession. All of those who helped in providing this input are also to be congratulated.
28 August 2004
The Toy in the Cereal Box — Marketing the Picture of Massage
Whether for a web page or for a brochure, there are times that a picture best conveys the vision of service and health that we are trying to get across to prospective clients. If you have a budget for a couple of photos, the stock image distributors are a good place to look first. A royalty-fee, for a low resolution image sufficient for web or brochure use, will run between $49 to $99. The $49 images are from health and beauty CDs created by Pixland and distributed by Inmagine. Those in Europe might prefer to deal directly with Pixland. Other distributors include Punchstock, ImageBank, FotoSearch, Stockbyte, PhotoAlto, Comstock, and Suite Media. You can search for "massage" on all of these services. Most provide immediate access to a small thumbnail picture and to a larger picture with a distributor watermark to help you narrow down to pictures you want.
Stock photo vendors generally have two kinds of arrangements, "royalty free" and "rights managed". For royalty free images, you pay a fixed fee to download and use an image at a given resolution. The higher the resolution, the higher the fee. With rights managed images the fee will depend on the specific use and breadth of distribution. Before buying an image, look to see how its release is being handled. In dealing with stock vendors, you get images for which the model being photographed has already signed a model release form. You can also use available stock images to get ideas for having your own photo shoot, but, be sure to get your model to sign a release, as well as having her or him pose for pictures. Here's hoping you "get the picture" you need.
11 August 2004
A Pasadena Example of Charter City Prerogatives
Yesterday's Pasadena, CA Star News carried a story about a massage technician who was arrested in a sting and pleaded guilty to an infraction of "disturbing the peace". The technician's attorney claims state law forbids the city from revoking her license for an infraction. The Pasadena Assistant City Manager argued in a letter that because Pasadena is a charter city, it does not have to abide by the California statute on grounds for revocation of massage licenses. California Charter cities, deriving their regulatory powers over local affairs from the California constitution and their charter, have greater "home rule" powers than general law cities.
07 August 2004
Massage as a Trade
In the sense that massage is a craft dependent on learning physical skills of both perception and application, it fits the definition of a trade. This in no way interferes with coming into massage with the altruistic perspective that also serves to define massage as a profession. A recent article in the Christian Science Monitor, Quick Trip to a New Career, captures this focused mid-life career transition aspect that I've fought for a number of years to preserve and expand.
[He is] one of a growing number of Americans going back to school to learn a trade. The classes they're taking often last no more than a few weeks or months and are highly specific - programs ideally structured to offer a speedy transition into a clearly defined field of work.
This is exactly the model of adult education, both as career change and as part-time career extension, that I feel is important to protect. It's one that fits a modern style of focused learning and life-long learning and matches well with the knowledge, skills, and abilities necessary to practice entry-level massage effectively. As we have mentioned on the CAMEL home page,
Ultimately, costs are to the consumer and to time students unnecessarily shift from family and community involvement. As a rule of thumb, a parent who can only spend two evenings a week taking class will require a year to complete 250 hours of training.
A good part of all of this push for me comes in making choices that continue to enable the practice of massage to be part of the search and practice of "Right Livelihood". Jack Kornfield gives a thorough discussion of right livelihood as it stems from the Buddhist Eight-Fold Path. Rick Fields and others in the 1984 book Chop Wood, Carry Water, A Guide to Finding Spiritual Fulfillment in Everyday Life, devoted a chapter to such work. Fields et al. include a quote from Michael Phillips, one of the founders of The Briarpatch, itself a source of numerous works on community and life.
Right livelihood is something you can spend your life doing; this means the livelihood should have within it the room for your constant curiosity; it must give you room to keep learning, to grow in compassion; and it should offer you challenges that will try you and yet appeal to you time and again. Most livelihoods actually have this potential, whether it is garbage collecting or systems programming, because the range of subtle and delicate refinements is always present. It should be something that serves the community; you should feel that you are completely serving the community in what you do or you will have a longing as you get older to do something else and may have regrets — but nearly every livelihood has enormous potential to serve people, and you will be serving people best when you are using your unique skills most fully. (Chop Wood, Carry Water; p. 111)
So there we have the draw of massage a trade and as a path of career and life transition and the tie back to the altruistic nature of massage as a profession.
Regulatory Definitions
The differences between terminology in a particular state and the definitions commonly used by those discussing occupational regulation has come up a number of times in discussions. While CLEAR is the ultimate source of the following, it was more readily available from America's Career InfoNet.
There are three main types of state occupational regulation. The Council on Licensure, Enforcement, and Regulation (CLEAR) has developed definitions for these different types of occupational regulation, registration, certification, and licensure. However, the different terms are often used interchangeably from state to state or from occupation to occupation. To promote standardization and clarity on the topic, CLEAR's definitions are as follows:
Licensure — The most restrictive form of professional and occupational regulation. Often referred to as right-to-practice or practice act. Under licensure laws, it is illegal for a person to practice a profession without first meeting State standards.
Certification — The State grants title (occupational right-to-title or a title act) protection to persons meeting predetermined standards. Those without certification may perform the duties of the occupation, but may not use the title.
Registration — The least restrictive form of occupational regulation, usually taking the form of requiring individuals to file their names, addresses, and qualifications with a government agency before practicing the occupation. This may include posting a bond or filing a fee.
Given the above as standard definitions, consider a state that "certifies" practitioners but that requires such certification in order to practice. The state, under the common usage above, is actually practicing licensing. States can set what titles they choose. Thus such a state could enforce that practitioners must call and advertise themselves as "Certified Massage Practitioners" rather than "Licensed Massage Practitioners". On the other hand, a board would be on questionable legal grounds if it tried to prevent such practitioners from generically noting that they were licensed by the state, since this involves a question of common usage of terminology rather than use of a state defined title. If such a question arises, it would be best to be clear on the differentiation between title and usage and to consult a lawyer.
In terms of the standard definitions above, there is no inherent difference in the qualifications between those certified by a state and those licensed by another state. In both cases the requirements are set by the specifics of the enabling law. The distinction arises only that those uncertified in a certifying state may still practice, as long as they avoid use of restricted titles. Those unlicensed in a licensing state are forbidden to practice under any title. British Columbia, for example, may require 3000 hours for use of the title "Registered Massage Therapist" but this is still a certification (title protection) act as recommentd by the Health Professions Council's Scope of Practice Review .
06 August 2004
The Cox and Foster Report on Occupational Regulation
Back in 1990, Carolyn Cox and Susan Foster wrote one of the most extensive and well-thought out reviews of the balance between the costs and benefits of occupational regulation that I have uncovered. It is referenced in a number of other reviews of occupational regulations, such as the 1999 report by the Minnesota Office of the Legislative Auditor. Unfortunately, the Cox and Foster report was published by the Bureau of Economics of the Federal Trade Commission in the era just before such reports started being made available on the World Wide Web. I'd obtained a paper copy a couple of years ago and made the executive summary (html) available. I finally went back and scanned and converted the entire report. So The Costs and Benefits of Occupational Regulation is now available as an Acrobat PDF file for your reference and enjoyment. May it serve as a reminder to keep the focus of such regulation, particularly (of course) in the arena of massage, on the benefit to the public. Such reminders have assumed greater importance as term limits in various states have acted to shorten the institutional memory and experience of legislatures.
01 August 2004
Technology Adjustments
I can't place my finger on the source, but in the not very distant past I read a commentary on technology and its use. One of the observations was that any sufficiently large increase in the power/speed of a technology causes fundamental changes in the way it is used. The past decades have brought immense changes in both computers and communication technology. It was once thought that the market for computers would be very limited. There was one off the wall comment at a conference in the late 1970s that the only way to sell many more would be to place them in doorknobs. Ironically, as computer technology became much smaller and faster, that's exactly what happened. Cell phones and text messaging have become ubiquitous.
One of the societal results of technological changes showed up in an article in today's Contra Costa Times (S.F. East Bay, registration required for access). The article outlined recent police experience with brothels moving from store fronts into temporary apartments, accessible to perspective customers by web page and cell phone. Before the location can be well-know, the participants move on to another location.
The implication is that the sex industry is rapidly adapting to pressure on storefront locations by giving them up and keeping technology as the only consistent presence. Technology has made it easier and likely less costly to fade into the background than to meet licensing laws and ordinances head on. The prevalent keywords may be flexible and mobile.
It may well become true that the only people adversely affected by local massage ordinances or badly written state laws are legitimate massage practitioners. Changes in technology may well make ordinances targeting fixed location brothels into a cliche of a simpler past. Legitimate massage practitioners, on the other hand, tend to seek stability and a location where clients can find them from month to month. If we are going to be the only ones visible to get forced to jump through the hoops, it's all the more reason to keep a close watch on proposed laws.
31 July 2004
Governor Schwarzenegger and the Elimination of Boards
The San Francisco Chronicle carries a story that California Governor Arnold Schwarenegger has the goal of eliminating about 120 state boards and commissions in his efforts to cut the state budget by $32 billion. As Bay Area practitioners Carl Brown and Robert Flammia have recently pointed out on several email lists, Schwarenegger's goal may well create a context with an even lower than normal likelihood for success for trying to create a new massage board. It certainly will make the process interesting. It's one more issue to watch very closely with any bill introduced in 2005 to insure that language changes don't drift massage beneath some other board. Better that such a bill should die a very swift and sure death.
Miscellany
I've been rather quiet lately, both taking a break while politics have been relatively quiet and focusing some energy on a complete redesign of the McKinnon Institute's web site. I've also started slowly working through scanning and optical character recognition on the entire Cox and Foster (1990) report on "The Costs and Benefits of Occupational Regulation". It's a Federal Trade Commission report done several years before they started placing such things online. I've had the executive summary available for a while.
09 July 2004
U.S. Senate Subcommittee Examines Human Trafficking
For those who might have thought otherwise, human trafficking is a far larger and more pervasive problem than the use of "massage" as a front. This past Wednesday (July 7), the Senate Subcommittee on the Constitution, Civil Rights and Property Rights held a hearing "Examining U.S. Efforts to Combat Human Trafficking and Slavery". A Voice of America report summarizes some of this. Another news article by Dave Montgomery (Knight-Ridder) terms U.S. slavery as a "growth industry".
The trafficking of human beings constitutes a "growth industry" in the United States, with more than 15,000 people forced into bondage each year as sex slaves or captive laborers, according to testimony before a Senate panel on Wednesday.
Prior efforts in documenting the extent of human trafficking have include a CIA report (PDF file) and a State Department fact Sheet. Jon Harrison of Michigan State University keeps a page of links to criminal justice resources on human trafficking . Given the scope of the problem and its transnational nature, it's pretty naive to believe that there is any hope of a "silver bullet". Combating trafficking is going take commitment of time and resources by levels of government from local to federal. Massage regulation doesn't address the underlying presence, only the outbreak of symptoms. As a profession, we have to push back against local agencies that, in drafting ordinances, take on the Vietnam war era attitude of "We had to destroy the village in order to save it".
05 July 2004
CAMBS Releases new Position Statement on State Licensing
Since AB 1388 was tabled in January, members of CAMBS (the California Alliance of Massage and Bodywork Schools) have continued to discuss massage licensing concepts, hoping to build on the basis laid by the drafting committee late last year. In keeping with AMTA-CA's request for concepts and language to help the legislative process along, and in the spirit of cooperation with the multifaceted touch therapy community in California, CAMBS now proposes a new version of AB 1388. This draft bill, along with a cover letter to AMTA-CA governmental relations chair Beverly May, is aimed at clarifying and providing a framework for CAMBS' goals. Since no actual bill introduction will be done by anybody until January 2005, this simply, at this time, creates a more defined framework for review and discussion. From my point of view, this framework is the plateau I discussed in a prior posting.
Long Beach Exempts Art Classes from Adult Entertainment Ordinance
It seems that massage profession businesses are not alone in being affected by overly broad definitions in ordinances designed to regulate adult entertainment. As reported in the Press Telegram, a Long Beach art center wanting to offer life drawing classes with nude models had to get an exemption to avoid having their classes classified as adult entertainment. Such a classification would have placed them in violation of zoning laws. As the Telegraph article notes:
For the law to place artistic drawing or painting of the nude human figure on par with a tawdry strip club is an insult, not just to contemporary Long Beach artists and the East Village Arts District, but to the distinguished history and study of art.
Many of us in the massage profession can empathize with the art center. Such ordinances often use far too broad a brush in what they paint black.
04 July 2004
MPS Entries for January through June 2004 Archived
My MPS entries for January through June 2004 have been moved into their own archive file. There's also a link to the old index page from the archive index page on the navigation bar to your left.
If you came here via a link or search to the old index entries, there may be a date hash of the form "#yymmdd" following the "index.html" at the end of the URL in your browser's address bar. When you get to the archived file, go to that date to see the entry you were seeking. You can even copy the "#yymmdd" hash here, and paste it on the new page, then hit the enter key to go there. Here's a JavaScript based link that does all of that for you.
It is through each of our individual efforts that together we work to keep or get our profession and practices independent of unneccesary and/or onerous regulation — a suitable independence day thought.
The price of freedom is eternal vigilance. — Thomas Jefferson
