Recommendationon Chinese Medicine in the
United States of America
(Primary)
TO: White House Commission on Complementary and
AlternativeMedicine Policy
FROM:Bob Xu
RE:Recommendation
DATE:December 4, 2001
Dear Sir or Madam:
As a doctor of Chinese Medicine practicing in the United States, I have met some issues relating to patients’ care and the profession of Chinese Medicine.I have discussed these issues with representatives at the American Association of Oriental Medicine (AAOM).They have generally agreed with me on these issues, and felt that these issues are important to address in order for the American public to receive the reliable, safe, and effective system of Chinese Medicine.They suggested I send my recommendation to the White House Commission on Complementary and Alternative Medicine Policy.
Because English is my second language, and I am writing this recommendation in a short time, I am presented with many challenges.Yet I hope to call to your attention to issues that will benefit both the American public and the profession of Chinese Medicine.
Thank you.
Sincerely,
Bob Xu, CMD, MS
Director
Center for Holistic and Herbal Therapy
Recommendation on Chinese Medicine
in the United States of America
1.Inappropriate Status of Chinese Herbal Medicine
Traditional Chinese Medicine (TCM), or Chinese Medicine, is composed of two parts: Acupuncture and Chinese Herbal Medicine. Acupuncture first drew the American public's attention, partly attributed to the media, during President Nixon's historic visit to China in the early 70s. Chinese Herbal Medicine arrived in US later than Acupuncture, and is not as well known as Acupuncture.
The less well-known status of Chinese Herbal Medicine does not mean that it is less important. On the contrary, it is the most important component of TCM.In all TCM hospitals in China, there is only one Acupuncture Department, but there are normally between ten and twenty Departments of Chinese Herbal Medicine. In China, students at TCM medical schools are trained in both Acupuncture and Chinese Herbal Medicine.After graduation, they will focus in their practice on either Acupuncture or Chinese Herbal Medicine (although some of them focus on both).For thousand years, more TCM doctors have focused on Chinese Herbal Medicine than on Acupuncture.Above facts show that Chinese Herbal Medicine is more than a dozen times larger than Acupuncture, and is the major component of TCM.
Despite this fact, in the United States many agencies and insurance companies regard Chinese Herbal Medicine as a sub-category of Acupuncture, and include Chinese Herbal Medicine into Acupuncture.This relationship between Acupuncture and Chinese Herbal Medicine is inappropriate, and will block the development of TCM in the United States.TCM cannot be fully developed in the US, and the American public will not enjoy the full benefit of TCM if Chinese Herbal Medicine is bound to Acupuncture.The American public will get more benefits once Chinese Herbal Medicine has obtained the status and recognition it deserves.
2.Scientific Basis of TCM
For thousands of years, TCM has been proven clinically safe and effective when applied appropriately.However, because TCM diagnoses and treats diseases in a way different from Western medicine, many people question its scientific basis.
I had a chance to study physics before entering TCM medical school.The interdisciplinary background provides me with an opportunity to view TCM from a physics viewpoint.To my surprise, many TCM principles, methods, processes, and mechanisms have their basis in physics.TCM relates to theoretical mechanics, aeromechanics, fluid mechanics, thermodynamics, statistical physics, control theory, system theory, information theory, etc.For example, the mechanisms of many diseases in pulmonary system relate to aeromechanics, and the mechanisms of many cardiovascular diseases relate to fluid mechanics.
According to TCM, a healthy state is ayin-yangbalanced state, and a diseased state is ayin-yangimbalanced state.From the physics viewpoint, the human body is a complex system in dynamic equilibriums. There are constant flows of matter, energy, and information which are in dynamic equilibriums inside the body. Therefore, the balance is not a static balance, but a dynamic equilibrium.Any deviation from these equilibriums, no matter if it is due to internal factors or external factors, will lead to a diseased state. The goal of TCM’s treatment is to reestablish the dynamic equilibriums with the appropriate application of Chinese herbs and other modalities of Oriental Medicine.
Although more studies are needed to clarify these relationships, it is reasonable to say that TCM is compatible with physics, and it is scientific.The relationship between physics and TCM is not a coincidence.Because the human body is also a physical system, all physiological and pathological processes should obey physical laws.
3.Controversy on TCM
As a scientific field, TCM should have a high degree of reproducibility and consistency.Unfortunately, TCM enjoys a varied reputation in the United States at this time.Some patients say that TCM is excellent and superior to Western medicine.They believe TCM is natural, safe, and effective.Others say it is ineffective, or even has adverse side effects.
The controversy arises mainly from the fact that the Chinese Herbal Medicine is not regulated in the United States.
Currently, there is no mechanism to ensure a consistently high quality of TCM practitioners.The lack of TCM regulations has, in some cases, allowed unqualified people to practice TCM.As a result, people with limited knowledge about TCM can practice Chinese Medicine.Some of them have only several months to two years of TCM study, and have not received a recognized TCM degree.They lack systematic study and rigorous training in TCM, and are therefore unable to provide patients with safe and effective TCM treatments, thus giving TCM this undeserved mixed reputation.
When patients have complained that Chinese Medicine did not work, it was not that Chinese Medicine did not work, it was because the practitioner was not qualified to practice Chinese Medicine.Low standards and quality not only harm the public, but also seriously damage the reputation of TCM.
I had the opportunity to witness several Nationally Outstanding TCM Doctors honored by the State Department and the Ministry of Health, P. R. China (I studied under these master TCM doctors).If these TCM master doctors were allowed to practice in America, most Americans would believe that Chinese Medicine is wonderful and excellent.They practice the same TCM, but reach different results from those unqualified practitioners.It is because these master doctors are qualified to provide the public with the best and most consistent high quality of Chinese Medicine.
The government’s decision of not regulating TCM probably has sent a wrong message to the public.Because the FDA classifies the herb into food category, many people think it is safe to take Chinese herbs by their own decisions.This has lead to many inappropriate takings of Chinese herbs by the public.In the end, many people say that Chinese herbs are ineffective or have side effects.
Actually, the public is not supposed to take Chinese herbs by their own choices.Even in China where everyone know TCM, the public still seek TCM doctors’ prescription for Chinese herbs rather than take herbs by their own decision.Recently, the public’s inappropriate uses of Chinese herbs have increased the number of ineffectiveness or side effects of Chinese Herbal Medicine in US and other countries.
Because TCM is new to many countries, many governments do not have adequate information or preparation on how to regulate it.Thus, they decide not to regulate it based on partial information.The decision of not regulating TCM is a misunderstanding about Chinese Herbal Medicine.In fact, this decision has played an important role in increasing reports of side effects on TCM.We will discuss the herbal side effects later in details.
4.Regulation of the TCM Profession
To ensure high quality of TCM and to protect the public interests, the TCM profession needs to be regulated in a similar manner to the one that Western medical doctors are.The purpose of TCM professional regulation is to:
Ensure that all TCM practitioners have adequate education, training, and experience in order to practice TCM safely and effectively;
Preventunqualified practitioners from harming the public and damaging theprofessionof Chinese Medicine.
In China, there are two types of medical schools:Western medical schools and TCM medical schools.TCM medical schools are independent of, and parallel to, Western medical schools.It takes 5 years to obtain a Doctor of Chinese Medicine (CMD) degree for practicing TCM.The length and workload of the curriculum at TCM medical schools is the same as those at Western medical schools.It is impossible to become a Doctor of Chinese Medicine in less time.Even after obtaining the CMD degree, there is still a long way to go to become a good TCM doctor.
In the United States, the criteria for a practitioner to be a qualified TCM doctor should be 4 to 5 years study and training at an accredited TCM Medical School, either in China or the US.Anyone without adequate TCM Medical School study and training should not be allowed to practice Chinese Medicine.
Currently in many states in the United States, an MD, DO, DC, ND, or other healthcare practitioner is automatically allowed to practice Chinese Medicine (e.g. Acupuncture and/or Chinese Herbal Medicine) no matter how little education or training he or she has in TCM.This is another area that lowers the standards of Chinese Medicine and do harm to the public.If an MD, DO, DC, ND, or other healthcare practitioner has received adequate training (has met above criteria of 4 to 5 years formal study and training at a TCM Medical School), he or she is qualified to practice Chinese Medicine.However, if the MD, DO, DC, ND, or other healthcare practitioner has not met above criteria, he or she is unqualified to practice Chinese Medicine.
In China, generally speaking, a graduate from Western medical schools is an MD who is qualified to practice Western medicine only, and the MD is not allowed to practice Chinese Medicine.A graduate from TCM medical schools is a Doctor of Chinese Medicine (CMD) who is qualified to practice TCM only, and the CMD is not allowed to practice Western medicine.This is because the trainings at Western medical schools and TCM medical schools are completely different.Both types of medical schools take 5 years of study and training.It is impossible for an MD graduated from a Western medical school to have adequate education, training, and knowledge in Chinese Medicine, and vice versa.
Therefore, to ensure the high quality of Chinese Medicine and to protect the public interests in the United States, an MD, DO, DC, ND, or other healthcare practitioner should not automatically be qualified to practice Chinese Medicine unless he or she has met the criteria to practice TCM.
5.Insurance coverage
In my practice, many patients say that they like Chinese Herbal Medicine because it is natural, safe, and effective.What concerns them the most is the insurance coverage.“Does the insurance cover Chinese Herbal Medicine?” became one of the most frequently asked questions.
Currently in the United States, some insurance companies have begun to cover the Acupuncture treatment.However, no insurance company covers Chinese Herbal Medicine as an independent treatment program.In a few cases, some insurance companies cover Chinese Herbal Medicine under Acupuncture only.As a result, patients generally must pay out-of-pocket for treatment of diseases, prevention of illnesses, and promotion of health services when Chinese Herbal Medicine is used.Thus, access to Chinese Herbal Medicine and practices appears to be limited largely by the ability to pay.
As mentioned above, Chinese Herbal Medicine is parallel to, is independent of, and is approximately ten to twenty times larger than Acupuncture.Chinese Herbal Medicine is the main component of TCM.Including Chinese Herbal Medicine as a subset of Acupuncture is inappropriate.It will not meet the great public demand for Chinese Herbal Medicine, and is not in the best interest of American people.Many Americans cannot benefit from TCM largely because the insurance does not cover Chinese Herbal Medicine.
To meet the great demand for Chinese Herbal Medicine in the United States, independent insurance coverage for Chinese Herbal Medicine is needed.
6.Disease Prevention vs Disease Treatment
Currently, many people take single herb extract in a way similar to taking dietary supplement for disease prevention.Thus, some people have an impression that Chinese Herbal Medicine, similar to single herb extract, is for disease prevention mainly.They perceive TCM as a supporting health maintenance system (for disease prevention) rather than a medicinal system (for disease treatment).
This is a misunderstanding about TCM.The application of a single herb (or its extract) is very different from the practice of Chinese Herbal Medicine.In TCM, there are monarch, minister, assistant, and guide requirements in applying Chinese Herbal Medicine.Therefore, it is very rare for a TCM doctor to apply a single herb to treat diseases.Most of the time, a TCM doctor will apply a combination of herbs to form a formula, which can not only prevent diseases, but also treat illnesses.
The function of a herbal formula is very different from the function of a single herb.In TCM, treating a disease is similar to fighting a war.A single herb is like a soldier, and a formula is like a troop.A soldier alone can rarely win a war, but a well-organized troop usually can.In TCM, it is through the cooperation between different component herbs that a formula effectively treats and cures diseases.
Therefore, there is a clear distinction between the application of single herb and the application of Chinese Herbal Medicine.The former may fall into the scope of nutrition dietary supplement, which is mainly for disease prevention.The latter falls into the scope of medicine, which is not only for disease prevention, but also for disease treatment.
In sum, TCM is neither a nutritional program nor a dietary supplement system.Nor is it for prevention only.TCM is a comprehensive, effective, and rigorous medicinal system.It is effective not only for diseases prevention, but also for illnesses treatment.Disease prevention is only a small portion of TCM practice.
Western herbal medicine in the United States does not have the legacy or the diagnostic and therapeutic processes honed to provide the skill levels that are seen in Chinese Herbal Medicine.While the constituent based treatment process can be useful in simple and some acute disease patterns and follows the pharmaceutical model, it does not meet the quality of care provided by the Chinese Herbal Medicine.
For thousands of years, TCM has successfully treated and cured numerous diseases, and saved millions or billions of peoples’ lives.TCM is a great treasure belonging not only to the Chinese people, but also to the whole mankind.TCM can, should, and will benefit all human beings in disease prevention as well as disease treatment.
7.Scope of TCM
TCM does not classify diseases the way Western medicine does.TCM approaches diseases in a holistic way.It stresses the relationship between different organs and systems.For example, in TCM, an illness related to vision may be caused by some internal organ’s problem.The treatment might be approached from internal medicine rather than from ophthalmology.Also, a heart problem might be caused by other TCM organ systems.The treatment might cover not only cardiology, but also other systems.Examples like this are numerous.
Therefore, it is common that a TCM doctor’s practice covers a wider area of diseases.Insurance companies should understand this difference between TCM and Western Medicine, and not impose Western Medicine specialties on TCM doctors.
8.Regulation on Certain Chinese Herbs
Most Chinese herbs are very safe, fall into FDA’s food category, and need not be regulated.
However, there have been reports of adverse side effects when certain Chinese herbs have been applied.As a result, a few herbs are regarded as “dangerous” and are restricted by the FDA.
Actually, there are significant differences between the adverse side effects of chemical drugs and the adverse side effects of Chinese herbs.The adverse side effects of a chemical drug exist no matter whether the drug is applied appropriately or not.In other words, the adverse side effects of the chemical drug areunconditional: they exist no matter if the chemical drug is applied appropriately or not.On the contrary, most adverse side effects of Chinese Herbal Medicine arise from the inappropriate application of herbs.In other words, the adverse side effects of Chinese herbs areconditional:they generally exist only when applied inappropriately.
The inappropriate applications of Chinese Herbal Medicine include:
(1) Wrong diagnosis;
(2)Inappropriate selection of herbs;
(3) Inappropriate combination of herbs;
(4)Inappropriate processing of herbs;
(5) Inappropriate methods of taking herbs;
(6) Inappropriately high dosage;