Open letter to BC Ministry of Health

On January 23, 2024, the Ministry of Health released the amendment of TCMPA regulation to replace the current regulation “Traditional Chinese Medicine Practitioners and Acupuncturists Regulation proposed to replace B.C. REG. 290/2008)”. This newly proposed regulation involves extensive modifications to the current version seriously contradicting the original intent of legislative oversight to protect public health in traditional Chinese medicine. Moreover, it severely undermines the clarity of healthcare services provided by TCM professionals to the public and greatly diminishes the existing high-quality educational standards in TCM. As a result, it has sparked significant dissatisfaction among TCM professionals and societal groups. For examples, It involved replacing TCM-specific and medical terminology with more ambiguous expressions, such as “manual therapy” for “tuina” and “thermal stimulation” for “moxibustion.” This alteration diminishes the expression of TCM culture and its traditional roots, potentially harming public interests and health by obscuring the definition of TCM to the public. Moreover, this newly proposed version simplifies the definitions of TCM and acupuncture, leading to the near-complete removal of content from the “scope of practice” section. Additionally, all oversight regarding “Chinese herbal prescriptions” prescribing, compounding and dispensing TCM herbal medicines and formulas in the “Restricted activities” section has been eliminated, possibly enabling unqualified individuals to practice Chinese herbal medicines. This will also disrupt the thorough change in the professional education and training requirements for all levels of TCM practitioners since the legislation on traditional Chinese medicine in 1999, posing a significant potential risk to the BC residents!

It is worth mentioning that traditional Chinese medicine has been under provincial legislation and regulation to protect public interests for 25 years since 1999. The current TCM Regulation in BC dates back to 2008, established by the College of Traditional Chinese Medicine Practitioners & Acupuncturists of British Columbia (CTCMA) and approved by the Ministry of Health. During the ensuing 25 years, TCM in BC has been effectively regulated and becoming a benchmark for TCM healthcare nationwide. It has provided the public with economically effective TCM treatments including acupuncture, tuina, qigong, Chinese herbal medicines, and herbal dietary therapy, thus reducing healthcare costs for the provincial government.

Amidst these concerns, there is a consensus among TCM registrants regarding the importance of regulation. We understand that regulation is essential for ensuring the safety and efficacy of TCM and acupuncture practices. We recognize the ongoing efforts to amalgamate four colleges into a unified regulatory body as a positive step towards enhancing the professionalism and integrity of the profession. Consequently, we strongly advocate for well-structured regulatory frameworks to govern the practice of TCM and acupuncture. In order to protect the best interests of BC residents, we earnestly urge the provincial government to firmly retain the 2008 TCM regulatory framework, and under no circumstances cancel the restricted practice of “prescribing, formulating, and dispensing of Chinese herbal medicine”!

Prof./ PhD Rong-Gang Li (Founder of Home of Canadian TCM Society, Chairperson of Canadian Traditional Chinese Medicine Development Alliance)

Mr. Hua Niu (President of Canadian Community Service Association)

Mrs. Vivian Zhuang

Dr. John Lee ( Co- Chairperson of Canadian Traditional Chinese Medicine Development Alliance)

Feb.21,2024