AMERICAN
ASSOCIATION OF PRACTITIONERS AND RESEARCHERS OF AYURVEDA (AAPRA)
301-762-8262
mishra13505@yahoo.com
3 10 06
TITLE: PETITION FOR LICENSING
OF QUALIFIED AYURVEDIC PHYSICIANS IN
FROM: LAKSHMI C. MISHRA, M. PHARM, PH.D., B. I. M. S.
PRESIDENT AND AAPRA MEMBERS
Supported by:
1.Medical Professional Societies Supporting Regulation of AMI in
(1) Am Assoc. of Physicians of Indian Origin
(AAPI) (MDs and AMI
degree holders: >45000 members) V. Koli, MD, President, H.
Sharma, MD Chair of Integrative medicine committee AAPI
(2) Assoc. of Ayurvedic Professionals of
(3) Am. Assoc. of Practitioners, Researchers of Ayurveda
(4)
2.
Support from Citizens of
1.
Over 300 signatures of registered voters of MD
2.
Support letter from India House of Worship
3. Support letter from Asian
Americans for Community Service, Inc.
I. PURPOSE OF THE PETITION
The
purpose of the petition is to regulate Traditional Ayurvedic Medical System of
India through licensure of qualified ayurvedic physicians to practice Ayurvedic
Medicine of India (AMI) in order to protect citizens from unqualified Ayurvedic
practitioners and to provide quality ayurvedic health care. Minimum qualification required
for licensing AMI practitioners in
II. PARAMETERS
OF AMI PRACTICES TO BE REGULATED
The AMI practice to
be regulated will include diagnose, prevention , treatment and cure of
diseases using standard Ayurvedic disease management procedures, dietary
and life style interventions, therapeutic
use of herbs, minerals, herbo-mineral dietary
supplements, personal, family and environmental hygiene, spiritual practices,
yoga, yogic exercises, breathing exercise, meditation, and spiritual
counseling.
III. JUSTIFICATION FOR LICENSING QUALIFIED
AYURVEDIC PHYSICIANS (BAMS, BIMS, AMS AND EQUIVALENT FROM ACCREDITED
INSTITUTIONS)
Potential Public Health Hazard from
unqualified AMI practitioners in the US:
Currently there are over 20 educational
facilities in the US (Appendix 2) offering AMI training limited to a total of about 500 hours (less than 300 hours of
lectures) and covers primarily health maintenance and life style choices
(National Ayurvedic Medical Association web site). The admission criteria is only a High School Diploma. None of
the schools are accredited by regional accreditation boards such as WASC. A certificate, such as “Clinical Ayurvedic
Specialist” given by California College of Ayurveda, implies that a
student has mastered and can practice AMI. The fact is that in
order to be a clinical specialist of AMI to be able to diagnose, prevent, treat
and cure diseases, the minimum required course work in India is 2860 lecture
hours and 700 practicum hours (full time 4 ½ years) and one year of internship.
American citizens deserve to be treated by equally qualified physicians as the
citizens of
2. Status of AMI in the
3. India to teach AMI in the US: Thursday , Jan 12, 2006, IST PTI
NEW DELHI: In a
major step towards promoting Ayurvedic studies in the US and tapping its $40
billion herbal market, India has cleared the proposal to send experts to teach AMI in 10 American medical colleges.
"Prime Minister Manmohan Singh has extended his
full support for the proposal and we are in touch with officials of the AMI
Department in this regard,'' said Navin C Shah, a
senior medical representative of Indian doctors in the US. For details call Dr.
Navin Shah, 301 699 3192 ;
Dr. K.K. Dwivedi, Embassy of India, 202-939-9803.
4. Scope of AMI Training: The subjects included in the BAMS
training program are listed in Appendix 1.
The major subjects are: (1)
Sharir Rachana (Anatomy), (2) Sharir Kriya (Physiology), (3) Padarth Vigyan (Ayu. Physics), (4) Bhasajya Kalpana (Ayu. Pharmacy), (5)
Rasa Shastra
(Ayu. Drugs of Metals and Mineral origin), (6) Dravya Guna (Ayu. Pharmacology), (7) Kaya Chikitsa (Medicine,
Charak and Ashtanghradaya Samhitas), (8). Shalya Chikitsa (Minor surgery, Susruta
Samhita), (10) Shalakya Chikitsa, (Eye, Ear, Nose and Throat), (11)
Kaumarbhratya
(Pediatrics), (12) Prasuti Tantra (Obstetrics),
(13) Stri Roga (Gynecology), (14) Bhutavidya (Psychiatry), (15) Swasthyavrat (Hygiene, mediation, Yoga, life style changes,
dietary choices), (16) Agadtantra (Toxicology and Forensic Medicine) (17) Rasayan Tantra (Science
of Health and Longevity), (18) Vajeekarantantra (Ayu. Procreative
Activity and Rejuvenation). http://www.ccimindia.org/curriculum_ayurveda_1_7.htm The training covers
conventional medical subjects as an integral content of the AMI courses. Students are also familiarized with the conventional drugs and
interactions with Ayurvedic drugs. The program is designed to allow for smooth
cross referral between conventional and AMI practitioners.
5. No Conflict with Conventional Medicine: A license
will include only the right to use ayurvedic diagnostic methods,
diagnosis, prevention, treatment recommendations and treatment protocol; the
license would NOT allow the use of conventional medicine treatments.
6. Validity and Scientific
Basis of Ayurvedic Therapies: Indian government agencies and universities have studied AMI and
published findings in conventional medical journals included in the National
Library of Medicine and indexed in Index Medicus.
Additionally, the NIH, private foundations and ayurvedic herbal products
manufacturers have expended millions of dollars in funds to underpin the safety
and effectiveness of AMI therapies. Many
of these findings from the pharmacological, biochemical and clinical studies
have been summarized in (www.redwingbooks.com/products/books/SciBasAyuThe.cfm) Scientific
Basis of Ayurvedic Therapies, CRC Press
7.Popularity
of AMI: “Even in such major cities as
8.Ayurvedic Pharmacopoeia and Formulary of
9.Usefulness of AMI: Ayurvedic Text formulas and
single herbs are known to be useful in the management of chronic diseases,
psychiatric disorders, neurological disorders and maintenance of good health,
particularly when patients become resistant to conventional drugs or are unable
to utilize conventional drugs due to co-morbidities which put them at risk for
side effects from conventional treatment.
Volumes of effectiveness/ efficacy, and safety data have been published
both in
10. Education: Education in AMI at the college level,
equivalent to BAMS, will be more easily facilitated in states where it
is regulated.
11. Growth of AMI:
12. Supply of AMI Products: With regulation, Ayurvedic suppliers will be encouraged to open
outlets in
13. Third part payment: Although, Complimentary
Alternative Medicine health services are often not covered by third party
payers in the way conventional health services are. However, many
14. Health Care cost: AMI may bring down the health care cost by
providing an alternative therapeutic system.
1) AMI is known to produces desirable therapeutic effect without
causing adverse health effects, thus may save health care costs from the
treatment of side effects known to result from treatment with conventional
dugs. (Appendix 3)
(2) AMI is not known to cause delayed adverse health effects or co-morbid
conditions which sometimes develop years after the use of a conventional drug,
again saving the cost of treating the secondary disorders. (Appendix 3)
(3) Based on available data AMI formulas are proven useful dietary
supplements to improve health, strengthen the cardiovascular system, immune
system, improve memory, and relieve depression.
The formulas are also cited in Texts to reduce the frequency of
illnesses. Through the emphasis on prevention, health care cost may be
reduced.
(4) AMI therapies and Text formulas are herbal or herbo-mineral,
thus, can not be patented. The use of
the formulas should be less expensive.
It is apparent from the scope and extent of AMI that there is a great need
for the regulation of AMI in the US so that a minimum standard of education and
experience necessary to practice AMI can be enforced to protect the public and
establish it as a reliable and safe medicine in the US.
IV. AVAILABLITY OF QUALIFIED AMI PHYSICIANS
There are over 200 accredited AMI colleges
and over 367,528 registered qualified ayurvedic physicians in
In Maryland and
other states such as California, there are many persons with degrees in
Ayurvedic medicine, trained in India, who because of lack of regulation see
patients in their homes for moderate fees and have to refer patients to Indian
grocery stores or have their relatives ship the herbals to them from Indian
outlets which may or may not have followed the GMP standard. Additionally, there are those persons trained
in mail order courses or in short courses of 200-600 hours who wish to stay off
the radar screen of any regulatory body.
This is how AMI is being practiced in the
Additionally, there
will be those who will not practice, in spite of having the BAMS degree, due to
fear of malpractice issues as the medical discipline is not regulated and
therefore generally uninsurable. As
soon as BAMS and equivalent degrees in AMI are recognized, licenses are given,
the number of qualified degree holders will increase considerably similar to
Indian MDs.
V. IS THERE A PUBLIC OUTCRY FOR THIS MEDICAL SYSTEM?
Yes.
The public has complained about wrong diagnosis of disease, useless treatment
and overcharging for a long time from conventional medicine practitioners. Subsequently, patients can go to regulated
AOM practitioners but do not know where to turn for Ayurvedic treatment. Many
of the community members have been highly verbal in their desire for
regulation.
VI. WHY ARE THERE SO FEW COMPLAINTS REPORTED AGAINST PRACTITIONERS?
The public does not know where to file
complaints; with no system in place for regulation, patients merely go to another health care
practice for treatment if unhappy with the practitioner. Absence of complaints
in official files does not necessarily mean absence of health risk.
VII. HAVE OTHER STATES IN THE
No.
Although AMI has been practiced in
VII. ARE WIDELY ACCEPTED TESTNG
STANDARDS AVAILABLE?
Yes. Widely accepted testing standards are
available. Ayurvedic Pharmacopoeia of
VIII. DOES AYURVEDIC MEDICINE
MANUFACTURED BY LICENSED PHARMACEUTICAL COMPANIES CONTAIN UNSAFE LEVELS OF
LEAD?
Although the
permissible levels of heavy metals have not been formally set by US FDA, the
Government of India, Department of AYUSH has set following permissible limit of
heavy metals in Ayurvedic products with only herbal ingredients: lead, 10 ppm,
cadmium, 0.30 ppm, arsenic 10 ppm,
and mercury, 1 ppm.
It is important that qualified physicians knowledgeable about the
available safe drugs are licensed.
IX. INSURANCE COVERAGE:
Ayurvedic practitioners are advised to prepare a waver form and have patients sign it. They are also advised to search for city ordinances concerning the scope of practice limitations and the presence of a registered nurse while performing invasive procedures or refer patients to a qualified MD physician. After the AMI practice is regulated then practitioners will be required to carry insurance coverage. Without a license to practice it is very difficult to get insurance coverage. At this time Ayurvedic practitioners without an MD degree are legally not allowed to “diagnose, prevent, treat and cure” diseases and limit their practice to health maintenance by life style changes and Yoga exercises.
In more conventional clinics in
X. PROPOSED LICENSE CRDENTIALS
Persons with a BAMS or an
equivalent degree, one year of clinical experience and passing a National AMI
Board Examination will be considered qualified for a license to practice AMI
which includes diagnosis, prevention, treatment and cure of diseases using
ayurvedic methods and therapies. The
minimum Ayurvedic
Program course work required consists of 2860 lecture hours and
700 practicum hours, a total of 3,560 hours, as required for BAMS degree by
CCIM in
XI. FOLLOWING APPENDICES ARE AVIALBALE ON
REQUEST
1. CCIM curriculum for BAMS degree program in AMI
2.
AMI Educational facilities in the
3. Conventional drugs banned for serious adverse health effects
4.
Government of
5. Frequently asked questions about AMI
6. Brief history and principles of AMI
7. Sources of theoretical and scientific knowledge of AMI
8. Ayurvedic research
9.
AMI Education in the
10. AMI drug regulations
11. Manufacturing of AMI drugs
12. Regional Research Centers of AMI
13. Post Graduate Study Centers
14. Effectiveness of AMI confirmed by CCRAS clinical trials
15. List of AMI drugs with confirmed therapeutic activity