American Chiropractic Association


White House Commission on Complementary and Alternative Medicine Policy


February 5, 2002

Stephen C. Groft, Pharm.D.
Executive Director
White House Commission on
Complementary and Alternative Medicine Policy
6707 Democracy Boulevard
Rockville, MD 20892

Dear Mr. Groft:

On behalf of the American Chiropractic Association, I respectfully request the following comments to be distributed to the members of the White House Commission on Complementary and Alternative Medicine Policy (WHCCAMP) and addressed at your meeting this month. Our comments focus on a doctor of chiropractic's ability to serve as a primary care provider and also to provide nutritional advice to their patients.

The ACA is extremely concerned with the commission's discussions on the ability of a doctor of chiropractic to serve as a primary care provider under the National Health Service Corps. The ACA knows that doctors of chiropractic can and do play an integral role in the delivery of quality health care to rural and underserved areas. It is a well-known fact that one of the greatest challenges facing health care is the serious lack of primary health care providers living in rural areas. In many rural areas, doctors of chiropractic for years have served their communities as primary health care providers, providing a host of other services to their rural patients. In fact, a study of doctors of chiropractic in South Dakota found that, in addition to spinal manipulation, a majority of rural chiropractors offer a variety of other services, including physiotherapy, nutritional counseling, diagnostic x-ray, soft tissue therapy, acupuncture, massage, urinalysis and blood analysis.¹

Primary Care Providers
The ACA believes that the role of doctors of chiropractic in primary health care is characterized by direct access, integrated conservative ambulatory care of patients' health care needs, emphasizing neuromusculoskeletal conditions, health promotion, and patient-centered diagnosis and management. This coincides with the educational requirements designated in the Standards for Chiropractic Institutions of the Council on Chiropractic Education, the federally recognized accrediting agency for chiropractic colleges. These standards specifically state that the purpose of chiropractic education is to train the doctor of chiropractic to be a primary care provider. A doctor of chiropractic in the primary health care system is a first-contact gatekeeper for neuromusculoskeletal conditions.

As primary care providers, doctors of chiropractic emphasize collaboration with patients in the development of a life-long path to health promotion and disease prevention. Incorporating knowledge, skills and attitudes acquired through professional training, doctors of chiropractic work with patients in a number of domains including: evaluation/assessment of patients (risk factors, health needs), information/education of patients (awareness), intervention/monitoring (including counseling) and integration with other community medical and health-related resources.

Doctors of chiropractic serve as a resource to the community for health care, health promotion, and wellness. As a direct-access provider, he/she serves as a conduit to other health care practitioners, services, and information resources. Patients are encouraged to engage in preventative care within the chiropractic model. The various levels of injury prevention include:

  • Primary Prevention - prevents a disease or condition from occurring;
  • Secondary Prevention - detects early signs of a condition or injury and intervenes;
  • Tertiary Prevention - reduces sequellae and is supportive or rehabilitative in nature.
As a conduit in preventative care and wellness, doctors of chiropractic play a primary care role in ensuring the health and wellness of the patients they treat.

Nutritional Advice
The ACA is also concerned with the commission's discussions regarding a doctor of chiropractic's qualifications to provide nutritional advice to his/her patients. As part of their education, doctors of chiropractic are provided training in nutrition and utilize this knowledge in providing nutritional advice to achieve the overall wellness of their patients. Most state practice acts recognizes the ability of doctors of chiropractic to provide nutritional advice to their patients. For example, Commissioner Dr. Veronica Gutierrez' home state of Washington's chiropractic state scope of practice specifically recognizes chiropractic treatment to include "…dietary advice and recommendation of nutritional supplementation except for medicines of herbal, animal or botanical origin."

Conclusion
Doctors of chiropractic, through their training and education, stand ready to serve rural and underserved communities as primary care providers. The ACA urges the White House Commission on Complementary and Alternative Medicine Policy to encourage the use of doctors of chiropractic as primary care providers under the National Health Service Corps. In addition, doctors of chiropractic are trained and educated to provide nutritional advice to their patients. The ACA opposes any attempt by the commission to limit in any way the scope of practice of a doctor of chiropractic in rendering nutritional advice to their patients.

We appreciate the opportunity to express our views. If you have any questions regarding our comments, or require additional information, please contact Ingrida Lusis, ACA Director of Government Relations, at 703/276-8800.

Sincerely,

Daryl D. Wills, DC
President
American Chiropractic Association


¹Barnett K, McLachlan C, Hulbert J & Kassack K. Working Together in Rural South Dakota: Integrating Medical and Chiropractic Primary Care. Journal of Manipulative and Physiological Therapeutics, November/December 1997; 20:9:577-582

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