Department of Veterans Affairs
Transcription
Department of Veterans Affairs
Attachment D: Department of Veterans Affairs Chiropractic Advisory Committee Summary of Public Comments The Department of Veterans Affairs (VA) Chiropractic Advisory Committee accepted public comments to assist in identifying issues and concerns regarding the development and implementation of a chiropractic health program within Veterans Health Administration (VHA). While some comments were received early in Committee deliberations, the majority were received after draft recommendations were provided for public review and comment. The recommendations were posted on the Committee’s Intranet site (www.va.gov/primary) on July 24, 2003 and were announced August 4, 2003 in the Federal Register notice of the Committee’s September meeting. The comments were provided to the Committee. This report summarizes the comments as they relate to each recommendation and identifies the persons/organizations who have provided comment at any time during the Committee’s work. Summary of Comments Recommendation Introduction Background Comments (footnote refers to list of persons/organizations providing comments) Objects to statement on page 1, lines 41-44 as reflecting parochial interests. 303, 486 Follow-up by Committee Comments noted. No change made. Commends committee for including statement on lines 41- 44. Goal is to give veterans another alternative for healthcare, not to remove existing provider options. 472 Comments noted. No change made. Page 2, lines 39-45 – believes all new clinical services offered by VA should work within the confines of the existing primary care model. 472 Comments noted. See Recommendation 9, access to care. Page 3, lines 18-25 – include a reference to the need for the swift and timely implementation of the chiropractic program 486 Comments noted. No change made. Page 3, line 19 - Change phrasing of “appropriate access“ to Word “appropriate” removed. Phrase now reads “Patients “direct access”. Key to development of an effective policy on chiropractic care is the guarantee of direct access. Patients have difficulty accessing chiropractic care when a referral from a medical doctor or nurse is required.23 have access to chiropractic care.” Page 3, line 19 – use of the term appropriate should in no way serve to justify any effort to obstruct, delay or in any way impede the full integration of chiropractic services. Change to “direct access” 486 See above. Page 3, line 19 - Change phrasing to full access to reflect Dr. Roswell’s comments that he felt direct access should be available after the initial referral for all subsequent follow-up visits. 303 See above. Page 3, line 25 - remove phrase “in an appropriate manner” as it serves no useful purpose. 303 Phrase “in an appropriate manner” removed. A. Qualifications Restrict qualifications to the basic criteria of state licensure with a minimum number of years in practice. 11 VA qualification standards require delineation of education. See VHA Handbook 1109.19, paragraph 5.e. 1. Education requirement Dept. of Education should expunge CCE as the official accrediting agency for chiropractic colleges. 1 Not within charge of Committee. Recommend limiting the Secretary’s approval to schools recognized by the CCE. 21 Comments noted. No change made. Require graduation from a CCE accredited schools with those who graduated from schools subsequently accredited by CCE considered on an individual basis. 5 Comments noted. No change made. Require graduation from a CCE accredited school or its equivalent or have such status granted by grandfathering privilege as recognized by the accrediting agency. Graduates of non-US programs should demonstrate equivalent accreditation. Comments noted. No change made. Concern that requirement for graduation from a CCE accredited school excludes those graduating prior to formation of CCE, when school had interim period before full accreditations or Comments noted. No change made. 6 2 those graduating in future from a school accredited by some other accrediting agency. 7 Support recommendation for the broader educational standard. Comments noted. No change made. Objects to Comment on page 4, line 40-44 and requests its removal. 23, 303 Comment rephrased to more accurately reflect the concern expressed by some members of the Committee. Recommends deletion of discussion of accrediting agencies as irrelevant and urges committee recommend only degree from an institution accepted for licensure. 486 Comments noted. No change made. Language of HR 2414 (HR 2357) states the educational qualifications of chiropractors and models them on those used for other professions in Title 38. Supports enactment of amendments to Tile 38; Committee should employ the language of the legislation (HR 2357) as the basis for the recommendation 23, 303, 486 Phrasing in HR 2357 states “college of chiropractic approved by the Secretary”. Recommendation as written by Committee provides criteria to the Secretary on what should constitute an approved college of chiropractic. 18, 19, 28*, 38, 78, 127, 164, 268, 462 2. Licensure requirement Current licensure in at least one US jurisdiction; verify licensure information with the Chiropractic Information Network/Board Action Databank (CIN-BAD); verify malpractice history by confirmation of status with insurance carrier and NPDB. 6 Change term “licensure requirement” to “credentialing requirements”. Urge the credentialing process be defined in greater detail. Add “as verified with the Chiropractic Information Network/Board Action databank (CINBAD) maintained by the FCLB. Add “Further, any history of malpractice claims should be disclosed by the applicant.” 25 3. Other requirements B.4. Scope of practice Credentialing requirements are spelled out in VHA Handbook 1100.19, March 6, 2001 (available at http:// www.va.gov/publ/direc/health). Licensure is one part of credentialing. Disclosure of malpractice and other adverse actions is required. Comments will be referred to Office of Quality and Performance for consideration. PL. 107-135 requires chiropractic care for neuromusculoskeletal conditions including the subluxation complex. 5 Comments noted, No change made. Chiropractors must be allowed to use vertebral subluxation as a primary diagnosis when appropriate. 7 Comments noted. No change made. 3 Believe Congress acted to provide services not already being offered by current DVA providers - the detection and correction of subluxation; DVA should center its efforts on the development of protocols that most effectively allow the doctor of chiropractic to perform this unique function as part of the greater health are team. 11 Comments noted. No change made. Scope of practice should focus on the diagnosis (evaluation) of the chiropractic vertebral subluxation and the specific chiropractic adjustment which only chiropractors are equated and qualified to do; crossover or duplication of services such as chiropractors engaging in full body (differential) diagnosis or physical therapists attempting to manipulate the spine to correct vertebral subluxations is inappropriate. 13 Comments noted. No change made. The recognition of the detection and correction or vertebral subluxation as an integral part of the chiropractic purpose is of utmost importance. The inclusion of subluxation correction underscores the unique contribution of chiropractic and ensures that DCs do not duplicate medical services already provided in VA system.19 Comments noted. No change made. Of utmost importance that the reference to subluxation correction be a part of any official VA policy; underscores unique contribution of chiropractic and ensures DCs do not duplicate services already provided in VA. 28 *, 78, 127, 164, 268, 462 Comments noted. No change made. Objects to phrasing of Recommendation 4, page 5, lines 39-40 as representing bias and prejudice of certain healthcare physicians on this advisory committee. 23 See VHA Handbook 1100.19, paragraphs 4.c., and 6. JCAHO requirement.- standard HR.3. Individual competency is required for all professions. Objects to phrasing of Recommendation 4, page 5, lines 39-40 – no similar limitations or statements of concern regarding the core competencies of osteopaths, physical therapists, neurosurgeons or other healthcare providers within the DVA system. 303 See above. Concerned about the phrase “provide a variety of chiropractic care and services for neuromusculoskeletal conditions”. Recommend the chiropractic scope of practice be limited to This phrase is in PL. 107-135, Section 204 (d). 4 back pain and other conditions where medical practice guidelines recommend spinal manipulation as effective treatment. 21 Support the recommendation on scope of practice. C. Services to be Provided (Privileges) 25 Comments noted. No change made. While chiropractors often deliver some services that might also be delivered by physical therapists, the services delivered by chiropractors should not be considered physical therapy. Physical therapy is a separate, unique and distinct clinical service from chiropractic. The integrity of each clinical service should be maintained. Physical therapists and chiropractors overlap scopes of practice but were not educated the same way, do not make clinical judgments the same way, and do not examine a patient from the same perspective. 472 Comments noted. No change made. Page 6, lines 17-26 – objects to highly questionable views on the term “subluxation”; debate on these issues reflects ICA’s concerns about the potential for ignorance and/or bias holding program back. Subluxation care is specifically mentioned in the statute as a unique area of chiropractic responsibility and authority and has been a long-standing element in federal health programs. 486 Allow full range of services doctors of chiropractic are licensed to provide by state law; DVA policies and procedures should recognize the full scope of the DC license with appropriate ordering, referral and other privileges typically accorded physicians. 10 Removed phrase “or complete”. Otherwise unchanged. Chiropractors are deemed diagnosticians in every state and trained to identify serious healthcare issues that would cause them to refer patient to a primacy care provider.15 Comments noted. No change made. State boards are allowing an infiltration of services such as physical therapy by basically untrained individual chiropractors. Comments noted. No change made. Focus of chiropractic examination should be evaluation of human spine, checking for the Chiropractic Vertebral Subluxation complex; chiropractic spinal adjustment if non- Comments noted. No change made. Comments noted. No change made. 24 5. Minimum Initial Privileges 5 duplicative and not the same as osteopathic manipulation, physical therapy mobilization/manipulation, naprapathic moves or therapeutic massage. 3 6. Other Initial Privileges Recommendation 5 is not consistent with Recommendation 19 #5 refers to management of care; # 19 refers to comanagement. Recommend the wording in Recommendation 5 be changed to co-management of care. 27 Committee did not perceive the phrasing of these 2 recommendations to be in conflict. No change made. Add SMEG and thermography to list of privileges; constitute appropriate chiropractic procedures. 19, 28*, 38, 78, 127, 164, 268 Comments noted. No change made. Include SMEG and thermography; instrumentation is and has been in the core curriculum of chiropractic colleges for many years and is used as a procedure to help in the analysis of the vertebral subluxation. 20 Comments noted. No change made. Allow use of paraspinal thermal measurements. 24 Comments noted. No change made. Do not agree that SMEG and thermography should be added to list of privileges. 462 Comments noted. No change made. Restrict practice to locating, analyzing and adjustment of vertebral subluxation (misaligned vertebrae that cause nerve interference). 1 Comments noted. No change made. The primary care physician is the appropriate medical point of contact for patients. Recommends the results of laboratory tests ordered by chiropractors be routinely shared with primary care physicians to ensure quality and appropriate follow-up. 21 VHA Directive 2003-043, Ordering and Reporting Patient Test Results directs that abnormal results be directed to the ordering provider. First ‘Comment’ removed in entirety. Need to clarify who will read and/or evaluate the results of tests. See above. Regarding surface electromyography and thermography, Committee appears to have relied on an obsolete Job Analysis conducted by the National Board of Chiropractic Examiners. 2003 Study “How Chiropractors Think and Practice” reported 86.9% of the chiropractors surveyed considered SEMG appropriate for DCs scope of practice and 88.6% indicated thermography appropriate. CCP CPG #1 rated both as Remove reference to NBCE Job Analysis. 27 6 “established procedures”. Should include SEMG and thermography on the list of minimal initial privileges. 18 7. Additional Privileges 8. Publication of Information Letter D. 9. Access to Chiropractic Care DCs are portal of entry providers. 3, 488 Support full integration of chiropractic services as primary contact providers within DVA system; insure access to chiropractic care; chiropractors at the TX Back Institute are integrated as full service musculoskeletal providers with direct access by patients. 4 After extensive discussion by the Committee, the recommendation and the dissenting recommendation were rewritten, the rationale statements rewritten, realigned, or removed, and a new comment by the 2 dissenting members added. Ensure unimpeded access to chiropractic care; Committee should develop protocols for direct access to chiropractic care; should explore advantages of utilizing doctors of chiropractic as Primary Care Managers and evaluate this concept at various DVA facilities. 10 See above. Direct access; no mandatory referral requirement; chiropractic care available at the request of the patient as a clearly identified care option. 11 See above. Open access is essential for the success of the program; most allopathic physicians not trained to recognize need for chiropractic services. 12 See above. Portal of entry providers without need for referral. 13 See above. VA health care cost will be greater if VA develops access through a primary care provider (PCP). WA State has statistics regarding lack of referrals to non-physician healthcare practitioners when a PCP is managing care. Nationally, when patients have the right to choose their healthcare practitioner, use of alternative medicine is 30-50%. In WA when MDs controlled access to alternative medicine, the use rate was less than 3%. WA State law demands access to coverage for every licensed health care practitioner in the state. 15 See above. 7 Comment from disabled veteran, also DC who utilizes VA healthcare: must see primary care physician to get referral; can take 3 weeks or more. Recommend patient be allowed direct access.16 See above. Direct access should be available to eligible veterans who request it and patients should participate in making health care decisions. Desirable for DCs to be integrated into the VA system and function as members of the healthcare team. Significant issue is whether a primary care physician (or other provider) has the education, training, and clinical skills to determine the safety and appropriateness of chiropractic care. Medical schools/residency programs do not provide training in chiropractic analysis. 1998 study in J Bone and Joint Surg concluded current medical school training in musculoskeletal medicine is inadequate. Primary care providers, with few exceptions, lack the education, training and experience to determine indications and contraindications to chiropractic care and a generally not familiar with the variety of chiropractic adjusting procedures. Eligible veteran requesting chiropractic care would be seen by DC who would report finding, recommendations, and chiropractic care plan to the primary care provider.18 See above. Oppose the use of medical gatekeepers to control access to chiropractic services. American public has freedom to choose chiropractors without referral by MDs; veterans deserve the same right. Access would be determined by the personal prejudices of medical provider. Requiring medical referral is inappropriate since MDs receive no training in detection or correction of vertebral subluxation; impracticable to give MDs responsibility of determining appropriateness of chiropractic care when have no training or experience in analyzing the subluxation complex. 19, 28*, 78, 79, 82, 127, 153, 164, 268, 462 See above. Requiring a medical referral before visiting a chiropractor’s office is legally questionable. Chiropractors are by law a primary health care provider and no referral is necessary. Taking away a basis freedom from vets is very un-American. 128 See above. 8 After speaking with my patients that are veterans they are encouraging direct access in the VA system. With the Iraq crisis currently underway they have a difficult time accessing care. Therefore, they believe that direct access would be the most beneficial for them. Many times they have to return for referral appointments which costs them money and time. 146 See above. Veterans should have direct access without going to primary care provider; delays in getting appointments with primary care, Chiropractic has been historically and legally declared “separate and distinct” from practice of medicine. Duplication of services would be redundant as VA has on staff physiotherapists trained in those services. 20 See above. Against use of medical gatekeepers. 192, 489 See above. MD's have no training whatsoever in Chiropractic and are therefore not qualified to determine if a patient is a Chiropractic candidate. People should realize that 82% of practicing medical doctors failed a basic proficiency exam in treating musculoskeletal conditions. You cannot treat mechanical problems with chemicals.151 See above. Committee should review the topic of access to care as published by the WH Commission on CAM Policy and reconsider using medical doctors as gatekeepers. Use of medial gatekeepers is a gross injustice and discriminatory hurdle to services.38 See above. WHCCAM did not make recommendation regarding direct access. Concurs with dissenting recommendation on page 10. 23 See above. Supports the dissenting recommendation. Delaying access to necessary care while waiting for referrals from an admittedly overloaded intake system may constitute patient neglect. 25 See above. Agree with dissenting recommendation and note the repeated concerns about systemic backlogs in timely availability of primary care providers and concerns about the detrimental effect of inherent bias on veterans to obtain chiropractic See above. 9 healthcare as mandated by law. Consider testing direct access on a pilot basis in areas where overloads and backlogs for primary care are most acute. 303 Would like information on those specialty services that do not require referral from a primary care physician in order to determine whether the argument against such direct access might be appropriate for chiropractic.303 See above. Patients deserve an opportunity to make their own decisions about their own health care. 259 See above. Believe veteran should be entitled to seek chiropractic care as a matter of choice for conditions within chiropractic’s realm of professional competence.; such access does not disconnect or eliminate existing primary care case management and crae relationships. Rejects as obstructionist and unreasonable the argument that direct access by the choice of a beneficiary compromises the primary care structure in place; rather it obligates the agency to expand the decision options available to eligible beneficiaries. Direct access could speed up access to care by taking pressure off other segments of the system 486 See above. Concur with Recommendation 9 with the exception that the word “direct” should precede the word “access in line 28 to make it clear that veterans may have direct access to their DC once referred by their primary care provider. 303 See above. Supports access only by referral from the primary care physician. 21 See above. Support recommendation to require referral from primary care physician prior to accessing any new benefit; feel role of primary care physician in monitoring and managing care of the beneficiaries is essential to the successful implementation and utilization of any new benefit. It is in keeping with the primary care model that currently exists within VHA. 27 See above. Would view unfavorably any recommendation to remove or lessen the role of physicians as the primary provider of See above. 10 healthcare. Urge omission of any references to chiropractors being the “managers” of care for musculoskeletal conditions; not appropriate to expand DCs role to the primary principal in such care. 27 10. Continuity of Care for Newly Discharged Veterans Page 10, lines 24-31 – statements regarding the alleged consequences of allowing direct access to chiropractic care are speculative and bordering on paranoia that further reflects the inherent underlying bias against DCs. 303 Comment removed. Agrees with the requirement of a referral from a primary care physician in order to access chiropractic care. Although physical therapists practice independent of referral or direction from physicians in many settings, in the VA physical therapists practice collaboratively wit physicians within the VA primary care model. Believes the same standards followed by all other clinical services must apply to the chiropractic benefit. 472 See above. Goal is to enhance the healthcare services available to veterans; try a number of methods of delivering chiropractic care. 5 Agree with recommendation, but a defined time frame for chiropractic care should be specified, as veterans will need to be evaluated and seen on a periodic basis by their primary care provider. 27 See above. If the referral requirement is removed for chiropractic care in this situation, it should also be removed for any service that military personnel may access directly while on active duty. 472 Comments noted. No change made. Objects to opinion stated on page 12, line 33-36. 23 Comment removed. Believe comment on page 12, line 33 is evidence of bias against chiropractic care. 303 Comment removed. If chiropractic services are offered in such a setting, alternatives to chiropractic care such as physical therapy must also be Comments noted. No change made. Recommendation revised to recommend assignment of primary care provider at earliest possible time. 11. Inpatient Care 12. Chiropractic Care in CBOCs 11 available. Patients must be educated regarding all possible modes of care and access to those services should be of equal convenience. 472 13. Fee Basis Care Provide chiropractic care primarily through doctors of chiropractic who are hired as full-time employees. 10 Comments noted. No change made. 14. Occupational Health Programs Believes DVA should draft and submit to Congress legislation that would remove limitations on reimbursement for chiropractic services under Federal occupational health programs. 23, 303 Not within Committee Charter. Federal OWCP is under Dept. of Labor Objects to statement on page 14, lines 1-12; reflects inherent biases toward chiropractic; inappropriate for an Advisory Committee that is supposed to be providing specific, concrete recommendations to enhance rather than detract from the integration of chiropractic into DVA. 303 Comments noted. No change made. DCs are trained and understand when they should refer patients to the appropriate physicians for care; unnecessary to point out the 3 areas specified in this recommendation. 23, 303 Comments noted. Slight rephrasing made for clarity. Referral service agreements should clearly define appropriate mechanisms for referral to or from chiropractic services. Referral service agreements should exist for all clinical services to ensure equitable treatment. Referral to chiropractic care should not be easier to obtain than a referral to other clinic service as this may unduly influence the veteran to seek chiropractic care. 472 Comments noted. No change made. Agree with page 15, lines 26-29 and urge this statement be retained in final recommendations. Two questions in this recommendation need to be answered. The first refers to patient symptoms - if a patient presents with no symptoms, how can that patient be treated? Finally, the comments state that chiropractic care requires multiple patient encounters over a period of time. If that is the case, how cost effective will this treatment be within the VA system? 27 Comments noted. No change made. E. Referrals to and from Doctors of Chiropractic 15. Screening of Patients 16. Referral Service Agreements 12 17. Referrals from Doctors of Chiropractic F. Integration of Chiropractic Care into VHA Comment on page 15, line 26-29 is irrelevant, as the Committee’s charter has nothing to do with the capabilities of other health care providers. 303 Comments noted. No change made. Disagrees that periodic care over an indefinite period of time is acceptable practice. Utilization management is a hallmark of the primary care model. Guideline for determining medical necessity need to be in place prior to offering the chiropractic benefit to veterans. 472 Comments noted. No change made. Asks that last sentence of 3rd comments (page 15, lines 39-42) be removed. Believes mandatory referral requirement should not apply to chiropractic care within DVA. 23 Comments noted. No change made. Eliminate sentence on page 15, line 39-42; deep concerns that the matter of efficacy continues to be raised by some members of the committee. 303 Comments noted. No change made. Maximize the positive impact of chiropractic care in relation to improving patient satisfaction, improving patient outcomes, reducing unnecessary surgical and diagnostic procedures, reduce over-utilization of pharmaceuticals, reduce medical errors and reduce healthcare expenditures; should be considered full team members of the DVA healthcare delivery apparatus. 10 Comments noted. No change made. Clear forceful direction from top management. 11 Comments noted. No change made. I am a disabled veteran as well as a chiropractor and am grateful for the inclusion of chiropractic into our VA system. I feel the transition of chiropractic services will be smooth and all of the providers at the VA with whom I have spoken will welcome the help. This is an opportunity for both chiropractic and medicine to learn from each other for the betterment of the patient. Certainly, that is paramount. 319 Comments noted. No change made. 13 18. Coordination of Care 19. Co-management of Care 20. Placement of Doctors of Chiropractic within a Health Care Team Agree with recommendation. 27 Comments noted. No change made. Utilize model at NNMC; full integration of chiropractic care; interactive interdisciplinary team; should report along clinical lines of authority. 5 Comments noted. No change made. Consider models of collaborative care in Canadian health plan. Comments noted. No change made. A good implementations model could be: 1) a chiropractic physician on the primary care staff to assist with intake of musculoskeletal complaints and/or 2) a “back pain/neck pain” clinic with both medical and chiropractic practitioners working together to evaluate and treat complaints.22 Comments noted. No change made. 21. Site Selection DCs should be placed at all DVA hospitals, clinics, and treatment facilities, with the possible exception of those areas where multiple DVA facilities are located in close proximity and serve the same patient populations. 10 Recommendation rephrased. 22. Doctor of Chiropractic Staffing Enough doctors of chiropractic should be hired to adequately serve the needs of the patient population and to be readily accessible to those in need of chiropractic care.10 Recommendation rephrased. Suggest recommendation not name a specific number of chiropractic staff to be hired; determining factor should be patient volume. 27 Comments noted. No change made. There is no clarification or description of the role of chiropractic assistants. Unclear if persons working in a physical therapist assistant capacity currently will be expected to act as a chiropractic assistant also or if this is an entirely new designation. Need to specify the level of supervision required for a chiropractic assistant. Recommend these issues be clarified in the final document. 472 Comments noted. No change made. Local facility HR issue. All clinical services deserve equitable treatment. Existing Comments noted. No change made. No service has 8 23.Support Staff 24. Space 25. Co-location with 14 Collaborating Providers and Services resources should not be diverted from existing services in order to provide the new chiropractic benefit. Physical therapy and chiropractic, as well as other clinical services, require uniquely dedicated fiscal, human and physical resources. 472 “uniquely dedicated fiscal, human and physical resources” 26. Equipment Recommend SMEG and thermography be added to the list of equipment. 18 Comment noted. Comment revised to remove reference to NBCE job analysis.. 27.Orientation Educate existing personnel on the availability and potential of chiropractic care to facilitate a smooth implementation of the program. 11 Comment noted. No changes made. 28. Ongoing Education of Providers DoD project revealed expectations of healthcare staff changed after professional interaction. 5 Comment noted. No changes made. ACA and ACC should participate with DVA to implement and maintain on a permanent basis an education campaign aimed at educating DVA physicians and primary care managers regarding the appropriate use and benefits of chiropractic care; every DVA physician and primary care manager should be required to complete this formalized training/education program. Comment noted. No changes made. Include demonstrations of chiropractic treatment for hospital staff and doctors to assist them in making better decisions about recommendations or advising against chiropractic regimens. 22 Comment noted. No changes made. Provide educational information to veterans about availability of chiropractic care. 5 Comment noted. No changes made. DVA should, in cooperation with the American Chiropractic Association and the Association of Chiropractic Colleges, develop, implement and sustain a public education campaign designed to inform eligible veterans of the availability of chiropractic care within the DVA system. 10 Comment noted. No changes made. Rejects the comment on page 20, line 2 and asks that it be stricken from the report. 303 Comment noted. No changes made. Beneficiaries of veterans programs deserve full disclosure and Comment noted. No changes made. 10 29. Education of Patients 15 education regarding all options for treatment of health concerns. 472 30. Quality Assurance 31. Performance Measures 32. Evaluation of Chiropractic Care Program 33. Medical Staff Voting Privileges 34. Continuing Education 35. Oversight and Consultation for the Chiropractic Program Evaluation should include analysis of quality of care and patient outcomes related to chiropractic care.21 Comment noted. No changes made. Any new benefit should be monitored for efficacy, utilization, and cost; important to determine if a new benefit is improving the health care of beneficiaries. 27 Comment noted. No changes made. Objects to the assertion that the chiropractic health care program is somehow a “demonstration” project to be evaluated and either continued or not after a period of time; rejects that a special “test” or evaluation of the effectiveness of chiropractic should be instituted at DVA or any assertion that DVA is still trying to determine if chiropractic care should be offered to veterans. 303 Comment noted. No changes made. All programs are evaluated in some manner, e.g., recent cardiac care program evaluation, with intent of improving services. All Clinical services and clinicians should strive for an evidencebased practice model. 472 Comment noted. No changes made. Each clinical service should be represented equally in the VA facility. If chiropractors gain medical staff voting privileges, then each clinical service present in the VA facility should have voting representation. 472 Comment noted. No changes made. Determination is made on local facility basis. These recommendations concern the integration of DCs into VHA. Establish Office of Chiropractic Services staffed by doctors of chiropractic with appropriate authority and resources to oversee chiropractic care within DVA on a permanent basis. 10 Comment noted. No changes made. Rejects any special oversight or analysis of chiropractic care that is not required of other health care providers; categorically rejects the statement that chiropractic is “controversial” and therefore requiring further Central Office oversight. Remove All professions/programs have some sort of consultative/ oversight representation in Central Office. 16 comment page 22, lines 4-8. 303 36. Committee Membership 37. Academic Affiliations All Chiropractic colleges should have affiliation agreements with DVA facilities as do medical schools with clinical rotations. 5 Comment noted. No changes made. Study risk of vertebral artery dissection by performing magnetic resonance angiography of upper cervical region prior to and after cervical manipulation. 2 Comment noted. No changes made. Rejects that research should in any way focus on evaluation of efficiency. Research is complete on this subject and irrelevant to the task assigned to the Committee. 303 Comment noted. No changes made. Recommendation uses term “efficacy”. Appendix A: Include the following – elbow, feet, knee, shoulder, wrist. 23 Comment noted. No changes made. Appendix B: Support model 3 – integration into a specialty service or service line without specific liaison to primary care. 27 Comment noted. No changes made. Appendix C: Use of passive modalities such as electrostimulation and ultrasound have been shown to prolong disability in musculoskeletal conditions; provided references. Recommend that physical modalities be provided through the physical therapy department where they may be incorporated into a regime of patient-active therapies in order to avoid duplication of services; DCs could refer patients for PT services. 18 Comment noted. No changes made. Add adjusting table, head rest paper, stool, writing surface (desk). 23 Added to list. Complete occupational study as quickly as possible. Amend Title 38 to clarify Congress’ intent that doctors of chiropractic should be hired under Title 38. 5 Occupational study underway. HR 2357 to amend Title 38 has passed House. Hire full-time doctors of chiropractic at appropriate pay scale levels and provided with benefits and career advancement opportunities equivalent to other doctors with four-year clinical degrees.10 Comment noted. No changes made. 38. Research Other comments 17 Develop and communicate specific policies regarding acceptable chiropractic standards of care and professional conduct; notify both jurisdiction of practice and jurisdiction(s) of licensure regarding any adverse action with complete disclosure of relevant information to all chiropractic regulatory boards where licensed .6 Comment noted. No changes made. DVA should develop and implement policies that not only provide access to chiropractic care, but, as deliberate policy actively encourage the utilization of chiropractic care as a substitute for less effective and more costly forms of traditional care. 10 Comment noted. No changes made. Ensure permanent employee status and establish a clear stable career pathway for the doctor of chiropractic. 11 Comment noted. No changes made. Chiropractic should be part of the total heath/disease care of every veteran (and non veteran). Objective findings may be in conflict with subjective complaints; likewise symptoms do not correspond with examination of the neuromusculoskeletal system, so there will continue to be diagnostic and analytical disagreements. 14 Comment noted. No changes made. Opposed to chiropractors being part of the VA system. Literature says spinal adjustment might be beneficial during weeks 3-4 for symptomatic control of acute low back pain only. Literature indicates the benefits of neck adjustment do not outweigh the risks. 17 Comment noted. No changes made. Provided references on health benefits of long-term chiropractic care. 18 Comment noted. No changes made. Urge development of an additional recommendation to address accountability and the exchange of information, i.e. To protect the general public, we recommend that DVA notify both the jurisdiction of practice and the jurisdiction(s) of licensure regarding any adverse actions taken against doctors of chiropractic practicing in the VA system. We also urge adoption of a VA policy which allows complete disclosure of relevant information to those jurisdictions’ chiropractic regulatory boards Comment noted. No changes made. 18 to assist their expeditious investigations. 25 Concerned that some members of the Committee appear to treat the chiropractic health benefit enacted by Congress as a “demonstration” whose merits remain in question. Object to any comments, recommendations or dissents that attempt to reopen debate on the efficacy or benefits of chiropractic care to veterans. 303 Comment noted. No changes made. VA should accept the Council on Chiropractic Practice Clinical Practice Guideline Number 1: Vertebral Subluxation in Chiropractic Practice as an acceptable standard of care within the VA system. 313, + Comment noted. No changes made. Significant concern that the implementation of a new benefit, such as chiropractic service, without additional resources, could be detrimental to existing clinical services and the veterans served by these services. Draft does not address how this new benefit will be financed. VA must take the appropriate action to ensure that physical therapy is a unique clinical service separate and distinct from chiropractic and that appropriations for this new benefit are allocated in the VA budget on an annual basis. 472 Would like to see references within the document that clearly include therapy disciplines as appropriate services to consult with in order to provide comprehensive rehabilitation care. Reference is made to the multidisciplinary team or to “other appropriate VHA providers.” Would like physical therapists to be specifically mentioned as one of the providers. Should be very clear in the final document language that many clinical services are appropriate options in the treatment of neuromusculoskeletal conditions. 472 Comment noted. No changes made. Support addition of chiropractic to Medicaid/VA; recommends a specific company to do credentialing of DCs. 488 Comment noted. No changes made. 19 Comment noted. No changes made. Persons/Organizations Providing Comments * letters are the same ** body of letters are the same as those marked with * but have additional personal identification, a few additional remarks reflecting the same points, or are abbreviated versions of the same letter. + letters are the same # identified self as veteran Date Name 1 9/28/2002 John V. Whaley, DC 2 3/8/2003 John C. Haumesser, MD 3 4 3/20/2003 3/20/2003 Gwain Zarbuck II, DC Sidney H. Bernstein, MD et al 5 3/25/2003 David O’Bryon, JD, LLD 6 3/25/2003 Wayne C. Wolfson, DC 7 3/25/2003 Matthew McCoy, DC. 8 3/25/2003 David Chapman-Smith, LLB 9 3/25/2003 George McClelland, DC 10 3/25/2003 James D. Edwards, DC 11 12 13 3/25/2003 3/25/2003 3/26/2003 Ronald M. Hendrickson Brian D. Reilly, DC Parker Todd Zarbuck, DC 14 15 16 8/11/2003 8/12/2003 8/13/2003 17 8/18/2003 Doral Robb, DC# Melinna Giannini Seymour Shribnik, DC# Preston, Long, DC, PhD (with 6 attachments) 18 19 8/18/2003 8/18/2003 Christopher Kent, DC Terry Rondberg, DC 20 8/20/2003 Norris A. Erickson DC# 21 22 8/20/2003 8/20/2003 23 8/22/2003 Warren A. Jones, MD Ward J. Henry, DC# Government Relations Department, American Chiropractic Association 24 8/22/2003 Rob Sinnott, DC 25 26 8/22/2003 8/25/2003 Richard L. Cole, DC Jack Morgan, DC Organization/ Location Consumer Protection Committee on Chiropractic Practice, Naperville, IL Lead Orthopedic Surgeon, VA Western NY Health Care System, Buffalo, NY Legal Affairs Chairman, IL Prairie State Chiropractic Assn., Rock Island, IL Texas Back Institute, Plano, Tx Executive Director, Association of Chiropractic Colleges President, Federation of Chiropractic Licensing Boards Editor, Journal of Vertebral Subluxation Research; Chair, Guidelines Commit-tee, Council on Chiropractic Practice Secretary General, World Federation of Chiropractic; General Council, Ontario Chiropractic Assn. Foundation for Chiropractic Education and Research Chairman, Board of Governors, American Chiropractic Association Executive Director, International Chiropractors Association Private Practice, IL Madison, WI President, Alternative Link. Albuquerque, NM Weymouth, MA President, Council on Chiropractic Practice; Board of Directors, World Chiropractic Alliance President, World Chiropractic Alliance Commander, American Legion Post No. 84, Aurora, IL Chair, Board of Directors, American Academy of Family Physicians CA American Chiropractic Association President, Association for Chiropractic Educational Standards President, Federation of Chiropractic Licensing Boards 27 28 29 30 31 32 33 34 35 36 37 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 Darryl A. Beehler, DO * Paul Edwards, DC * Erin Elster, DC ** Brycen A. Hudock * Chad Rohlfsen, DC * Tony Curcuruto, DC * Kurt Wipperfurth, DC * Jonathan S. Priess, DC ** Dr. Hanifen ** Dermot Jinks * Micah D. Carter, DC President, American Osteopathic Association Nampa, ID Boulder, CO Charlottesville, VA; WCA Intl Brd of Gov Newton, IA Santa Rosa, CA Green Bay, WI Portland, OR “Student doctor of chiropractic” Peabody, MA Edmond, OK Member, WH Commission on CAM, Arlington, WA Plano. TX Manchester, MO Ann Arbor, MI 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 Veronica Gutierrez, DC * Ted Koenen, DC ** Craig Anderson, DC * Darren Schmidt, DC, ND * Matthew D. Colby, DC * William F. Strieff, DC * Bryan Zales, DC * Scott Brodnax, DC ** John Cafferty, DC * Howard Hadley, DC * Jeremy Popp, DC * Robert D. Helveston, DC * Dennis Caudill, DC * Lizette K. Eckert, DC * Paul Schaffer, DC * Alfonso Di Carlo, DC * Christopher C. Cox, DC * Steve A. Hawkins, DC 56 57 58 59 60 61 62 63 64 65 66 67 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 ** Cara Davis * Adam Propper, DC * Dr. Jill Narlock, DC * Tami Forsythe, DC * Dwight Copeland, DC * Mary Audia, DC * Guy Anderson, DC ** Heide L. Hartmann-Taylor * Thomas Pinard, DC * Dale Lotter, DC * Christian Gonsalves, DC * Steven Lark, DC 68 69 8/25/2003 8/25/2003 ** William Marc Goldenberg * Nicole Buchanan, DC 70 71 72 73 74 75 76 77 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 ** Akiba Green * Treye Hovinga, DC * John F. Przybylak, DC ** Brian Flannery, DC ** Jeff W. Dill, DC * Timothy Jameson, DC ** Brian Murray, DC * Deborah Peters, DC Big Timber, MT Clover, SC Gresham, OR Rochester, NY Homewood, IL Wauchula, FL Kannapolis, NC South Portland, ME Santa Barbara, CA Allentown, PA Tucson, AZ New Ulm, MN Doctor of chiropractic student; Boiling Springs, SC Westport, CT West Chester, PA Cullman, AL Fergus Falls, MN Clinton, MI Tucson, AZ Sarasota, FL Student, Palmer College of Chiropractic, Davenport, IA Phoenix, AZ Student, Sherman College of Straight Chiropractic, Spartenburg, SC Snoqualamie, WA Buffalo, NY Central Regional Director ICA, Lakewood, WI Pekin, IL Castro Valley, CA Hilliard, OH Bloomfield, IA 21 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/25/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 George Roy# Robert Richards, DC * Chris Akey, DC * Brian R. Sterns, DC Daniel T. Barrett, DC * Robert A. Berger, DC * Christine Fallwell, DC * Shadi Amin * David Tribble, DC * John Steigerwald, DC * Scott E. Brunengraber, DC ** Philip R. Schalow, DC * Jonathan M. Snyder, DC * Josh Gilbert, DC * Lynda Bribach, DC * Lyle Love, DC * Michael Schur, DC * Robert Martines * Fred J. Blum, DC ** Jason L. Pickel, DC * Ramin Izi, DC * Gary Bretow, DC ** Henry Wong * Curtis E. Garner, DC * Robert C. Dees, DC * Norman Colby, DC * Sue Schappert, DC * Daniel Knowles, DC and Rochelle Knowles, DC * Melvin J. Rosentahl, DC * Chris Serafini, DC ** Matthew Ferris * Dannielle McClintock, DC * Sylvia M. Skefich, DC * Mario Milani, DC ** Anthony V. Bastecki, DC * Michel N. Armaly, DC * Jimmy Blanton, DC * Michael J. Farrell, DC * Bill Gallagher, DC ** Ellen S. Jackson, DC * Stephen Weschler, DC * Matthew Mix, DC * Matthew B. Shifflett, DC * Richard Sylvester, DC * Eric R. Hartman, DC * Andy DeHaven, DC * Paul B. Patterson, DC * James Easterling, DC * P. Bruce White, Jr., DC Erik W. Hanson, DC# Andy Abele ** Mark Butler, DC * Aaron Moreland * Chris Jensen, DC 22 Scarborough, ME North Bend, OR Farmington, AR Salem, OR Saint Paul, MN Palmyra, VA Aliso Viejo, CA Lee’s Summit, MO Holbrook, NY Rockford. IL Circleville, OH Salem, VA Atlanta, GA Kirkland, WA Clarkesville, GA Overland Park, KS CA Miami, FL San Ramon, CA Crested Butte, CO Boulder, CO Phoenix, AZ Chiropractic graduate student, Davenport, IA Alameda, CA Santa Cruz, CA Spring Hill, TN Mauldin, SC Huntington, WV Glenside, PA Scottsdale, AZ Fairview, PA Syracuse, NY Belle Chasse, LA Kilmarnock, VA Holland, MI Watervliet, MI St. Louis, MO Hartsville, SC Batesville, IN Bethel Park, PA Student of chiropractic, St. Louis Park, MN Bellingham, WA 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 * Pat Walsh, DC * Brett Casanova ** Rick Hueffmeier, DC ** Richard P. Casanova, Dc * Amy Kolman, DC * Matt Hubbard, DC * Craig McKee, DC * Michael T. Denery, DC ** Chad Cotter, DC * Mark C. Darling, DC * Adam Austin, DC ** Jace H. Ferguson, DC * Howard Short, DC ** Patrick S. Cooper, DC Elizabeth C. Kressin, Dc * Josh Johnston, DC * Tracy Gabbert, DC * John P. Rempel. DC * Richard Humiston, DC Christopher Brooks, DC * Jason A. Weniger, DC Gail Gilligan, DC * Jason Ledford, DC * David M. Gustitus, DC * Derek A. Houtz, DC * Brian Johnson, DC and Tracy Johnson, DC ** Lisa Hannifin, DC * Kristen O’Reilly, DC * Heather A. Van Skyhock, DC * Martha H. Bergner, DC * Alice B. Elrod, DC ** Arno Burnier, DC Christopher J. Rogers, DC ** Robert J. Manna, DC * Landrum Williams, DC * Don Lemberger, DC * Tripp Stover, DC ** Brice Kovarik, DC ** Brent Reiche, DC * Lora Kinter, DC 172 173 174 175 176 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 * Eric C. Krohne, PhD * Michael P. Cohen, DC * Paula Frey, DC * Scott Stachelek, DC ** Manon Fielding, DC 177 178 179 180 181 182 183 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 * Christopher H. Stewart, DC * Nancy Parker, DC * Brett D. Gallagher, DC ** Wade Lofton * Teri Lorencen Stockwell, DC * Allen R. Bastecki, DC * Simon A. Senzon, DC Davenport, IA MN Davenport, IA Wales, WI San Diego, CA Staples, MN Littleton, CO Ft. Collins, CO Raleigh, NC San Diego, CA Marysville, OH Spencer, IA Littleton, CO Indianapolis, IN NC Alpharetta, GA Wilmington, NC Calhoun, GA McVeytown, PA Santa Barbara, CA Burbank, CA Grand Prairie, TX Haslett, MI Tucson, AZ Eureka, MT Durango, CO Toluca Lake, CA Rome, GA Greenville, SC Louisville, CO Mechanicsville, VA Lynnwood, WA Pueblo West, CO Executive Director, GA Chiropractic Association Toronto, Ontario Montclair, VA Hillsborough, NC 23 Madison, AL Auburn, GA Bakersfield, CA Traverse City, MI Ames. IA Asheville, NC 184 185 186 187 188 189 190 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 8/26/2003 ** James Stirton, DC * Robert W. Dunn, DC * William Berkowitz, DC * Michael Quartararo, DC * Carol E. Adams, DC * Trey Stiles, DC * Adrian Yeung, DC Sacramento, CA Seattle, WA Arroyo Grande, CA Ballston Spa, NY Telluride, CO 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 8/26/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/27/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 ** Steven Black Avery N. Martin, DC ** Kenneth Fuller, DC * W. Kurt Miler, DC * Stephen D. Lee, Dc * Jeffrey Smith, DC * Rich Gorsuch, DC * Eugene L. Packer, DC ** Robert Rogillio, DC * Daniel R. Perkins, DC * sacred mission @ * Jean Warrington, DC * James A. Dahlin, DC ** Hans Conser, DC# * Willie W. Kindred, DC * J.M Sigafoose, DC * Jerry Webb, DC and Simone Webb, DC * Elizabeth Faletti, DC ** Miriam Leean, Dc * Jonathan Ewer, Dc * Randy C. Moze, DC * R. Scott Miner, DC * John Paul Reeve, DC * Damian A. Palmer, DC * Jean-Marc Slak, DC * James D. Eckert, DC * Richard Clark, DC * Heather Whittle, DC * Yitzchack Freeman, DC * Craig Stull, DC * Debra Barnes, DC * Desdemona Whitley, DC * Cara A. Iovino ** Jonathan Berns * Rick Eschholz, DC * David Ullian, DC * Jimmy Labrecque, DC * Mike Montesano, DC * Louis Abate, DC ** James R. Vana, DC * Travis Hughes, DC * Eric Mintz, DC * Pete Gay, DC * George C. Fraudin, DC * Len Schwartz, DC * Mitchell E. Falk, DC 24 Bothell, WA Student of chiropractic, Parker College of Chiropractic, Irving, TX Savannah, GA Sarasota, FL Gainesville, FL Keene, NH North Easton, MA Houston, TX Hatboro, PA Rocklin, CA Bozeman, MT Tempe, AZ Kingston, WA Kennewick, WA Waupaca, WI Dallas, GA Norcross, GA Hesperia, Mi Burlington, MA South Portland, ME Dublin, GA Kennesaw, GA Jerusalem, Israel MI Brandon, MS San Diego, CA Sandy Springs, GA Chiropractic student, Davenport, IA Montpelier, VT Fort Lauderdale, FL N. Richland Hills, TX Elmwood Park, IL Boston, MA Moline, Il Keego Harbor, MI ICA State Representative, Kennebunk, ME Richboro, PA Chairman, SC Board of Chiropractic 237 238 239 240 241 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 * Timothy Lenahan, Dc * Andrew Sokol, DC * Shawn Stubbs, DC * Matthew R. Derosier, DC * Jesus Castaneda, DC 242 243 244 245 246 247 248 249 250 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 251 252 8/28/2003 8/28/2003 ** J. Richard Burns, DC * Carrey Tiller, DC ** John House, DC * Brian Nardi, DC * Kelli M. Uhlman, DC * Jeana Thomas, DC * Kevin M. Smith, DC * Tim Henderson, DC * Anthony Pivonka, DC * Emily Stumpf, DC and J.T. Stumpf, DC * Steven L. Moon, DC 253 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 8/28/2003 278 279 280 281 282 283 284 285 286 8/28/2003 8/29/2003 8/29/2003 8/29/2003 8/29/2003 8/29/2003 8/29/2003 8/29/2003 8/29/2003 ** Gwain Zarbuck II, DC * Joshua K. Purcell, DC * John R. Fisher Jr. DC ** John G. Goodfellow III, DC * Jerry Dreessen, DC * Jack Mansche, DC David Sheitelman # * Danny G. Lipes, DC ** Gene Putnam, DC * Shahram Honari, DC * Daniel E. Arnold, DC * Brian Benson, DC ** Charles R. Dixon, DC * Daniel Jacobazzi, DC * L. Craig Crockett, DC Dennis M. Cozzocrea, DC # * Pamela S. Grindl, DC * Virginia A. Steiner, DC * Mindy A. Weingarten, DC ** Steven Cantor DC * Garrett Fritts, DC * Nancy Williver, DC * Tom L. McAvoy, DC * Luigi Di Rubba, DC ** Dennis Doyle, DC * Aaron M. Peters, DC and Jennifer M. Peters, DC * Marc Wind, DC ** Roy M. Ostenson, DC * Lane Luxon, DC * Seth Chalfin, DC * Scott Erichsen, DC * Kay K. Secrest, DC * Dale G. Kenny, DC * Dean A. Chancey, DC 25 Examiners South Amboy, NJ Duluth, GA Moody, AL Dilworth, MN San Antonio, TX Professor, Palmer College of Chiropractic, Davenport, IA Baton Rouge, LA Avon, CT Denver, CO Venetia, PA Lake Kiowa, TX Gilbert, AZ Keene, NH Concord, CA Legal Affairs Chairman, IL Prairie State Chiropractic Assn., Rock Island, IL North Las Vegas, NV Racine, WI IL Mountlake Terrace, WA Greenfield, WI Chiropractic student Davenport, IA Maui, Hawaii Davenport, IA Kokomo, IN Prescott, AZ Chandler, TX St. Johs, AZ Yakima, WA Davenport, IA Marion, IL Port Orange, FL Boca Raton, FL San Francisco, CA Landing, NJ Cheshire, CT DuBois, PA Boulder, CO Neenah, WI Lynden, WA Bergenfield, NJ Algoma, WI Algoma. WI MAJ, USAF IRR 287 288 289 290 291 292 293 294 295 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 8/29/2003 8/29/2003 8/29/2003 8/29/2003 8/30/2003 8/30/2003 8/30/2003 8/30/2003 8/31/2003 8/31/2003 8/31/2003 8/31/2003 8/31/2003 9/1/2003 9/1/2003 9/2/2003 9/2/2003 9/2/2003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/2/2003 9/2/3003 9/3/2003 9/3/3003 9/3/2003 9/3/2003 9/3/3003 9/3/2003 9/3/2003 9/3/3003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 332 333 334 335 336 337 338 339 340 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 ** Donald W. Olson, DC * Harald Conradi, DC ** Paul C. Sorchy II, DC * Edward C. Deemer, DC ** Edward Hacmac, DC * Heather Freedlund, DC * Matthew Zimmerman, DC * Stanley M. Miller, DC * Moshe Newman, DC * Asher Nadler, DC * Keith McKim, DC * Leonard Rosenblum, DC * Allison Glass, DC * Pamela Stone, DC * Kenneth H. Ruf, DC * Kevin J. Moore, DC Association of Chiropractic Colleges * Robert J. Scranton, DC * Daniel Greenberg, DC * Jason E. Hartle, DC * James R. Darnell, DC * Dustin J. Detrick, DC * Kreg D. Huffer, DC * Amy G. Debter, DC * Chad Luce, DC * John Marth, DC * W. Atkinson, DC Terry Rondberg, DC * Mark A. Bassett, DC * Heather Iannelli, DC * Brian J. Harasha, DC * Charles S. Emmons III, DC * Russel Schroder, DC Patrick Thomas, DC# ** Joanne Therriault, DC * Ronald Perry, DC * J. Dean Fitsgerald, DC + Robert Manna, DC + Liam P. Schubel, DC + Chad Rohlfsen, DC + Richard G. Stein, DC + Alan J. Lichter, DC +Craig Finkelstein, DC + Bruce Grundy, DC + Marc Ott Charles Jackson (did not receive body of message due to virus) + Bruce Kesten, DC + Derek S. Atchley + Robert G. Casteel, DC + Dale V. Lotter, DC + Chad S. Young, DC + Tony Palmero, DC + Tania Howard DC + James P. Ramos, DC 26 Auburn, WA Durango, CO NRCC Oklahoma City, OK Milwaukie, OR Winnebago, IL Mt. Pleasant, SC Troy, MO Jerusalem, Israel Los Angeles, CA Nampa, ID Sunderland, MA Kennesaw, GA Coon Rapids, MN Palmer Chiropractic College Association of Chiropractic Colleges Margate, NJ Jackson Center, OH Jackson Center, OH Jackson Center, OH Jackson Center, OH Chattanooga, TN MA President, World Chiropractic Alliance Shelby Township, MI Ft. Wright, KY St. Louis, MO Poughquag, NY Corpus Christi, TX Roosevelt, UT Roosevelt, UT Rome, GA Freehold. NJ Newton, IA Washington, DC Doylestown, PA Peachtree City, GA Chiropractic student Oceanside, NY Student, Palmer Chiropractic College Green Bay, WI Tucson, AZ Paducah, KY Sedro Woolley, WA 341 342 9/3/2003 9/3/2003 * Diane M. Zaccaria, DC + James W. King, DC 343 344 345 346 347 348 349 350 351 352 353 354 355 356 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 390 391 392 393 394 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/3/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 + Jonathan Berns, DC + Michael O’Brien, DC + Preston Tornell, DC + Jeffrey P. Clark, DC + Lyle, Love, DC + James D. Eckert, DC + Jamy Antoine, DC + Marvin C. Lee, DC + Stuart Druckman, DC + Jeffrey James, DC + Arlin T. Resco, DC + Andrew Smyth, DC + Adam J. Williams, DC + H.B. Powell, DC + Brett D. Gallagher, DC + Jonathan M. Snyder, DC + David Ginsberg, DC + Robert Martines, DC + Myron D. Brown, DC + James D. Moss, DC * Rick Humiston, DC + Tim Ciolkosz, DC + Todd E. Plinke, DC + Lonnie Rudd, DC + Bonnie Travis, DC + Shervin Parvini, DC + Mayor Stephanie R. Grenier, DC + Patrick J. Walsh, DC + Roger J. Kasperbauer, DC + Charles G. Register, DC# + Fred Gerretzen, DC + Paula J. Sperry, DC + Asher Nadler, DC + Robert Wallace, DC + Ellen S. Jackson, DC + Dennis S. Brickner, DC + Mario Milani, DC + Richard M. Kuhns III, DC + Nancy J. Trimboli, DC + John Claussen, DC + Matthew B. Shifflett, DC * Kyrie Kleinfelter, DC + Sean Alan Reese, DC + Garnett Stover, DC + Perry O. Rush, DC + David W. Basista, DC + Fred Clarke, DC + Michelle Mix, DC + Thomas F. Tauer, DC + Donald J. Cox, DC + Michael R. Zolper, DC + Robert D. Meadows, Sr., DC 27 Wilmington, NC Auburn, CA Student, Palmer College of Chiropractic, Davenport, IA Sioux City, IA Lake Stevens, WA Seattle, WA South Portland, ME Victoria, MN Rancho Palos Verdes, CA Gettyburg, PA Los Angeles, CA Clyde, KS Norwood, MA Okemos, MI Salem, MO Bakersfield, CA Circleville, OH Santa Clara County Inman, SC Sterling Heights, MI Wilmington, DE Amherst, NY Kansas City, MO Fortuna, CA Auburn, GA Santa Rosa, CA Moscow, Russia Eastham, MA Los Angeles, CA Huntington, NY Fairview, PA Springboro, OH Spring Hill, TN NC Hammond, IN Kilmarnock, VA St. Charles, IL Mechanicsville, VA SC Olathe, KS Belle Chasse, LA Richmond, VA Libby, MT Baraboo, WI Atlanta, GA 395 396 397 398 399 400 401 401 402 403 404 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 427 428 429 431 432 433 434 435 436 437 438 439 440 441 442 443 444 445 446 447 448 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/4/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/5/2003 9/6/2003 9/6/2003` 9/6/2003 9/6/2003` 9/6/2003 9/6/2003` 9/6/2003 9/6/2003` 9/6/2003 9/7/2003 9/7/2003 9/7/2003 9/7/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 + John Adams, DC + Todd Caughey, DC + William F. Lawler, DC * Todd W. Gignac, DC + Darrel Crain, DC + Elizabeth Faletti, DC + Kevin C Smith, DC + Jennifer Sherriff, DC + Jason B. Welker,DC + Ida Allen, DC + Jeff Shiflet, DC Lisablu@ (no message, attachment blank) + David V. Young, DC + Josh Watkins, DC + Brenda Hassebrock, DC + Christian Haug, Dc + Linda Dirlam, DC + Stuart C. Kordonowy, DC + Nicole Buchanan, DC + Teresa Fourre’, DC + Tanya Hinka, DC + Guy Anderson, DC + Randy C. Moze, DC + Craig Rogers, DC + Steven C. Eisen, DC + Joe Hassler, DC + Adrian Yeung, DC + Patrick T. Ryan, DC + Dale Andelkovic, DC * Stephen C. Brower, DC + Dominiqe M. Scott, DC + Christopher J. Koch, DC + Robert A. Abbruzzese, DC + Soft Touch Chiropractic @ + Lori Ugolik, DC + Daniel F. Allen, DC + Rich Eschholz, DC + Michael Montesano, DC + Gerald A. Anzalone, DC + Glenn Gabai, DC Matt Willenkin, MD, DC + Bernard Kaseman, DC + Carolyn De Witt, DC + Terri L. Weed, DC + Israel Maldonado, DC + Charles L. Blum, DC + Dean L. Smith, DC + Alan Meden, DC + Thalia Duncombe DC + Martin G. Rosen, DC + Donald Gran, DC + David H. Pico, DC + D.W. Williams, DC + Jack Masche, DC 28 Grand Junction, CO WA Philadelphia, PA Fairfield, CT Hyde Park, UT WI Mesa, AZ Prior Lake, WI Houston, TX Fargo, ND Cedar Falls, IA Asheville, NC Phoenix, AZ Holly Springs, GA Delray Beach, FL Fergus Falls, MN Buchanan, GA Kihei, HI Philadelphia, PA Fort Collins, CO Bothell, WA Redlands, CA New Orleans, LA Manhattan Beach, CA Phoenix, AZ Briarcliff Manor, NY Macon, GA Tucson, AZ Montpelier, VT Elmwood Park, IL Peekskill, NY Lancaster, PA Tarzana, CA Tarzana, CA Boca Raton, FL Oxford, OH Pleasant Hills, PA Parker College of Chiropractic Wellesley, Ma Palmer College of Chiropractic, Davenport, IA New York City, NY Coldwater, MI Milwaukee, WI 449 450 451 452 453 454 455 456 457 458 459 460 461 462 463 464 465 466 467 468 469 470 471 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/8/2003 9/9/2003 9/9/2003 9/9/2003 9/9/2003 9/9/2003 9/9/2003 9/9/2003 9/9/2003 9/10/2003 + William Martin Sloane, LLM + Steven G. 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Miller, DC + Barabara Bjerken, DC Marvin Talsky, DC (attachment blank) + Karl R.O.S. Johnson, DC * Christopher G. Lee, DC * Ronald Festa, DC International Chiropractors Asso. + Emerson S. Taylor, DC Grant Shapiro, DC Christian Bartels, DC *Thomas D. Barnes, DC + Katrina van der Merwe, DC * William C. Keith, DC 29 Carlisle, PA Marquette, MI Rhinebeck, NY Marquette, MI Las Vegas, NV CA, NM TysonsCorner, VA Arlington, WA Staples, MN DuBois,PA Bozeman, MT Bkln, Y Antigo, WI Sherman College of Straight Chiropractic Newport Beach, CA Gilbert, AZ Vernon Hills, IL South Lake Tahoe, CA La Grange Park, IL ID President, American Physical Therapy Association Chambersburg, PA Sarasota, FL Chino Valley, AZ Traverse City, MI S. Dennis, MA Recent graduate Westfield, NY Moorhead, MN Shelby Township, MI New Kensington, PA International Chiropractors Association Blanchester, OH Doylestown, PA Fayetteville, AR Texas