CSOMA OPPOSES AB 2668.
April 1, 2026
CSOMA conducted an emergency Town Hall on Tuesday, March 31, 2026 to discuss the implications on Assembly Bill 2668. A replay is available here.
Bill text of AB 2668 may be accessed here.
Below are key points (“major concerns”) of the Department of Consumer Affairs’ analysis of AB 2668. The full document may be accessed here:
Major Concerns with AB 2668
Lack of clarity on curriculum requirements
The bill increases total and clinical training hours but does not specify how those hours should be allocated across subjects.
This creates regulatory uncertainty and forces the Board to redesign curriculum standards without clear legislative guidance.
Increased regulatory burden and inefficiency
The Board would need to realign or redistribute curriculum hours, requiring regulatory amendments.
Leads to significant additional workload for program review and approvals without clear benefit.
Confusing and contradictory “Doctor” title provisions
The bill creates ambiguity between:
Moving toward a doctoral entry-level profession, and
Restricting use of the “Doctor” title unless tied to very specific degree language.
Results in internal inconsistency within the law.
Disconnect between degree and title usage
Even if practitioners earn doctoral-level education, they may not be allowed to use the DAHM title unless their degree name exactly matches.
This creates a misalignment between education, credentialing, and professional identity.
Excludes many qualified doctoral graduates
Practitioners with equivalent doctoral degrees (e.g., DACM, DAOM, DOM) would be prohibited from using the protected title.
Establishes an overly rigid, degree-specific naming requirement rather than recognizing equivalent qualifications.
Fails to establish a universal professional title
Although the bill introduces DAHM, it does not function as a standardized license-level designation.
Instead, it ties title usage to specific degree nomenclature, limiting broad applicability across the profession.
Ignores existing and alternative licensure pathways
The bill does not account for current practitioners, students, or alternative pathways to licensure.
Raises concerns about transition timelines, fairness, and eligibility impacts.
Significant cost and administrative burden
Curriculum changes would require thousands of hours (2,960) of Board review work and potentially new staffing.
Could lead to new fees on schools or licensees to cover increased costs.
Unfunded mandate on schools and regulators
All programs must revise curriculum and undergo approval, creating system-wide strain during transition.
No clear funding mechanism to support this масштаб change.
Uncertain long-term impacts on the profession
Changes may affect applicant volume, licensure access, and workforce pipeline.
Potential to reduce entry into the profession due to increased barriers and confusion.
For actions you can take, please refer to the CSOMA Alert:
Contact: Dr. Robyn Adcock, LAc, Executive Director
