COMTA Executive Director Comments on Model Practice Act

Submit Your Comments on the Model Practice Act!

The FSMTB has a very short window for accepting comments on the Massage Therapy Model Practice Act (MPA). Please take the time to read the draft and submit your comments by August 15th.  You can access the draft and comment section here.

A few items to clarify:

1. Remember, this is a MODEL of an act. This will be used as the recommendation for wording when states are considering updating their laws. This model does not have any effect unless a particular state decides to use the recommended wording.

2. There are many people in the massage community who are making comments about the requirement in Section 103 (B) that schools be accredited by an agency recognized by the U.S. Department of Education. This is a very normal requirement for regulation of a profession. However, usually this is limited to the accrediting agency (or agencies) that have specialized focus and give a more comprehensive evaluation of the specific content of the accredited program. COMTA is the specialized agency for massage therapy and bodywork education. The way the Section 103 (B) definition is currently written, it would still allow accreditation by various accrediting agencies, even if they do not evaluate the content of the massage program. COMTA supports the inclusion of accreditation as a requirement in the MPA.  We would prefer to see more specific review of curriculum as the requirement by adding language to require accreditation by an agency recognized by the Department as having appropriate program level review.

3. To the right of the Section 103 (B) definition on page 6, the MPA notes that the details of what is to be contained in the program should be promulgated into the rules/regulations for a particular state. Then the ELAP recommendations and COMTA accreditation are noted as examples. COMTA supports the delegation of specific program content to rules/regulations level because these can be updated much more easily than the law which contains the official practice act. In support of more consistent requirements from state to state, we sincerely hope each state will consider adopting program requirements which are based on competency and demonstrated skills rather than only evaluating a transcript for hours of training with a specific topic name. The ELAP Blueprint pages 32-44 contain a recommendation for such outcomes, and COMTA curriculum competencies are compatible with the ELAP recommendations. Furthermore, we urge states to utilize COMTA as a support in evaluating educational programs, as that is our area of specialty. Utilizing a common standard and process will help improve consistency of education, one of the major problems identified in our field.

Please also keep in mind that although COMTA utilizes the work of many volunteers, the views of individual volunteers may not be the official stance of COMTA. We appreciate all of our supporters and volunteers, but please check with the COMTA staff (Angie and Kate) if you have questions about statements made on social media by others about COMTA. You can reach both of us through info@comta.org or (202) 895-1518.

Thank you for submitting your comments about the MPA. Have a great week!
Kate Zulaski
Executive Director
Commission on Massage Therapy Accreditation