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Chinese Herbal Formula Prescribing: The BC Government’s New Q&A

6 min read

The BC Government has released a new Q&A clarifying the current status of Chinese herbal formula prescribing under the HPOA. While the Q&A confirms that TCM professionals have not lost the ability to prescribe, compound or dispense Chinese herbal formulas, ATCMA’s key concern—ensuring unregulated individuals cannot prescribe these specialized remedies—remains unresolved.

ATCMA has been advocating for the return of the restricted activity for prescribing Chinese herbal formulas since it was removed with the transition to the Health Professions and Occupations Act (HPOA) and the updated Complementary Health Professionals Regulation.

The BC Government has now released a Q&A addressing questions about Traditional Chinese Medicine and Acupuncture (TCMA), including Chinese herbal formula prescribing. Read that here: https://www2.gov.bc.ca/assets/gov/health/practitioner-pro/professional-regulation/tcma_qa_2026.pdf

We appreciate that the government has continued to meet with us and listen to our concerns, and that the Q&A provides some important clarification. However, our primary ask has not yet been met.

Is There a “Deregulation” of Chinese Herbal Formulas?

No. The Q&A makes this clear, and this has always been ATCMA’s position.

ATCMA has never said that TCM professionals lost their scope of practice to prescribe Chinese herbal formulas.

The Q&A confirms that traditional Chinese herbs, formulae, and food cure recipes remain within the scope of practice of the TCMA profession under section 26 of the Complementary Health Professionals Regulation. It further states that nothing in the transition from the former Health Professions Act to the HPOA prevents TCMA practitioners from prescribing, compounding, and administering Chinese herbal formulae.

In other words, TCM professionals have not lost the ability to prescribe Chinese herbal formulae.

As before, R.Ac.s cannot provide or recommend Chinese herbal formulas, while the other TCM licensees can continue to prescribe, compound, and dispense them.

ATCMA has never said that TCM professionals would lose their ability to prescribe or dispense Chinese herbal formulas.

We also never characterized the situation as TCM prescribing being “deregulated.” Unfortunately, use of that term by others created confusion and allowed the focus to shift away from the actual issue ATCMA was raising.

ATCMA has always recognized that only appropriate CCHPBC licensees can use protected titles such as Traditional Chinese Medicine Practitioner, Doctor of Traditional Chinese Medicine, Acupuncturist, and Traditional Chinese Medicine Herbalist.

Our Actual Concern

Our concern has always been more specific.

When Chinese herbal formula prescribing was removed from the list of restricted activities, ATCMA and others raised concerns about the potential consequences of allowing unregulated individuals to prescribe Chinese herbal formulae.

The issue was never whether regulated TCM professionals could continue prescribing. The issue was who else could prescribe without being a regulated health professional.

ATCMA also recognized and communicated that restoring a restricted activity would require an additional schedule identifying the specific Chinese herbs or substances covered, as the previous regulations did not provide a list that could support enforcement of such a restriction.

Why This Matters for Public Protection

Prescribing Chinese herbal formulae is a specialized area of TCM practice.

TCM professionals trained in herbal medicine undertake substantial education in Chinese materia medica, formula construction and modification, TCM diagnosis and pattern differentiation, dosage, contraindications, interactions, adverse effects, and clinical management.

This training is supported by professional regulation. Licensed TCM professionals are accountable to their regulatory college, must meet professional requirements, and carry professional liability insurance.

This matters for public protection.

If a regulated TCM professional makes a prescribing error that results in harm, there is a regulatory body with jurisdiction over that professional.

If an unregulated person prescribes a Chinese herbal formula and causes harm, CCHPBC cannot investigate or discipline that individual as a health professional.

That was—and remains—ATCMA’s concern.

What the Government Has Said and What It Is Saying Now

In January 2026, MLA Anne Kang released a statement (https://atcma.org/blog/ministry-of-health-statement-on-traditional-chinese-medicine-regulation) attributed to then-Minister of Health Josie Osborne stating that, after hearing feedback from TCM practitioners, the Minister had directed the Ministry to make changes to clarify that activities related to Chinese herbal formulae are restricted and fall under the purview of regulated/licensed TCM practitioners, doctors of TCM, and TCM herbalists.

The new Q&A, however, states that the Minister has directed CCHPBC to “consider the development of professional standards related to the designing of herbal formulae” for TCM licensees and other regulated health professionals whose scope may include herbal formulae, such as naturopathic physicians.

This is not what ATCMA asked for and does not address our primary concern.

Professional Standards would provide rules and requirements for professionals who are already licensed to prescribe, compound, and dispense herbal formulas. They do not, on their own, prevent an unregulated individual from doing so.

CCHPBC expects this work to be completed by early 2027, and ATCMA has been told that, per the HPOA, we should be included in meaningful consultation before the Professional Standards are finalized.

What Happens Next?

ATCMA will continue to advocate for restrictions preventing unregulated individuals from prescribing, compounding, and dispensing Chinese herbal formulas.

We look forward to meaningful dialogue with CCHPBC regarding the upcoming Professional Standards and will continue to advocate with the Ministry of Health for the regulatory amendments it says it may consider “related to restricting TCM herbal formulae.”

Our position remains consistent: Chinese herbal formula prescribing should be connected to appropriate education, regulation, accountability, and public protection.

ATCMA will also provide members with information about what you can do to help protect the integrity of our profession and, most importantly, the public.

Stay tuned, and please contact ATCMA if you have questions about this issue. And, further, if you are not yet an ATCMA member, it’s time to join. We have work to do, and together we are stronger!



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