When Food Becomes “Out of Scope”: What the Latest CCHPBC Update Means for TCM in BC

Today, the College of Complementary Health Professionals of BC released a clarification on scope of practice for Traditional Chinese Medicine and Acupuncture (TCMA) licensees—specifically around dietary guidance and food cure recipes. While the College states that the scope itself has not changed, the interpretation has significant real-world implications for how many practitioners—paricularly R.Ac.s—can support their patients.

What the Update Says

According to the CCHPBC:

• Dietary guidelines—general advice based on TCM principles like flavour, thermal nature, and function—are within scope for all TCMA licensees, including acupuncturists.
• Food cure recipes, however, are not within scope for acupuncturists.
  These are defined as therapeutic applications of food involving:
  • Specific combinations
  • Quantities or dosages
  • Preparation methods
  • Use of foods as treatment (similar to herbal formulas)

Only TCM Herbalists, TCM Practitioners, and Doctors of TCM are considered to have entry-level competencies for this level of practice.

Why This Matters

This distinction may sound technical—but in practice, it creates a very restrictive boundary.

Under this interpretation, something as simple and time-honoured as recommending:

• “Take 1 Tbsp of honey in warm water twice daily,” or
• “Steam 1 pear with 1 Tbsp honey and take once a day for cough”

could be considered outside an acupuncturist’s scope—because it includes dosage and preparation.

That raises serious questions:

• Can an R.Ac. safely provide meaningful, practical dietary advice without crossing into “recipe” territory?
• Are we expected to stay at the level of “eat more warming foods” without actionable guidance?
• Are practitioners even allowed to share external resources (books, websites) that include recipes and dosages? We’ve asked that question and have been told the college will get back to us.

The fact that these questions now require clarification highlights just how unclear—and arguably impractical—this interpretation is.

A Bigger Issue: The Role of Food in TCM

Food therapy—often referred to as food cures—is not an “advanced add-on” in Traditional Chinese Medicine. It is a foundational pillar of the medicine.

All TCM-trained practitioners, including R.Ac.s, receive education in:

• The energetic properties of food
• Clinical application of diet in pattern differentiation
• The integration of food in treatment strategies

Separating “guidelines” from “recipes” in such a rigid way risks reducing TCM dietary therapy to vague, non-clinical suggestions, stripping it of its effectiveness.

A Stark Contrast in Regulatory Approach

At the same time, other professions in BC are seeing softened scopes based on practitioner competence rather than rigid categories.

For example, College of Naturopathic Physicians of British Columbia registrants (NDs) used to have to provide evidence of specific certification for the following therapies:

• Acupuncture
• IV therapies (including chelation)
• Advanced injection therapies
• IUD insertion and removal
• Ozone and oxidative therapies

These are now generally permitted with the expectation that each naturopathic licensee will self-regulate based on their training and competence. As stated via the link to “Additional Training for Previously Certified Practice Areas: Naturopathic Medicine”:  “Licensees may practise within these previously certified areas provided the activities fall within the naturopathic medicine scope of practice and the licensee meets all applicable professional and clinical practice standards… In the event of a concern or complaint, the College will assess a licensee’s practice based on whether professional and clinical practice standards were met and whether the licensee demonstrated appropriate knowledge, skill, and clinical judgment in the care provided. Licensees are expected to continue exercising professional judgment and self-assessing competence when deciding whether to engage in any area of practice.”

Meanwhile, TCM acupuncturists—who are trained in food therapy—may be restricted from recommending specific amounts of honey, ginger, turmeric, cinnamon, or green tea.

That contrast is difficult to ignore.

Why ATCMA Advocacy Matters

This is exactly why being a member of the ATCMA matters.

ATCMA is actively advocating to:

• Expand scope of practice to reflect real-world training and competencies
• Include “Design a Therapeutic Diet” as a recognized restricted activity for TCMA licensees
• Ensure that regulations support—not hinder—effective, patient-centered care

We are also working to ensure that TCM is treated with the same respect and regulatory logic applied to other healthcare professions: trusting practitioners to work within their training and competence, rather than restricting care based on overly narrow definitions.

A Call for a Unified Voice

Regulatory change does not happen in a vacuum. It requires:

• Clear evidence
• Consistent messaging
• And most importantly—a strong, unified profession

ATCMA can only advocate on behalf of its members. The larger and more engaged our membership, the more influence we have in shaping the future of TCM in British Columbia.

If you believe that:

• Food therapy is a core part of TCM
• Patients deserve practical, actionable care
• Practitioners should be trusted to use their training responsibly

then your voice matters—and it’s stronger as part of a collective.

What Comes Next

We are continuing discussions with the CCHPBC to seek clarification on:

• Whether sharing third-party resources (books, websites) is permitted
• How “dosage” is being interpreted in everyday practice
• Pathways to modernize scope in a way that reflects actual competencies

We will keep members updated as we learn more.

TCM is a complete medical system, not a collection of disconnected parts.
When foundational practices like food therapy are restricted, it impacts not just practitioners, but the quality of care patients receive.

ATCMA remains committed to ensuring that TCM professionals in BC can practice to the full extent of their training—safely, responsibly, and effectively.