Why It Matters
The National Certification Commission for Acupuncture and Oriental Medicine (NCCAOM) wants to capitalize on a narrowing legislative window which would support acupuncture as a non-opiod pain solution and qualify for Medicare reimbursement.
The Acupuncture for Our Seniors Act of 2025 has bipartisan sponsorship and Congress is actively debating non-opioid pain solutions.
NCCAOM’s shift to specialized lobbying represents a critical strategic move in its decades-long push for federal recognition. The organization is transitioning from a generalist association management firm to Capitol Decisions Inc., a boutique healthcare policy practice led by lobbyist Holly Merbaum Strain, who brings nearly two decades of Medicare reimbursement expertise.
This change positions Strain’s track record representing healthcare systems and addiction treatment organizations provides experience directly applicable to framing acupuncture as a Medicare-covered provider service and opioid alternative.
Key implications:
- Medicare payment structure: Passage would authorize Medicare payments for qualified acupuncturists as practitioners, fundamentally altering reimbursement pathways
- Provider recognition: Federal recognition would legitimize acupuncture within integrated pain management frameworks
- Regulatory precedent: Medicare provider designation could influence state Medicaid programs and private insurers to expand coverage
By the Numbers
The National Certification Commission for Acupuncture and Oriental Medicine spent $326,666 on lobbying from April 2018 to May 2025 through SmithBucklin Corp., filing 31 disclosure reports during that period.
NCCAOM has now shifted to Capitol Decisions Inc., bringing on lobbyist Holly Merbaum Strain, whose nearly two decades of experience centers on Medicare and Medicaid reimbursement.
Strain earned $2.29 million over 17 years representing Texas Health Resources on Medicare issues, plus $1.24 million for the American Society of Addiction Medicine Inc. and $700,000 for the Hazelden Betty Ford Foundation on substance abuse treatment advocacy.
The Agenda
NCCAOM is lobbying to secure Medicare provider status for licensed acupuncturists by amending the Social Security Act to recognize its certified practitioners as Medicare providers, enabling direct billing to federal healthcare programs.
The organization’s core legislative target is the Acupuncture for Our Seniors Act of 2025 (H.R. 1667), which would formally define "qualified acupuncturists" and establish payment under the physician fee schedule.
Beyond Medicare coverage, NCCAOM advocates for acupuncture’s recognition as a non-opioid pain management alternative and expanded Veterans Affairs access. The shift to Capitol Decisions Inc. reflects a deliberate move toward specialized expertise in Medicare reimbursement policy and addiction treatment advocacy.
Broader Context
Congress is actively considering legislation aligned with acupuncture advocates’ objectives. The Acupuncture for Our Seniors Act of 2025, introduced by Rep. Judy Chu (D-CA-28) and Rep. Brian Fitzpatrick, would amend Medicare to recognize licensed acupuncturists as providers. The bill has bipartisan backing and reflects congressional interest in non-opioid pain management solutions.
Federal policy has moved toward integrating acupuncture into healthcare systems. The Veterans Affairs system has institutionalized acupuncture through its Whole Health initiative, and recent VA proposals would exempt acupuncture from copayment requirements.
The persistent opioid crisis continues driving federal interest in non-pharmaceutical alternatives, creating a policy environment receptive to therapies like acupuncture.
Between The Lines
Rep. Chu has actively championed the measure, highlighting it in her spring legislative update as key to ensuring seniors access effective chronic pain treatments. Meanwhile, Rep. Nanette Barragán (D-CA-44) has publicly recognized acupuncture’s value for delivering affordable care in underserved communities.
The Relief of Chronic Pain Act of 2025 (S. 3064) creates a supportive environment by expanding Medicare Part D access to non-opioid pain medications, strengthening the case for acupuncture coverage.
Competitive Landscape
Other healthcare organizations lobby on overlapping policy priorities in pain management and integrative medicine. Capitol Decisions Inc. represents organizations like the American Society of Addiction Medicine and Hazelden Betty Ford Foundation, which lobby on non-opioid pain solutions—areas adjacent to NCCAOM’s agenda.
Professional associations for chiropractors, physical therapists, and other non-pharmacological providers also seek greater federal recognition and reimbursement, sharing NCCAOM’s interest in positioning their services as Medicare-covered alternatives to opioid prescribing.
The Bottom Line
The National Certification Commission for Acupuncture and Oriental Medicine hired specialized healthcare lobbyist Capitol Decisions Inc. to pursue Medicare provider status.
The firm brings deep expertise in Medicare reimbursement and pain management policy directly relevant to advancing the Acupuncture for Our Seniors Act of 2025.
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