Letter to House of Representatives

 July 28, 2016

Dear Speaker DeLeo, Chair Dempsey, Vice Chair Kulik, Assistant Vice Chair Swan, Members of the House Ways and Means Committee, Chair Nangle, Vice Chair Koczera, Members of the House Committee on Steering, Policy and Scheduling,

We are writing on behalf of the International Association of Structural Integrators® (IASI) and the thirty Structural Integration professionals working in Massachusetts, regarding S2444, which may come before your committees.

We respectfully ask that you oppose this bill. If passed as written, S2444 will regulate several diverse professions under one license and do so inappropriately. Under this bill, professionals would lose their right to practice the professions in which they have trained, professions some of these practitioners have held for decades, and consumers would lose the services these practitioners offer. Stakeholders affected by this legislation have not been consulted. The language of the bill shows a disconnect between the reality of these professions and what is perceived to be useful and necessary. This bill should have a hearing before being taken up.

Before moving to specific problems with the S2444, we would like to introduce our profession and our organization to help you understand who we are:

Structural Integration is a manual therapy profession based on the work of Dr. Ida P. Rolf which works the connective tissue of the body to integrate and align the body in gravity. In addition to manual therapy, we utilize movement, verbal cues, and awareness education to improve mobility and reinforce proper alignment and function. We have our own schools, curricula, continuing education, certification board, and psychometrically valid certification exam.

IASI is the umbrella organization that includes Structural Integrators from every school of Structural Integration (SI). We have a Board made up of professionals representing a variety of SI modalities and have Bylaws, a Code of Ethics, a Scope of Practice for Structural Integration, and a Position Statement for the Appropriate Regulation of Structural Integration. We also offer professional insurance for our members and approved CE courses applicable to our profession. (www.theiasi.net) (See: Appendices for attachments of Bylaws, et al.)

IASI is a member of the Federation of Massage, Bodywork, and Somatic Practice Organizations, and we stand with our member organizations in opposing S.2444. http://www.federationmbs.org

Specific problems with the bill:

1. S2444 creates a bodywork board to oversee a "the practice of bodywork therapy". Bodywork is a general term. It does not refer to a specific profession. S2444 lumps several diverse professions under the title "bodywork therapy", which causes problems in so far as regulation for each of these professions needs to be considered separately in order to be appropriate, and yet, there is no provision in the bill recognizing that these are separate professions and no provision requiring the board to set regulations appropriate to the individual professions under the one title/license.

2. Under Section 110, the board is tasked with establishing standards for Continuing Education that reflects "acceptable national standards". Since there is no bodywork therapy profession and since several professions are lumped together under one licensing title, we are not sure to what national standards the bill refers: e.g., the standards for Structural Integration are not the same as any of the other professions listed in the bill.

3. Section 267 "(a) the board may issue a license to practice as a bodywork therapist to an applicant who... (v) has successfully completed a course of study consisting of at least 500 classroom hours or an equivalent number of credit hours of supervised instruction in a nationally accredited bodywork therapy program." There is no "nationally accredited bodywork therapy program".  Even if this provision in the bill were interpreted to refer to a nationally accredited program within each of our professions, such as Structural Integration, only one of IASI's seventeen approved schools is nationally accredited in the United States: the Rolf Institute for Structural Integration is accredited by COMTA. COMTA is too expensive for most schools, and adds the burden of requiring that our schools meet demands that have no applicability to our profession. Understand: this does not mean there is no oversight of our schools. Indeed, our organization, the International Association of Structural Integrators®, oversees and approves the schools for our profession.

There are currently seventeen IASI approved schools of Structural Integration worldwide. All of our foundation schools require between 730 and 2,100 hours of education for graduation. Eleven of these schools are in the United States. (http://www.theiasi.net/become-an-si-practitioner). Our schools are an elite few. They are small, have open communication with each other and with IASI, they are demanding, have low teacher to student ratios, have extremely high standards, and do not rubber-stamp candidates for admission or transfer.

Despite rigorous training, most Structural Integrators would lose their businesses in Massachusetts under S.2444 due to this requirement that they graduate from a nationally accredited school.

4. Section 269. "The board may grant a license to an individual who: (C) received a passing grade on a board-approved examination administered by a national organization or board accredited by the National Commission of Certifying Agencies or the Institute for Credentialing Excellence."

In 2008, the International Association for Structural Integrators® completed the process of developing and implementing the international certification exam for Structural integration that is both NOCA and ANSI certifiable. This is a psychometrically validated exam, developed under the direction of a professional Phsychometrist, Dr. Gerald A. Rosen, (drgeraldrosen.com). The Certification Board for Structural Integration® oversees implementation of the exam. The exam is the only professional certification exam for the Structural Integration profession; the only professional exam that can determine whether a professional meets the basic level of competency necessary to practice our profession. (http://www.theiasi.net/certification-board-for-structural-integration). Although The Certification Board for Structural Integration (CBSI) follows the guidelines of the Institute for Credentialing Excellence, however, it is not yet accredited by the ICE.

The important point for licensure is to ensure basic competency in the profession under consideration, and the CBSI fills this need. However, due to the requirement that a licensee pass an exam nationally accredited the ICE, most Structural Integrators would lose their businesses in Massachusetts under S.2444.

5. Section 272."(c) It shall be a violation of this chapter for a person to advertise: (iii) as specializing in particular bodywork therapy services without an appropriate showing of competency as determined by the board." Is this language referring to each of the individual professions listed under "bodywork therapy" as a "service" within the broader term of bodywork, or does this provision mean something else? Structural Integrators must be able to advertise that they practice the profession of Structural Integration, and we need to ensure that there isn't a second set of hoops to pass through after meeting requirements for the bodywork license in order to so advertise. We also want Structural Integrators to show proficiency in our profession without having to pass through bodywork license requirements that have no relation to Structural Integration.

6. Section 273. "A city or town may adopt ordinances or by-laws relative to health and safety of the practice of bodywork therapy not inconsistent with sections 265 to 272, inclusive." This provision may leave practitioners vulnerable to additional local regulation. It does say the ordinances and by-laws must be consistent with state law, but that may not preclude multiple regulations and burdens upon practices. It could use more clarity.

For these considerations, we respectfully ask that you oppose this bill. Our professionals would lose their businesses, and consumers would lose the services these practitioners offer. At the very least, we request a hearing on this bill before it is taken up.

For more information on IASI and the profession of Structural Integration, please read the Appendices to this letter, or you may call or email us directly.

Sincerely,

Denise Foster-Scott, BCSI
President, IASI

Deborah Nimmons, BCSI, JD
IASI Board of Directors
Chair, Law and Regulations Committee
[email protected]
206-910-1576

Appendix 1: IASI Scope of Practice for Structural Integration
Appendix 2: IASI Position Statement on appropriate regulation of Structural Integration
Appendix 3: IASI Code of Ethics


APPENDIX 1: IASI Scope of Practice of Structural Integration

DEFINITION OF STRUCTURAL INTEGRATION

A system to improve structural alignment and enhance ease of movement consisting of organized sessions of manual therapy of the fascial matrix, guided movement, and embodiment education.

SCOPE OF PRACTICE OF STRUCTURAL INTEGRATION

The practice of Structural Integration means the application of a coordinated system of manual therapy, guided movement, and embodiment education to the fascial matrix of the human body, including but not limited to:

  1. Assessment of all connective tissues and of global patterns of posture and movement;
  2. Organization of a session or series of sessions for treatment of those tissues and patterns;
  3. Manual therapy using anatomically precise directional touch combined with specific client movement, including all body parts accessible through the skin, as well as oral and nasal cavities; and
  4. Client education about body awareness and movement.

The practice of Structural Integration does not include:

  1. Massage for relaxation or stress reduction;
  2. High velocity joint manipulation;
  3. Diagnosis of illness or disease; or
  4. Prescription of medical therapeutic agents.

THE ORGANIZATION OF THE PROFESSION OF STRUCTURAL INTEGRATION

Structural Integration is based on the work of Dr. Ida P. Rolf, from which several related models for delivery of structural integration services have evolved..  Structural integrators are trained at structural integration education programs that meet the standards established by the International Association of Structural Integrators (IASI). Structural integrators demonstrate competence by passing the international certification examination administered by the Certification Board for Structural Integration (CBSI), certifying that they meet Core Competencies for Basic Structural Integration Practice. Board certified structural integrators must practice in accordance with IASI Code of Ethics and Standards for the Practice of Structural Integration.  To maintain the designation of Board Certified Structural Integrator (BCSI), structural integrators must meet CBSI's specific continuing education requirements of 72 hours every four years. Structural integrators adhere to ethical practice standards and contraindication protocols. Structural integration services are provided in partnership with clients of all ages in diverse settings such as private offices, ambulatory care and rehabilitation clinics, community health systems, homes, and hospitals and nursing care facilities.


APPENDIX 2: IASI Position Statement - Appropriate Regulation of Structural Integration

IASI Position Statement

 Appropriate Regulation of Structural Integration

In response to the high prevalence in the United States of America of required state authorization to practice structural integration coupled with use of inappropriate standards in existing law and regulation for structural integration education, practice, and competency assessment, The Board of Directors of the International Association of Structural Integrators offers this policy guidance for legislators, regulators and other consumers

  1. Structural integration is a distinct, specialized bodywork discipline with a unique scope of practice.
  2. Appropriate regulation of structural integration protects the public from unsafe and unqualified practitioners.
  3. Professional licensure boards can appropriately regulate structural integration practitioners, provided that regulations incorporate professional standards, educational requirements (initial and continuing), and competency assessment specific to the discipline of structural integration.
  1. Safe practice of structural integration is assured by:
  • professional practice standards and defined scope of practice
  • professional standards for basic education
  • competency determination by examination
  1. The safe practice of structural integration requires demonstrated competency in:
  • visual assessment of global postural and movement patterns
  • manual assessment of fascial and myofascial tissues
  • manual therapy skills and movement education skills
  • organizing a series of individualized sessions, based on the work of Dr. Ida P. Rolf, to increase clients' capacity for efficient, comfortable movement
  • adherence to ethical and contraindication protocols

APPENDIX 3: IASI Code of Ethics & Standards of Practice Document

IASI Code of Ethics &

 Standards of Practice Document

Introduction

The IASI Code of Ethics is not meant to preclude any professional ethics code of any other individual or collective group, representing any faction of Structural Integration operating in the tradition of Ida P. Rolf, Ph.D.  It is instead the general ethics code of IASI and is meant to offer a basic set of boundaries and principles as a guide to acceptable conduct. Ethical behavior is necessary to remain a member in good standing of the IASI.

This Code offers guidance for professional conduct and a vehicle for the assessment and appraisal of situations having ethical implications.  This Code also is offered as a guide and an affirmation of the will of the IASI membership and is intended to protect their best interests and reputation while insuring the highest quality professional service to all of their clients.

IASI Code of Ethics

Client / Practitioner Relationship

IASI members are entrusted with the responsibility of creating an environment that allows the Structural Integration Client to have a rewarding and positive experience.  IASI members will:

1. Ensure client safety, protecting them from unreasonable physical and emotional risk,
2. Enable and empower all clients in their growth and evolutionary process with empathy, dignity and caring,
3. Never discriminate against anyone in providing Structural Integration services because of race, creed, sex, sexual orientation, national origin or disability,
4. Engage only in honest and fair business practices,
5. Ensure that all Structural Integration practice is conducted in an alcohol and drug free environment,
6. Avoid all sexual relationships with clients
7. Never engage in sexual harassment of any kind or create a sexually intimidating or offensive environment. 

Standards of Practice

All IASI members have a duty to adhere to the IASI Standards of Practice. IASI members will:

  1. Only provide Structural Integration services for which they were properly trained, have proven competency and are recognized by their peers as capable to provide such services in the scope of their practices,
  2. Accurately and truthfully represent IASI policies, actions and procedures,
  3. Use the established IASI ethics procedures to resolve all complaints of conduct regarding charges from a client or charges between members,
  4. Ensure client confidentiality and never breech the confidence of IASI, its Members or clients,
  5. Never misrepresent themselves through information which is based on falsifications regarding accomplishments, qualifications, education, experience, certifications, licenses or criminal records.
  6. Never misrepresent the nature and scope of their Structural Integration practice,
  7. Provide clarity for clients, peers and public, by initiating the Structural Integration process with reference to the standard ten session series as a tradition inherited from Ida P. Rolf,
  8. Seek advice and counsel of peers and other professionals whenever it is in the best interest of their clients.

Practitioner Conduct

All members of IASI are to be in compliance with all national, regional and local criminal codes.  No member may have a felony criminal history.  This includes any felony conviction resulting from entering a guilty plea, being found guilty by jury or judge or entering a no contest plea.

Development

Members of IASI should strive to increase their competency, skill and proficiency in the craft of Structural Integration. Members must take responsibility for remaining current on safety, health and developments that are relevant to the practice of Structural Integration. Members should accomplish this through participation in the following continuing education programs:  

  1. Clinics and seminars conducted by IASI,
  2. Programs conducted by or approved by the members individual parent educational institutions,
  3. Continuing education offered by other Structural Integration schools recognized and approved by IASI,
  4. Continuing education offered by other organizations recognized as meeting the continuing education requirements by IASI.

Conflict of Interest

Members are responsible for avoiding conflicts of interest, both actual and perceived, while acting in a business capacity for IASI. It is unethical for any member to: 

  1. Achieve personal gain by using IASI services, their position in office, or authority inherent or implied or associated with their elected or appointed position in IASI,
  2. Incur unsubstantiated, unnecessary and/or unreasonable debt in the name of or while representing IASI,
  3. Participate in any decision-making mechanism within IASI that would result in their immediate of future personal gain.  

Enforcement of the Code

Enforcement of the IASI Code of Ethics depends on voluntary compliance peer involvement, client participation and the support of all members. 

  1. Voluntary Compliance
    1. Any member who believes that another member has violated the IASI Code of Ethics, unless extraordinary circumstances dictate otherwise, should first address the concern directly with that member.  The respondent member should comply completely to the satisfaction of the complainant member. A member of the Standards and Ethics Committee may be sought for a consultation and/or negotiation role in this part of the process.
    2. Any member in personal ethical conflict is required to seek advice and counsel of a peer and/or the IASI Standards and Ethics Committee.
    3. Peer Involvement.
      1. Any member, who after addressing an Ethics concern directly to another member with unsatisfactory results, is obligated to file a signed, written complaint with the IASI National Headquarters and cooperate fully with all subsequent investigations.
      2. All members will cooperate fully with any investigation.
      3. Client and Member Participation
        1. Any client, member or person outside of IASI, may file an ethics complaint. 
        2. All written and signed complaints will be handled personally by the Executive Director, or his or her assigned representative, according to the IASI Bylaws.
  1. Before a complaint if sent to the Standards and Ethics Committee, all procedures will be explained to the complainant, both verbally and in writing.
  2. Both complainant and respondent will be supported by all staff and Committee members. 
  3. Negotiation to a conclusion will be pursued initially when deemed appropriate by the Committee
  4. At the end of the investigation, when necessary and appropriate, the Committee will present a detailed report, including recommendations, to the Board of Directors for final disposition.
  5. All appeals will be made directly to the President of the IASI Board of Directors. 

IASI International Association of Structural Integrators
2150 N 107th Street | Suite 205 | Seattle, WA | 98133
[email protected] |1-855-253-IASI (4274) | www.theiasi.net

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