How to judge training when no state licenses the practice

Four practitioners can each say they’re certified, and mean four very different things. One completed 800 hours of herbal education and documented 80 clients over five years before colleagues reviewed the cases. One logged 50 coaching sessions and then passed a 150-question exam run jointly with the National Board of Medical Examiners. One completed 500 hours of clinical observation for a homeopathy credential. And one finished three levels of Reiki training and was certified as a master by the person who taught the course.

None of them holds a state license for that work, because no state licenses these practices the way most states license acupuncture or massage. In these fields, the training and whatever private body certifies it are the only checks there are. Sometimes the person who sold the course is also the person who issued the certificate.

This article is about judging that training: the practices nobody licenses, the different ways they train and certify people, what an hours figure can and can’t tell you, and what to ask. The five licensed modalities, with their accredited schools and board exams, are mapped in a companion article on licensed credentials. Decoding the letters after a name is a job for the library’s credential primer. This piece starts where both of those run out.

Sorting unlicensed credentials into the four buckets

This library sorts every credential into one of four bins: defined in regulation, government certification, private third-party certification, or undefined. For licensed professions most credentials land in the first. For the practices covered here, almost nothing does.

Defined in regulation. Close to empty, and misleading where it isn’t. According to a National Center for Complementary and Integrative Health page last updated in April 2021, Arizona, Connecticut and Nevada are the only states with homeopathic licensing boards for medical doctors, and in some states people without any health license may practice homeopathy. Washington requires hypnotherapists who charge a fee to register with the state, yet sets no education or examination requirement for them; the library’s hypnosis article walks through that registration. Minnesota and Rhode Island go further and make unlicensed practitioners state in writing that the state has adopted no educational or training standards for them. The disclosure laws behind that sentence are the subject of the companion piece on consent forms.

Government certification. None found that is current. Indiana once offered one. Rules published under its administrative code describe how a hypnotist committee of the state’s medical licensing board certified hypnotists by examination; they were filed in 2000 and readopted in 2006. A note on the Legal Information Institute’s copy of those rules says the enabling statute was repealed effective July 1, 2010. That couldn’t be confirmed on an Indiana government site, so treat it as reported, but it shows that a government credential can disappear.

Private third-party certification. This is where the serious credentials in these fields live: the National Board for Health and Wellness Coaching, the American Herbalists Guild, the Council for Homeopathic Certification and several hypnosis bodies, each examined below. All are private. None is a license.

Undefined. Reiki levels and master titles, qigong teaching certificates, and most energy-healing and sound-healing certificates. NCCIH’s qigong page, last updated in February 2022, says instructors don’t have to be licensed, the practice isn’t regulated by federal or state governments, and there’s no national standard for qigong certification. Sound-healing certificates, some earned through less than three hours of video, come up in the sound wellness article.

The buckets aren’t fixed. Minnesota, whose only massage rules came from its general law on unlicensed practitioners, enacted a 2026 law creating optional state registration for massage therapists and Asian bodywork therapists. From January 1, 2028, only registered practitioners may call themselves a registered massage therapist or registered Asian bodywork therapist, or use the abbreviations RMT and RABT. Unregistered practice stays legal under the older law, so the title, not the work, is what moves. A practice can shift partway from the undefined bin toward a regulated one, and when it does, the questions worth asking change.

Three ways unlicensed practices train people

Look past the names and most training in these fields follows one of three models. Knowing which one you’re looking at tells you what kind of check, if any, stood behind the certificate.

Lineage: the teacher certifies the student

Reiki is the clearest example. Researchers describing it in The Permanente Journal in 2011 wrote that training moves through levels I, II and III to a master practitioner level. A 2014 case report in the journal Explore defined a Reiki master as someone who has completed all three levels and who trains and certifies others. Read those two descriptions together and the structure is plain: the person qualified to certify you was certified by someone of the same kind. No outside body writes the curriculum or tests the result.

NCCIH’s Reiki page, last updated in December 2018, says nothing about training, levels or certification at all.

Few studies have tried to measure what the training produces. One that did, a small 2002 trial led by Samuel Shiflett in the stroke unit of a rehabilitation hospital, trained practitioners in a way that kept them blinded to whether they had received real Reiki training or a sham version. Afterward, neither group could tell which category they belonged to. Sham practitioners reported feeling heat in their hands more often than the real ones, and the two groups reported no difference in sensing energy flowing through their hands. That doesn’t settle whether Reiki helps patients, a different question weighed in the Reiki article. It does show how hard it is for anyone, the trainee included, to check what the training conferred.

Peer review: colleagues judge your cases

The American Herbalists Guild’s Registered Herbalist designation, abbreviated RH (AHG), uses a different model. Its applicant criteria, revised in August 2026, require at least 800 hours of education in clinical herbalism, of which no more than 40 may be botany. Up to 600 hours may be documented independent study, but mostly self-taught applicants also need 200 hours of supervised clinical training.

The clinical requirement is the heavier one. Applicants must show at least 80 individual clients over five years as the primary practitioner, each with a full intake and two follow-ups, and supervised cases can cover no more than 30 of those. Two letters of recommendation must come from qualified clinical herbalists, not friends or colleagues with less experience. The Guild describes the whole process as a rigorous peer-review application. Its pages don’t describe a written exam.

One detail on the Guild’s site is worth knowing before you pay any herbal school. Its directory of schools says a listing is offered only as a reference and does not mean the Guild endorses the content or quality of any program. A school saying its curriculum matches the Guild’s standards is making its own claim.

This review found no state that licenses herbalists. Minnesota’s disclosure law lists herbalism among the unlicensed practices it covers, which points the same way.

Examination: someone else writes the test

Homeopathy and hypnosis lean on exams. The Council for Homeopathic Certification awards the CCH credential. Its website, which still displays exam windows from 2016 and 2017, says that beginning in January 2016 the council required 500 hours of training in clinical observation and case analysis before awarding the credential, supervised by holders of specified homeopathic credentials. Because the page looks dated, confirm current requirements directly before relying on them.

Arizona shows a state leaning on private bodies. On a page about homeopathic practitioner licensing, its homeopathic board lists approved accrediting bodies, including the Accreditation Commission for Homeopathic Education in North America, and approved exams, including the CCH exam. It says that as of March 11, 2025, it approved another private exam, the HPLEX, as Arizona’s licensing exam. The page doesn’t say who may sit for it. No page found shows that the homeopathic education commission is recognized by the Department of Education or its private counterpart.

In hypnosis, the American Council of Hypnotist Examiners offers a Certified Hypnotic Coach credential. As described in the Labor Department’s O*NET certification listing, it requires at least 200 hours of instruction from a school approved by the appropriate state agency and by the council, plus written and practical exams, with renewal every two years. If a hypnotist mentions state approval, ask which agency approved what. Approval of a school is not a license for the people it graduates.

Compare the clinician route. The Society for Clinical and Experimental Hypnosis certifies clinical hypnosis only for people who already hold a license for independent clinical practice in a health profession. On top of that license, it requires 70 hours of training within five years, including ethics and research, and two years of experience. Its credential is abbreviated CCH too. Same three letters as the homeopathy council’s, entirely different meaning, so ask which one.

The middle case: health and wellness coaching

Coaching is the one field here with a national exam built like a professional board exam, and it’s worth seeing why that matters.

The National Board for Health and Wellness Coaching runs its exam jointly with the National Board of Medical Examiners. According to the 2026 exam information packet, candidates must finish an approved training program and pass a practical skills assessment in it. They must then log 50 qualifying coaching sessions dated after that assessment; sessions with friends, family or classmates don’t count. The exam itself is 150 multiple-choice questions, taken at testing centers. Keeping the credential requires an annual fee and 36 hours of continuing education every three years.

The training standard behind it is built around being watched. The board’s program approval handbook, updated in October 2024, sets a floor of 75 instructional hours, most of the core content taught live by faculty rather than by recorded video. Each student must complete three full practice coaching sessions of at least 30 minutes, and after each one a faculty member spends 20 minutes or more giving feedback. The final practical skills assessment, graded pass or fail, comes only after 80 percent of the program is done.

The exam content wasn’t invented by a single school either. A 2016 job task analysis led by Ruth Wolever, published in BMC Health Services Research, used a panel of 15 experts to identify 21 tasks essential to coaching, then surveyed coaches about them. Of the 1,031 people who responded, 885 were practicing coaches, and their ratings were used to weight the tasks as a foundation for a national certification exam. That’s what it looks like when someone other than the teacher defines competence.

It still sits in the private bucket. The credential is voluntary and isn’t a state license. The program approval handbook doesn’t describe approval as accreditation, and nothing read claims the credential itself is accredited. The entry bar isn’t high, either: an associate’s degree, or 4,000 hours on the job in any line of work. What coaches may and may not do once certified is spelled out in our health coaching guide.

Why call it the middle case? Because it has the parts the other models lack: an observed skills test, logged real-world practice with rules about who counts, an exam written apart from the training school, and renewal. A field nobody licenses can still build those. Most haven’t.

What an hours figure can and can’t tell you

Training hours are the number practitioners most often advertise, and the one most easily misread. Here are the figures from the bodies above:

• Health coaching: a 75-hour minimum program, then 50 logged sessions and an exam
• Clinical hypnosis through the professional society: 70 hours, on top of a health care license and degree
• Hypnotic coach certification: 200 hours, plus written and practical exams
• Homeopathy certification: 500 hours of clinical observation and case analysis, per a dated page
• Registered herbalist: 800 hours, plus 80 documented clients

The smallest number on that list, 70 hours, may represent the most total training, because it sits on top of a full clinical education. The hours aren’t the same kind of hour, and they can’t be compared directly.

There’s a second problem. Hours are usually reported by the practitioner to the body that certifies them. Unless that body checks transcripts or supervisors, nobody outside verifies the number. The Guild’s criteria let up to 600 of its 800 hours come from documented independent study, which is a legitimate route and also one that depends heavily on the applicant’s own records.

No study or regulator finding was located measuring how often hours claims in these fields are inflated. The useful move is to stop asking how many hours and start asking what was observed and assessed by someone other than the teacher.

Try it on a typical bio line: trained in energy healing, 300 hours, certified practitioner. Three follow-ups turn that into information. Hours of what, classroom, reading or supervised sessions with real clients? Certified by whom, the school that sold the course or a body that sets its own standard? And did that body ever see the practitioner work, or only the paperwork?

Checking the accreditor behind a certificate

When a program says it’s accredited, the next question is accredited by whom. The U.S. Department of Education states plainly, on a page last reviewed in April 2025, that the Secretary and the Department are not responsible for accrediting colleges. Accrediting agencies do that work, and the Department says an accreditor without its recognition deserves caution until its reputation is known.

The Federal Trade Commission’s guidance on fake degrees, dated January 2005, warns that many diploma mills claim accreditation from bogus but official-sounding agencies they invented. That guidance was written for employers checking academic degrees, not for consumers judging health certificates. The warning applies by analogy, and only by analogy.

None of the bodies discussed here claimed Department of Education or Council for Higher Education Accreditation recognition on the pages read. Approved and certified don’t mean accredited. Checking an accreditor’s own standing takes about ten minutes, and the library’s accreditation explainer gives the steps.

Questions about the training itself

NCCIH’s general advice on choosing a complementary practitioner is to find out as much as possible about education, training, licensing and certification, and it notes that required credentials vary enormously from state to state. The questions below turn that advice into something you can ask on a first call. They target the training rather than the letters, so they work even when no license exists.

1. Who wrote the curriculum, and can I see it? A program with nothing to show has nothing to compare.
2. Did anyone other than your teacher watch you work with a real client and grade it? The coaching board’s practical skills assessment is one model of what that looks like.
3. How many clients have you seen since finishing, and in what setting? The Guild’s 80-client threshold gives you a sense of scale.
4. What did your training say you must not do? Good programs teach limits: no diagnosing, no advice about prescriptions, clear points for referral.
5. Does anyone ever fail your program, or lose the credential? A credential nobody fails isn’t testing much.
6. Who could I complain to about you, other than you? In the undefined bucket, the honest answer is sometimes no one. In Minnesota, Rhode Island and New Mexico, though, a state office takes complaints even about unlicensed practitioners.

When a training question becomes a health question

No certificate in these fields covers diagnosing a disease or managing prescriptions. In California, Minnesota and New Mexico, statutes bar unlicensed practitioners from recommending that you stop prescribed medicine, and Minnesota and New Mexico also bar them from giving a medical diagnosis. If a practitioner offers to treat a diagnosed condition in place of your clinician, comments on your prescriptions, or discourages you from telling your doctor, the question has moved past training. That conversation belongs with a licensed clinician, and the clinician who prescribed a medicine is the one to ask about any change to it.

For hypnosis aimed at a medical or psychological problem, NCCIH’s cancer guidance calls the technique safe in the hands of a trained, experienced and licensed health professional. That is a reason to know which kind of certificate your hypnotist holds. For herbalism, the risk sits in the products as well as the practitioner. Whatever an herbalist recommends belongs on the list you share with your clinician and pharmacist, for reasons the library’s coverage of supplement disclosure explains.

The Takeaway

In practices no state licenses, a credential tells you which model of training someone went through: a teacher’s lineage, a peer review of real cases, or an exam written by someone else. Each model suggests its own follow-up. For a lineage credential, ask who trained the teacher and what, if anything, was ever tested. For a peer-reviewed one, confirm the registration with the body itself. For an exam-based one, find out who wrote the exam and whether people fail it.

The single most revealing question is the same across all of them. Ask who, other than the person who taught them, ever checked their work.

Sources

1. National Center for Complementary and Integrative Health, National Institutes of Health. “Homeopathy (content Last Updated April 2021; state regulation of homeopathy practice).” nccih.nih.gov
2. Washington State Legislature. “RCW Chapter 18.19, Counselors (18.19.035 hypnotherapist registration; 18.19.090 application requirements).” app.leg.wa.gov
3. Legal Information Institute, Cornell Law School (mirror of the Indiana Administrative Code). “844 IAC 12-3-2, hypnotist certification by examination, with note that IC 25-20.5-1 was repealed by P.L. 84-2010 effective July 1, 2010.” law.cornell.edu
4. National Center for Complementary and Integrative Health, National Institutes of Health. “Qigong: What You Need To Know (content Last Updated February 2022).” nccih.nih.gov
5. National Center for Complementary and Integrative Health, National Institutes of Health. “Reiki (content Last Updated December 2018).” nccih.nih.gov
6. The Permanente Journal. “Mehl-Madrona L, Renfrew NM, Mainguy B. "Qualitative Assessment of the Impact of Implementing Reiki Training in a Supported Residence for People Older Than 50 Years with HIV/AIDS." Perm J, 2011. PubMed. DOI: 10.7812/TPP/10-152.” pubmed.ncbi.nlm.nih.gov
7. Explore. “Bukowski EL, Berardi D. "Reiki brief report: using Reiki to reduce stress levels in a nine-year-old child." Explore (NY), 2014. PubMed. DOI: 10.1016/j.explore.2014.02.007.” pubmed.ncbi.nlm.nih.gov
8. Journal of Alternative and Complementary Medicine. “Shiflett SC, Nayak S, Bid C, Miles P, Agostinelli S. "Effect of Reiki treatments on functional recovery in patients in poststroke rehabilitation: a pilot study." J Altern Complement Med, 2002. PubMed. DOI: 10.1089/10755530260511766.” pubmed.ncbi.nlm.nih.gov
9. American Herbalists Guild. “AHG Registered Herbalist (RH) Applicant Criteria (Revised August 2026).” americanherbalistsguild.com
10. American Herbalists Guild. “Becoming a Registered Herbalist.” americanherbalistsguild.com
11. American Herbalists Guild. “Directory of Schools (listing disclaimer).” americanherbalistsguild.com
12. Council for Homeopathic Certification. “CCH certification requirements (page displays 2016 and 2017 exam windows).”
13. Arizona Board of Homeopathic and Integrated Medicine Examiners. “Homeopathic Practitioner Licensing (approved accrediting bodies and exams; HPLEX approved March 11, 2025).” homeopath.az.gov
14. O*NET OnLine, sponsored by the U.S. Department of Labor. “Certification listing: Certified Hypnotic Coach, American Council of Hypnotist Examiners.” onetonline.org
15. Society for Clinical and Experimental Hypnosis. “Certification in Clinical Hypnosis (CCH) Application.” sceh.us
16. National Board of Medical Examiners and National Board for Health & Wellness Coaching. “NBHWC Board Exam Information Packet, 2026.” nbme.org
17. National Board for Health & Wellness Coaching. “Program Approval Handbook (Updated October 2024).” nbhwc.org
18. BMC Health Services Research. “Wolever RQ, Jordan M, Lawson K, Moore M. "Advancing a new evidence-based professional in health care: job task analysis for health and wellness coaches." BMC Health Serv Res, 2016. PubMed. DOI: 10.1186/s12913-016-1465-8.” pubmed.ncbi.nlm.nih.gov
19. U.S. Department of Education. “Diploma Mills and Accreditation (last reviewed April 24, 2025).” ed.gov
20. Federal Trade Commission. “Avoid Fake-Degree Burns By Researching Academic Credentials (business guidance, January 2005).” ftc.gov
21. National Center for Complementary and Integrative Health, National Institutes of Health. “6 Things To Know When Selecting a Complementary Health Practitioner (undated).” nccih.nih.gov
22. National Center for Complementary and Integrative Health, National Institutes of Health. “Cancer and Complementary Health Approaches: What You Need To Know (content Last Updated October 2021).” nccih.nih.gov
23. Minnesota Office of the Revisor of Statutes. “Minn. Stat. 146A.01, Definitions (22 listed practices; exclusions; no medical diagnosis or recommending discontinuance of prescribed treatment).” revisor.mn.gov
24. Minnesota Office of the Revisor of Statutes. “Laws of Minnesota 2026, Chapter 115 (optional registration for massage therapists and Asian bodywork therapists; protected titles RMT and RABT effective January 1, 2028; unregistered practice not prohibited; related 146A provisions effective July 1, 2028).” revisor.mn.gov
25. State of Rhode Island General Assembly. “R.I. Gen. Laws 23-74-14, Unlicensed health care client bill of rights (P.L. 2002, ch. 133).” webserver.rilegislature.gov
26. New Mexico Legislature. “House Bill 664 (2009), Unlicensed Health Care Practice Act, final text, effective July 1, 2009.” nmlegis.gov
27. FindLaw, mirror of the California Business and Professions Code (current as of January 1, 2026). “Cal. Bus. & Prof. Code 2053.5.” codes.findlaw.com