On December 12, less than 24 hours after a compliance hearing before the NACIQI, an email was sent out to AVMA members. It displayed no COE logo, only the AVMA logo (the old one; not the new one). It was sent out with one name on the bottom of it, that of Fred Derksen, chair of the AVMA’s Council on Education.
Eden was present at the hearing as a third party commentor. There is a significant discrepancy between the tone and content of the memo and the facts of the situation as well as her experience at the hearing.
The text of the memo is in AVMA green. Our analysis is in black.
The AVMA Council on Education (COE) recently participated in an accreditation renewal hearing with the National Advisory Committee for Institutional Quality and Integrity (NACIQI) of the U.S. Department of Education (USDE). This hearing was part of a routine assessment process conducted by the USDE with all of its accrediting bodies.
The AVMA and COE “participated” in the recent hearing much as parolees “participate” in a hearing before their parole board. At their last regularly scheduled review in December 2012, when they should have been able to have their recognition renewed for five years, the AVMA and COE were found non-compliant with fourteen federal criteria for recognition. This resulted in the COE needing to appear again before the committee not in five years, but in one. The hearing December 11 was AVMA and COE’s chance to prove compliance.
The NACIQI will forward a recommendation to the Undersecretary to grant the Council 6 months to one year to come into compliance with five remaining recognition criteria. This along with the staff analyst’s recommendation will be forwarded to the Undersecretary , who will make the decision regarding continued recognition of the AVMA COE.
NACIQI voted, on staff recommendation, to give separate 6 month and 12 month time periods to satisfy separate counts of noncompliance.
Six months was granted on the remaining counts of non-compliance from 2012. The staff stated at the hearing this time was recommended because the agency had worked in good faith to resolve many of the original counts. Committee members questioned the utility of doing this, commenting that in six months the agency was likely to be in the same position, with the issues unresolved ad many more critical commentors. The committee also questioned why staff had not discussed limiting the agency’s ability to operate during the six months. The implication was clear that at least those committee members making the comments thought the situation warranted ending or limiting the agency’s recognition on the spot. This is not mentioned in the AVMA memo.
An additional count of noncompliance with criteria §602.13 (b), requiring wide acceptance by practitioners, was recommended by USDE staff based on the overwhelming volume and content of critical letters received. The staff recommended, and the committee approved, giving the agency 12 months to come into compliance on this new count of non-compliance. The committee questioned why USDE staff had recommended 12 months; staff replied that even though it was a new finding when the agency was still non-compliant from a year prior, since the agency was working in good faith, and this was a type of non-compliance issue that would take any agency time to resolve, the standard operating procedure recommendation of 12 months was still warranted. The fact that this was a new count of non-compliance is not mentioned in the AVMA memo.
At the hearing itself, yet another new count of non-compliance was proposed and unanimously approved by the committee itself. The committee found the agency noncompliant with §602.15 (6), requiring effective controls against conflict of interest. This was based on the revelation that two COE members had been thrown off the Council for conflict of interest, yet the agency had not mentioned this in any of its submissions to NACIQI, could not provide documentation of its policy for removing Council members, nor provide a satisfying verbal explanation of why the members had been removed. This was not a remaining violation of federal criteria, but a totally new one, and one about which multiple committee members made statements of serious concern. No time frame was explicitly assigned at the hearing for coming into compliance on this additional new count
None of this is described or referenced in the AVMA memo.
Several experts and stakeholders testified in support of COE, including Dr. Trevor Ames, dean... and president of AAVMC; Dr. Sheila Allen, dean...; Dr. Cyril Clarke, dean...; Dr. Jeff Klausner, Chief Medical Officer, Banfield...; Dr. Joan Hendricks, dean...; Dr. Kent Hoblet, dean...; Dr. Deborah Kochevar, dean...; Dr. Michael Lairmore, dean...; Dr. Phil Nelson, dean...; Dr. Jeffery Newman, president of the Virginia VMA; and Mark Cushing, JD, Animal Policy Group. ...We also appreciate the support from our members and veterinary professionals... The NACIQI also heard testimony from veterinarians critical of the COE’s role as an accreditor.
In this letter, the AVMA describes at length the names and credentials of those making positive comments, referring to them as “experts and stakeholders,” including non-veterinarian, Mark Cushing. It notes the existence of those making critical comments with no enumeration of credentials or position, describing them with the single word “veterinarians.”
The memo refers to AVMA enjoying the support of veterinary professionals. NACIQI received 98 letters in support of AVMA- approximately a third from sitting deans, many of whom were also third party commentors. There is no mention that over 800 veterinarians wrote in opposition to the COE.
This is inconsistent with AVMA’s oft repeated claim of wanting to be a science based organization, and its claim to be the one voice of the profession. It is inconsistent with a COE or an AVMA that is accountable to the whole profession.
Answering a question from NACIQI member Simon Boehme, a student at Dr. Derksen’s alma mater Cornell, Dr. Derksen stated categorically there was no culture problem present at the COE.
This is inconsistent with the content of the over 800 letters received from practitioners, reporting a widespread perception of the CEO as an insular body whose processes and standards are heavily influenced by the agenda of a specific, small group of people- the deans, AVMA staff and AVMA political leaders.
We have learned from this experience, and look forward to working with our members and colleagues to uphold professional standards and preserve the integrity of the veterinary professional degree.
Based on the tone and content of this memo, the AVMA has learned very little.
Dr. Derksen, on behalf of the COE, and Dr. Andy Mccabe, on behalf of the AAVMC, agreed to a listening session immediately after the hearing. The proposed meeting was NAVC 2015; the CEO of NAVC, contacted the night of the hearing, pledged full support- and backed it up by making a meeting room, hotel rooms and plane tickets available within 24 hours of the request.
The meeting was cancelled as third party commentors refused to attend. It would seem likely this memo was such a discrepancy from what was said to, and by, Dr. Derksen at the hearing that it was impossible to trust that the COE and AVMA would listen.
The end goal here is a COE accountable to all, beholden to none. To achieve this, we are going to have to separate COE from AVMA, because an accrediting agency and a trade association have mutually incompatible purposes. Hopefully the current leadership of the AVMA will not destroy the association fighting this separation.
Regardless of how that fight goes, we are going to have to educate an entire profession on what accreditation is, what it is for and how it is done. We need to create a community knowledgeable about accreditation to sustain a competent accrediting agency.
As an employer, accreditation provides you with peace of mind that your associates possess the knowledge and clinical competence to provide high-quality care for your practice’s clients and patients.
Many employers complain that their new graduate associates are not ready for clinical practice.
Accreditation requires NO assessment of individual students’ knowledge or clinical competence. In fact, graduates from accredited schools are specifically exempt from such tests as the BCSE and CPE, which ARE required of graduates of non accredited schools.
As a graduate of an accredited school, accreditation provides you with the confidence that the education you received provides you with the knowledge and skills necessary for a successful veterinary career.
We’ll keep you informed through our website, AVMA@Work blog, and other avenues as the process continues, and we welcome your input.
There was no allusion to the input given to the AVMA and COE at the hearing by committee members. One committee member noted that COE supporter Cyril Clarke’s approach of was unacceptable, advising him that the COE needed “to listen. Without judgement.” There was no reference to the volume or content of the input provided by the 800 veterinarians who submitted written letters, and the third party commentors critical of the COE.
This is inconsistent with welcoming input.
A transcript of the hearing will soon be available, as will information on specific steps COE has taken and will take to address USDE standards and questions. If you’re interested in learning more, we’ve got many resources on our site about the COE and the accreditation process, including the COE’s policies and procedures manual, standards of accreditation, accreditation classifications, pathways to accreditation and more.
These are the same methods currently in use by the COE. At the hearing, committee members specifically directed Dr. Derksen and the COE’s supporters to conduct outreach that would enable them to engage practitioners. The comittee voted to accept the staff’s reccomendation that the COE be found non-compliant with the criteria requiring wide acceptance by practitioners. Dr. Derksen specifically acknowledged the COE accepted the insufficiency of its current methods, saying “We realize this has been a one way street. We know we need to do better. We know we need to do more.”
More is not better. More is unlikely to engage practitioners and resolve the COE’s lack of acceptance. The one way street must become a two way street. An intersection.
A group of veterinarians (which included us) volunteered as Under The Microscope: Professional Issues In Veterinary Medicine to develop a website that more than 800 veterinarians used to write letters to NACIQI. As Eden stated at the hearing, the group did not create the discontent in those letters, but merely allowed its expression. The COE has a much larger budget than we had, and presumably a much longer e-mail list. We encourage the COE to work with its critics, including us, to find novel ways to accept input.
To do any of this, people from different perspectives throughout the profession will have to work together.
The profession has a tough road ahead.