My comments to NACIQI on the COE

So every five years, accrediting agencies get reviewed by NACIQI, a US Department of Education committee.  They are reviewed for how well they fulfill these criteria.  The AVMA COE was reviewed as scheduled in 2012 and given a year to change some items. 

Well, that year is up and on Dec 11 the COE has a public hearing before NACIQI in Washington DC.  At the meeting, the committee will decide whether or not to recommend continued recognition for the COE- and thus the continued ability to determine which school gets unlimited federal student loan money.   As part of the process, NACIQI asked for public comments. Here's what I submitted...



I would ask the committee to consider the following points in its review of the AVMA COE as a recognized accreditor.

Regardless of the decision rendered by the committee, I thank each member for the time and effort spent in consideration. As a taxpayer, as a federal student loan holder, as the parent of two kids who will be college age soon, as a consumer dependent on the services of those educated by the programs under consideration I appreciate the committee's dedication to it's task: ensuring the quality of education being purchased by my dollars as a taxpayer, a parent, a borrower.  As a practicing veterinarian of fourteen years I appreciate this specific effort to review the recognition of the AVMA Council on Education as an accreditor of veterinary medical programs.  Having taken the time and effort to educate myself in these matters, I appreciate the investment the committee's members have made, no matter what decision they render upon consideration of the COE's status as an accreditor.


The COE is in violation of 602.13 Acceptance of the agency by others.  The COE’s “standards, policies, procedures, and decisions to grant or deny accreditation” are not widely accepted among the practitioner and employer community.  Evidence of this can be found in

  • social media:
    • Many posts by the official AVMA Facebook page regarding accreditation since 2012 received multiple critical comments; I personally remember negative comments being deleted.   
    • a Facebook discussion group “Under the Microscope: Professional Issues in Veterinary Medicine” was started with the description “As veterinary practitioners, we do not accept the Council on Education's standards or processes for accrediting veterinary colleges. “ The group gained over 400 members in two months, with hundreds of posts and conversations; many posts and posters are critical of the Councils actions;
    • Veterinarians have expressed on Twitter (by retweeting, favoriting or composing tweets) positions and sentiment critical of the AVMA COE
    • independently hosted blogs such as
    • Communications from state veterinary medical associations—including Nebraska, Texas, New Jersey, Pennsylvania and this campaign from New York
    • The proprietary message boards on the veterinary subscription service Veterinary Information Network, which has seen many member veterinarians post scores of threads and hundreds of posts regarding accreditation- most critical of the AVMA.  Access to the discussions can be requested from the service by emailing company cofounder Paul Pion DVM at [email protected].  A poll conducted by VIN, to which 1309 veterinarians responded, showed over 30% felt the COE was doing a poor job
    • The members only professional listservs such as those for ACVIM and AABP have seen member veterinarians expressing sometimes profound concerns about the operations of the Council on Education. 
    • The number of comments submitted for the upcoming hearing- more than 20 times as many comments were submitted this time as for the 2012 hearing.  Comments have been submitted by practice owners, associates, students, new grads, mid career grads, large animal vets, small animal vets, retired vets, academics and more. 

These sources offer ample evidence that practitioners- many of whom are also employers- do not widely accept the Council on Education’s standards.  In fact, most of us feel totally disenfranchised from this process. 

 The criteria do not specify that practitioners and employers must understand the COE’s policies, decisions and standards- only accept them. Practitioners and employers may or may not understand the accreditation process itself- and it is clear some of us do and some of us don’t.  Either way, the onus falls on the COE to be accepted; if a lack of understanding is contributing to non-acceptance, then the COE must find ways to be transparent; if ignorance contributes to lack of acceptance, the COE must educate.

 The COE seems to be in violation of 602.18, as the standards of the COE are widely believed to be applied inconsistently.  This is due in part to the forcible reversal by lawsuit of a negative accreditation decision rendered by the COE apparently following it’s own due process.  This perception is sustained and strengthened by the repeated claim by the AVMA and COE that negative decisions can't be allowed, and applications for letters of reasonable assurance can't be denied, for fear of additional lawsuits.  

There is no information available from COE about how applications are evaluated, and how decisions are made, although a few schools do choose to make their self- studies available to their own communities or publicly on their websites.  The practitioner community can't figure out why some schools deserve to be accredited when it seems like they wouldn't meet the published standards.  It is widely believed that standards are changed so specific schools can be accredited to further the AVMA Executive Board's policies.

 The COE is in violation of 602.15 (6) as there appears to be undue influence on the AVMA COE by the AVMA and AAVMC board members and AVMA administrative staff- which is a clear conflict of interest.  

 It is the COE’s only role to pursue quality assurance through peer review, as even the CEO of the AVMA has publicly stated.  However it is the AVMA’s role to pursue a political agenda and advocate for its members.  There is evidence that this agenda is advanced by the way the COE is staffed and selected. 

 COE staff is paid by and housed in the AVMA's central office, and spend a significant part of their time performing non-COE duties as part of their AVMA paid jobs.  AVMA administrative staff prepares the COE's reports, saying the COE members are too busy, and that preparing USDE and CHEA reports requires a depth of knowledge and time commitment that can't be expected of volunteers. This may be true, and only serves to reinforce the need for an autonomous accrediting body with its own staff, its own offices, its own legal counsel.  The only legal counsel COE has access to is the AVMA's legal counsel, and the only staff it has use of is AVMA staff.

AVMA Executive Board members sit in on COE meetings, see COE documents before their release and until 2012 (and possibly to this day, we practitioners have no way of knowing!) went along all expenses paid on site visits.  Even when the intent of such overt monitoring is benign, the effect cannot be.  

There appears to have been direct interference with the Council's autonomous operations on at least three occasions- the ouster of Bill Kay, when as a duly appointed sitting member of the COE he mounted strong opposition to the COE basing decisions on the AVMA Executive Board's publicly expressed preference for which schools to accredit; the ouster just a month ago of Mary Beth Leininger for similar reasons- expressing objection to interpreting standards accrediting schools on the basis of AVMA policy rather than COE standard; and the case cited above, where a COE decision to grant accreditation to Western University in Pomona CA was reversed after Western filed a lawsuit against AVMA over the COE's negative decision.  The AVMA and COE have cited the threat of additional lawsuits as a reason negative accreditation decisions can't be handed out. 

There may be alternate explanations for the above cases, but the COE releases nothing and the persons involved are prosecuted legally for attempting to discuss it.  Certainly there is legitimate need to protect the COE’s deliberations before and while decisions are made.  However once a decision has been made the reasons behind the decision- be it a negative accreditation decision or the ouster of a duly seated member- should be transparently explained to the people who are expected to live by that decision.

AVMA COE does not and cannot prevent conflict of interest on the part of committee members, and those selecting them, due to the small size and limited engagement of the veterinary community- particularly the veterinary academic community.  Given the small number of programs, and the small size of the faculty at each program, it is impossible to find people in the veterinary academic community to sit on the COE in judgment of veterinary schools who are not, in fact, significantly compromised.  

Merely signing a paper at the beginning of a six year term, or abstaining from the vote on a particular school, does not obviate conflict of interest.  All the potential candidates are either current employees of one of the programs… or they are future employees, alumni, married to someone in one of those categories, co-investigators with faculty at another institution (sometimes several) or in some other way involved with the programs they will be judging- sometimes by having their own children enrolled in one of the programs they would have to judge.  There is no way to operate free of conflict of interest in such a situation. 

Currently the only check for conflict of interest is to have the COE members sign a paper. At the beginning of their six year term.  Before COE members were barred from going on site visits, conflict of interest was prevented by not letting you go on a site visit to the school you worked for or graduated from.  That was it.  No mention of where your spouse worked or went to school, where your dad went to school, where your kids went to school, where you were doing research, where you had worked in the past, where you were looking to work in the future.  We are a small profession compared to the numerical behemoths of law and human medicine, and the pool of qualified, interested, available volunteers to occupy these roles is even smaller- practically infinitesimal.  Okay, not infinitesimal, but far too small to realistically avoid COI.

 The people charged with selecting these members likewise have no plausible deniability that they can operate free of conflict of interest.  This is due to their position and background. Five people at the AVMA now pick half the COE, and the AAVMC board picks the other half. The five people at the AVMA who pick half the COE are the AVMA COE Selection Committee.  Of the five, four are handpicked by the AVMA Executive Board and the fifth is from the AVMA House of Delegates leadership- a battle scarred collection of political survivors who’ve managed to obtain and retain a seat in the inefficient deliberative body the AVMA staff has been trying to abolish for years.  

The AAVMC's degree of control is ethically even more troubling, as it allows leaders of the very programs being judged to pick their own program's judges- from among the judged programs' employees.  

 The press release announcing the formation of the AAVMC COE Selection Committee in October 2013 shows that four of the five charter members are sitting vet school deans, two also being former COE chairs (Sheila Allen and Deb Kochevar) and one (Kochevar) being both a former COE chair and immediate past president of AAVMC.  

 The COE Policy and Procedures manual (section 15) states "The membership consists of at least five veterinary medical college faculty members" thus the AAVMC's leadership is current deans selecting people who may, in fact must be employees of the programs they lead.  These same people can also revise the standards by which they are to then judge these programs. 

 Under the structure described above, there is no guideline that *can* be established or implemented to prevent bias and undue influence on who is appointed to the committee, and what those appointees are expected to do- even by themselves.

 Even the most basic knowledge of human behaviour recognizes the influence such situations exert on our decision making, even when we take measures against it.  Therefore the COE cannot be considered free of conflict of interest, and is perhaps even less so than in 2012 when they came before NACIQI and were advised to create more distance between the COE as an accrediting agency and the AVMA.

The COE appears to have taken actions to come into compliance as directed by NACIQI in 2012, however those actions seem to be procedural window dressing rather than substantive and effective measures.  Current first hand anecdotal evidence of this is provided by this February 2014 email from COE member Billy Martindale DVM of Denison Texas to Mark Cox DVM of El Paso Texas, who is a member of the AVMA House of Delegates leadership.  Mark shared the email with the Texas VMA-AVMA Liaison Committee (TALC):

 Although the final details by the AVMA and AAVMC for appointing COE members is yet to be determined (published),  both associations will be responsible for selecting 8 members each to serve on the Council...This is a significant was primarily implemented because of the Department of Education’s desire to create a greater distance between the AVMA and the COE.

Revisions to the [COE] Policies and Procedures manual  have been primarily focused on...changes in language... These changes have been labor and time intensive in an effort to determine terminology that is acceptable to the USDE. However, in effect, they have resulted in very little change to the overall ... accreditation protocol and procedure.

 It is remarkable that the final details for Council appointment procedures had already been published, six months before a mid term sitting member of the COE sent an email to one of the largest and most influential state associations, indicating they had not.  It is also remarkable that a "labor and time intensive effort" had been undertaken to keep things much the same yet make them acceptable to the Department.

As the COE was asked to remedy noncompliance in these areas after the 2012 hearing, and it has not done so, I request that the NACIQI recommend withdrawing COE's USDE recognition as accreditor for programs conferring the DVM or VMD degree. 

 Recognizing the indispensability of a smoothly functioning accreditation system, and recognizing the COE's strengths and resources as well as it's weaknesses and limitations, I suggest the withdrawal be effective upon the recognition of an alternate accreditor to serve as the COE’s successor.  This accreditor could be developed by spinning the COE off of the AVMA as the NAVLE was. This succeeding accreditor would be an autonomous, robust, interdependently funded body comprising a broad group of stakeholders capable of making transparent decisions that all stakeholders could understand and accept.  The governance of such a successful accrediting body should be aligned with that recommended for human graduate medical education under the aegis of the US Department for Health and Human Services in the Institute of Medicine report, “Graduate Medical Education That Meets the Nation’s Health Needs”.  


Eden Myers DVM

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commented 2016-12-31 05:54:01 -0500 · Flag
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