March 15, 2015


 Learning to listen

​In bid for re-recognition by USDE, AVMA education council called to reach out to practitioners

Posted Feb. 25, 2015

The AVMA Council on Education went before the U.S. Department of Education’s National Advisory Committee on Institutional Quality and Integrity this past December in a bid for re-recognition as the accreditor of veterinary colleges in the U.S.

After listening to commenters and considering the COE’s reports, NACIQI members acknowledged that the council has made a number of changes to come into compliance with the USDE’s requirements for accreditors. However, the advisory committee outlined four concerns and added an additional criterion that the COE has to come into compliance with. That includes a requirement that would have the council undergo something of a culture change—one that places a greater emphasis on interacting with and listening to practitioners—to receive re-recognition. In response, the COE held two listening sessions in January and February.

Changes in criteria

NACIQI is an advisory panel comprising 18 volunteer members appointed by Congress and the USDE. Its main job is to recommend to the education secretary whether the accrediting agencies it reviews, such as the COE, deserve the department’s stamp of approval. The USDE then determines whether to recognize those agencies as qualified to evaluate the education and training provided by higher education programs and to accredit them when appropriate.

The COE has been recognized by the USDE since 1952, when the department first established a list of nationally recognized accrediting agencies. The council’s recognition has been renewed periodically—the last time was in 2006 for a period of five years. In December 2012, NACIQI reviewed the COE’s application for re-recognition and gave the council one year to comply with a series of department standards and submit a report demonstrating compliance with issues identified during its review.

NACIQI, on the basis of a USDE staff report, recommended that the COE prove it meets certain criteria, such as being widely accepted by educators and educational institutions, providing adequate training for individuals conducting site visits, reporting progress in student achievement, accepting and considering comments on individual institutions’ qualifications for accreditation, and promptly notifying the public of decisions.

Dr. John R. Pascoe, a COE member, explained that reconstitution of the NACIQI in 2010, following reauthorization of the Higher Education Act in 2008, resulted in new interpretations of the USDE standards, which required accreditors such as the COE to make changes to remain in compliance.

“Most agencies that accredit had to make a lot of changes. There seems to be the perception from people that are unhappy with the COE or have issues with the COE that we are a bad actor. The reality is most agencies that accredit have had to come into compliance with new things. We’ve diligently done that,” Dr. Pascoe said (see sidebar on page 570 for more detail on changes made by the COE).

Into the spotlight

As Dr. Pascoe mentioned, throughout this time, the COE also has been dealing with numerous criticisms.

For most of the council’s history, the accreditor did its business quietly and with little fanfare as it deliberated on how veterinary colleges met its standards for producing graduates. But in 2001, the decision by COE members to grant a letter of reasonable assurance of accreditation to Western University of Health Sciences in Pomona, California, elicited backlash because it was the first veterinary college accredited with a full distributive education model. Critics contend students do not receive proper clinical instruction at off-site facilities as they do at a veterinary teaching hospital. (Western became fully accredited in March 2008, retroactive to the date of the comprehensive site visit).

A few years later, the council was pushed further into the spotlight after some veterinarians disagreed with its decision to accredit the veterinary colleges at three foreign institutions: the National Autonomous University of Mexico, Mexico City, in 2010, and Ross University, St. Kitts, West Indies, and St. George’s University, Grenada, West Indies, in 2011. Since then, the COE has come under fire for everything from its continued accreditation of foreign institutions to allegations of improper influence by the AVMA to practitioners calling into question whether the COE applies its standards consistently (see story). 

AVMA Education and Research Division Director Karen Martens Brandt responds to criticism of the Council on Education’s accreditation of veterinary colleges expressed during the regular winter session of the AVMA House of Delegates on Jan. 10. (Photo by R. Scott Nolen)

As a result, the 2014 USDE staff report indicates that NACIQI received more than 1,000 comments related to the council’s bid for re-recognition, most of them critical. But figures cited by the COE at the listening session in January during the North American Veterinary Community Conference in Orlando, Florida, and at the AVMA Veterinary Leadership Conference in Chicago that same month place the total closer to 900, many of which were form letters generated as part of a campaign against the council.

In either case, the volume of comments on such a proceeding was unusual. USDE staff reports from 2012-2014 indicate the committee received a total of only about 150 written comments on 82 other reports and petitions heard during that three-year period, and that includes a 2012 AVMA petition for continued recognition that received only 13 comments.

At the December 2014 NACIQI hearing, 12 individuals spoke in support of the council and seven against. Additionally, 26 of the 30 U.S. veterinary colleges wrote letters of support for the continuing role of the accrediting body. Of the remaining four, two wrote in opposition, and the other two did not write letters.

In transition

Ultimately, NACIQI, on the basis of the USDE staff report, stated four areas for which the COE must demonstrate compliance before being granted re-recognition, and a fifth one was added during the hearing. The council was called to do the following:

  • Ensure it has and applies a compliant student achievement standard.
  • Have compliant written policies for its systematic program of review,  demonstrate that it involves all its relevant constituencies in the review, and afford those constituencies a meaningful opportunity to provide input into the review.
  • Ensure that it has compliant written policies for its revision of standards.
  • Demonstrate wide acceptance among educators and practitioners.
  • Ensure effective controls against conflict of interest.

The council has been given six months to come into compliance with the first three and a year for the last two. This, along with the USDE staff analyst’s recommendation, will be forwarded to the undersecretary of education, who will decide on continued COE recognition.

Dr. Karen Martens Brandt, director of the AVMA Education and Research Division, told the AVMA Board of Directors in January that the COE does have policies on program review and revision of standards, for example, and overlooking them was an oversight on the USDE staff member’s part. The same goes for the deficiency added during the meeting that said the COE still needs to have policies in place to address conflicts of interest.

Also, she said, “There is language on student achievement standards we’re working on, and that was sent out for comment. The COE takes all that into consideration as members make their decision. When the COE sent out changes to the student standard last time, they got a number of comments back suggesting making the language less prescriptive, but broader still. The final language adopted was based on public comment.”

The requirement for broad acceptance by practitioners represents a change in interpretation by NACIQI. At the 2012 hearing, the COE was cited for needing to demonstrate wide acceptance among educators and institutions, but the wording didn’t mention practitioners.

The COE could give more information on how it goes about its activities, how decisions are made, and what factors are considered, rather than being closed-doored about it. You are never going to make everyone happy. These are difficult decisions to make; however, if the council errs on the side of over-communicating as to why and how decisions are being made, it will go a long way toward re-establishing a sense of trust.”
Dr. Sheila Allen, former COE chair and current dean of the University of Georgia
College of Veterinary Medicine

Receiving feedback

Dr. Pascoe says the COE will do what it can to come into compliance with the department’s requirement for gaining wide acceptance among practitioners. The council hosted a listening session Jan. 18 during the NAVC Conference in Orlando, Florida, to start seeking to gain that acceptance. Meeting attendees were encouraged to express their points of view related to accreditation by the council (see story).

At press time in February, a second listening session was planned for Feb. 15 at the Western Veterinary Conference in Las Vegas, and the COE was scheduled to meet March 8-10 at AVMA headquarters. Dr. Pascoe said that members would discuss comments that came up during the NACIQI hearing and the listening sessions, develop strategies for responding to those concerns, and develop ways to communicate with practitioners broadly and on an ongoing basis. 

A potential solution involves a survey that would allow the profession to respond to accreditation-related issues, generating feedback for the council to consider. Also, a biweekly blog is being considered for the AVMA website that would further explain, for example, the rationale for suggested future standards changes, similar to Federal Register notices.

New way of doing business

Dr. Trevor R. Ames, president of the Association of American Veterinary Medical Colleges, says the COE will have to deal with perception issues to ensure it reflects the image of being fair, independent, and unbiased.

“Certainly their communications being perceived as fair and accurate is important, as is conducting listening sessions like they did at NAVC and in the future,” Dr. Ames said.

Dr. Sheila W. Allen, former COE chair and current dean of the University of Georgia College of Veterinary Medicine, thinks the council can do a better job of communicating about its activities.

“The COE’s stakeholders should be informed as to why language on a standard is being changed or is recommended to be changed, and why certain policies and procedures are being revised. I think if that could happen, a lot of concerns about transparency could be resolved,” Dr. Allen said.

She adds that while accreditation deliberations and decisions would still need to remain confidential, “The COE could give more information on how it goes about its activities, how decisions are made, and what factors are considered, rather than being closed-doored about it. You are never going to make everyone happy. These are difficult decisions to make; however, if the council errs on the side of over-communicating as to why and how decisions are being made, it will go a long way toward re-establishing a sense of trust.”

Dr. Allen says in the case of Western University, “I think we could have done a much better job explaining what methods were used to document compliance with clinical resource, research, and curriculum standards, for example.

“If a school becomes accredited that you think should not receive that recognition, you’re not going to be happy. But if the council were more transparent on why they felt the standards were met—without violating confidentiality, perhaps in cooperation with the school—it would go a long way to answering the concerns of the COE’s stakeholders.”


The Accreditation Policies and Procedures of the AVMA Council
on Education are available at


Related JAVMA content:

COE given more time to comply with USDE standards (Feb. 15, 2013)

What’s at stake? (Feb. 15, 2013)

‘Philosophical differences of opinion’ (Feb. 15, 2013)

New federal regulations affect accreditors (July 1, 2010)

Speaking different languages (May 15, 2010)

WesternU drops antitrust lawsuit against AVMA (May 1, 2001)

WesternU granted letter of reasonable assurance (April 1, 2001)