Q: What are the remaining issues of non-compliance with the USDE recognition guidelines in 2014, and what is the status?
A: The remaining issues are as follows:
The agency (in our case, the COE) must demonstrate wide acceptance among educators and practitioners.
Acceptance by practitioners and educators is the intended outcome of the process required under section 602.21(a)(b) listed below, that is, a written review process that clearly provides the opportunity for all relevant stakeholders to provide input in the review process is required.
Status: The evidence provided by the COE at the time of the National Advisory Committee on Institutional Quality and Integrity (NACIQI) hearing adequately demonstrated the wide acceptance among educators and satisfied this part of the USDE requirement. However, the USDE required additional evidence to demonstrate acceptance by practitioners. In response, the COE review process has been greatly expanded.
This overall plan was discussed with USDE staff at a face-to-face meeting with AVMA volunteers and staff on April 22, 2015. USDE staff were pleased with this approach and complimentary of the efforts.
The agency must ensure it has and applies a compliant student achievement standard.
USDE staff had difficulty interpreting how the North American Veterinary Licensing Examination (NAVLE) pass rate was being used to evaluate foreign and domestic veterinary schools and whether all schools were being treated the same way. The Council edited Standard 11, Outcomes Assessment, at its Spring 2015 meeting. However, the proposed changes must be circulated to all stakeholders for review and comment, followed by Council consideration of the comments, final editing, and approval prior to publication. Stakeholder comments are currently under consideration.
In addition to the NAVLE pass rate, the analyst also expressed concern about the evaluation of graduate placement rate and course completion rate for each accredited school. Placement and completion rates at accredited schools are consistently high, making both parameters ineffective measures of program quality. Nonetheless, the Council subsequently established thresholds and appropriate consequences if they’re not met. Stakeholder feedback on the proposed changes is under consideration. In addition, the 2015 AVMA Employment Survey conducted by the AVMA Economics Division provided additional evidence that the COE-accredited veterinary medical school attended has no impact on placement rate (or salary).
The agency must have compliant written policies for its systematic program of review and demonstrate that it involves all of the agency's relevant constituencies in the review and affords them a meaningful opportunity to provide input into the review.
The deficiency was discussed above under section 601.13. The COE’s written policy on the program review is being revised to include additional efforts to involve relevant constituencies. The current version of the policy is available online and includes regular surveys to evaluate the standards.
The agency must ensure that it has compliant written policies for its revision of standards.
The Council’s written policies were not actually out of compliance with this section. The appropriate timeline for addressing stakeholder concerns was already included in section 17.3 of the COE policies and procedures manual, but was simply overlooked by USDE staff during their review.
The agency administrative capability, specifically, that it applies clear and effective controls against conflicts of interest, or the appearance of conflicts of interest, by the agency’s Council under 602.15.
This deficiency was added at the NACIQI hearing in response to opinions expressed by a former COE member regarding dismissal from the Council. The COE Conflict of Interest policies, including the Code of Conduct and a comprehensive review of the circumstances surrounding the dismissal and result of the subsequent appeal, will be submitted to the USDE for consideration.
In summary, the COE and AVMA have made extensive efforts to reach out to members and stakeholders to listen to their concerns. Substantial changes have been made to address several of these concerns and all remaining areas of non-compliance with USDE recognition guidelines. The USDE did not feel the remaining issues warranted a moratorium on new COE accreditation activity and instead complimented the diligent, cooperative efforts of the Council in its progress and efforts to reach full compliance.
Due to a change in the Higher Education Act, the UDSE will no longer evaluate individual foreign veterinary medical colleges after July 1, 2015, for the purposes of awarding Title IV federal financial aid to U.S. citizens who choose to attend. Instead, the USDE established a new program to evaluate the standards and accreditation processes of accrediting agencies that accredit foreign veterinary medical schools. The new approval program is separate from the USDE recognition process for domestic accrediting agencies. Under the new program, any accrediting agency, foreign or domestic, can apply to the USDE for acceptance as an accreditor. The COE and several foreign accrediting agencies submitted applications for acceptance, and the COE was notified that its standards and accreditation processes are acceptable to the Department.