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As the accrediting agency for U.S. veterinary schools prepares to face its government oversight committee today, it’s fighting off hundreds of comments from veterinarians critical of its standards and policies, including its approval of veterinary schools that lack traditional teaching hospitals or are located overseas.  

U.S. Department of Education staff are recommending that the American Veterinary Medical Association’s Council on Education (the COE) be granted just six months to a year to come into compliance with various federal standards for the recognition of accreditors. The recommendation comes after the department received more than 800 comments critical of the veterinary accreditor and just 98 comments in support.

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According to the department’s staff-produced report, to be considered today by the federal committee that reviews accrediting agencies – a body known as the National Advisory Committee on Institutional Quality and Integrity, or NACIQI – the comments reflect four main issues: allegations that the COE’s standards are “vague, inconsistently enforced, and deliberately ‘weakened’ to justify, retrospectively, the accreditation of substandard schools”; charges of “undue political influence” on accreditation standards and policies on the part of the American Veterinary Medical Association and the Association of American Veterinary Medical Colleges; concerns that the “science-based” nature of the profession is being compromised by the accreditation of schools lacking “a robust research enterprise"; and opposition to the COE’s policy of accrediting veterinary schools based outside the U.S.

The Department of Education staff report states that the accreditor has made changes to its policies and processes since its last compliance review in 2012 "to better ensure wide acceptance among its constituencies and to better align with common accreditation practice."

However, the Department of Education’s staff report says that the “volume and substance” of the negative comments raise concerns about the accreditor’s acceptance among practicing veterinarians and educators (a criterion for federal recognition). The comments did not just originate from individuals: ten state veterinary associations also weighed in, six in support of the COE and four opposed. 

New Models of Veterinary Education

A core concern centers on the accreditation of schools, domestic or foreign, that lack traditional veterinary teaching hospitals and instead place their students in clinical rotations at a variety of third-party sites. Critics of what’s called the “distributive veterinary clinical education model” have raised concerns about adequate oversight of and supervision of students at the external clinical locations and have further argued that the accreditation of upstart veterinary schools that lack teaching hospitals that integrate research, teaching and patient care represents a step backward for veterinary education.

Robert R. Marshak, the dean emeritus at the University of Pennsylvania’s School of Veterinary Medicine, described the schools without teaching hospitals or “sophisticated research infrastructures” as “reverting to a vocational model, de-emphasizing science and embracing an apprenticeship system.”

“Moreover, lacking graduate and residency training programs, they do not contribute to the production of veterinarian-scientists, clinical specialty development, and the new knowledge and novel tools without which a profession cannot progress. Further, the vocational-type schools lack educational and research programs that focus on such issues as emerging and endemic zoonotic [species-crossing] diseases, food safety and security, and the problems associated with intensive livestock and poultry production medicine and its environmental impact. In these vital domains that safeguard the nation’s health, and economic and social stability[,] no other profession has greater responsibility and expertise,” Marshak wrote in a spring letter urging colleagues to submit comments to NACIQI. 

A group of eight veterinarians has created a website on this topic collecting letters and resources titled “Under the Microscope.” 

One letter on the site is from Mary Beth Leininger, a past American Veterinary Medical Association president and former COE member who described being expelled from the accrediting council after she aired concerns that the approval of foreign schools was leaving it with insufficient money, volunteer time, and staff resources to adequately evaluate domestic programs (more on the foreign accreditation issue below). After describing a closed, unreflective institutional culture at COE and a lack of training in site visit protocols and Department of Education regulations for new council members, Leininger concluded her letter, “In closing, I believe the COE and the AVMA cannot be trusted to conduct an open, fair and comprehensive program of education review, which leaves the larger issue unanswered: why isn’t the agency using the skills, knowledge, and incredible talent of its members to upgrade the competencies of veterinary graduates in our country?”

Much of the criticism has centered on the veterinary school at the Western University of Health Sciences, in California, which uses a distributive model for clinical education and gained full COE accreditation in 2010; more recently, in 2013, the COE granted letters of reasonable assurance, a preliminary step toward accreditation, to two brand-new veterinary schools that use a similar model.

In one letter to NACIQI, Robert Cherenson, another former COE member who works at a food animal veterinary clinic that is used as a clinical site for Western, described the Western students he encountered as lacking “a didactic education in the basic medical sciences” and, in many cases, as “ill-prepared in essential subjects including microbiology, immunology, pharmacology, physiology, and parasitology.” 

Phillip D. Nelson, the dean of the College of Veterinary Medicine at Western – “the lightning rod,” as he called it -- described many of the criticisms of the school’s curriculum as “rife with sound bites” and low on evidence. It is the case that the curriculum, which is oriented around problem-based learning, doesn’t include courses called “physiology” or “microbiology,” but he said students are regularly tested on those disciplines (along with ten other basic science topics) and must demonstrate a minimum level of performance to engage in clinical training. Students build on small group work in lectures and labs.

Nelson said the school uses 60-75 clinical locations to deliver its core curriculum, and over the last decade has worked with up to 600 additional sites, some only once, to provide elective options to students in their fourth year. The school currently doesn’t offer its own graduate or residency training programs, but Nelson said they're in the works: Western's veterinary college is young, he pointed out, with its first graduates only seven years out. The first focus has been on developing the professional, entry-level D.V.M. (doctor of veterinary medicine) program. The college reported a 96 percent pass rate on the national licensing exam for the class of 2014.

“I don’t accept vocational as the smear it’s meant to be,” Nelson said. “Vocational techniques are not automatically void of a scientific approach or a scientific appreciation.”

Nelson thinks the COE is doing a good job as the veterinary accreditor. But it’s had the misfortune of facing what he called an “unholy alliance” between people who are concerned about “the accreditation of a new model of education as exemplified by Western and … people who are concerned with the market and believe that accreditation should help control the influx of veterinarians into the market.” 

The American Veterinary Medical Association has maintained in the past that accreditation is merely a means of evaluating educational quality and should not be used as a mechanism to control the marketplace.

Foreign Accreditation

Related to this is the concern about the impact the accreditation of foreign veterinary schools could have on increasing the supply of entry-level veterinarians in the U.S. and depressing salaries in an already glutted market. COE, like many accreditors, has dramatically increased its overseas activities in recent years. Some of the foreign COE-accredited veterinary schools are attached to major research universities such as the Universities of Glasgow and Sydney, though the accreditor has also awarded its stamp of approval to two veterinary colleges at for-profit health schools in the West Indies that cater to American students, Ross and St. George’s Universities.                 

Beyond the workforce-related issues, critics of foreign accreditation have also raised concerns about the bending of accreditation standards across borders. Cherenson, the former COE member, cited as just one example the fact that veterinary medicine is taught at the bachelor's level in in many other countries. With students entering veterinary programs directly from high school, how, he asked, can institutions in those contexts meet the council’s standards for admission policies, which specifically reference courses that are "prerequisite to the professional program in veterinary medicine"? (American students seeking entry to veterinary schools take a heavy undergraduate science curriculum akin to that of their pre-med peers.)

A spokeswoman for the American Veterinary Medical Association declined a request to interview a COE official, saying that the accrediting agency will provide its response to the report at the NACIQI meeting today. "Council is committed to fully complying with the recognition guidelines and remains confident that the few remaining concerns identified by USDE staff can be addressed within the timeframe recommended,” Sharon Granskog, an association spokeswoman, wrote in an email.

In its written response to a draft version of the Department of Education staff report, the COE noted that the letters submitted in support of it included ones written by deans at the majority of U.S. veterinary colleges, "a group that represents thousands of veterinary educators." As for the critiques of the distributive model, the accrediting agency wrote that it has developed “extensive requirements to assure quality resources for students” in institutions that employ it, including in regards to the training of on-site supervisors, evaluation of students, and selection of clinical sites. As for accreditation of foreign institutions, the accrediting agency described this as “a professional dispute that should be resolved within the profession.”

The Department of Education report acknowledges that the accreditor’s foreign activities are outside the scope of the federal recognition process. However it notes the Department’s interest in the fact that American students attending foreign institutions may be eligible for federal loans by virtue of the institution’s COE accreditation. And it does raise questions regarding the accreditor’s consistent application of standards across borders, including in regard to a standard requiring all accredited institutions to have a minimum 80 percent pass rate on the North American Veterinary Licensing Examination (NAVLE). While the COE writes in its response to the agency’s findings that pass rates for graduates of its accredited schools abroad are equivalent to those for graduates of accredited domestic colleges, department staff note that “[i]t is also apparent from the documentation provided, that the agency only reviews NAVLE pass rate data from foreign schools if they are available, some schools of which, have very few graduates that take the NAVLE. The agency has instituted a binomial confidence interval in such cases where numbers of foreign graduates taking the NAVLE are limited.”

“The documents provided indicate the differences within the veterinary community regarding the accreditation of foreign veterinary schools, and the problems in applying the same standards to both foreign and domestic schools, a concern raised by many third-party commenters.”


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