Should the Council on Education remain the accrediting body for U.S. veterinary colleges? Should the council still accredit foreign schools? What role should the American Veterinary Medical Association continue to play in the council’s work? Do conflicts of interest exist? These are some of the questions at the root of a raging debate in the veterinary community. Veterinary Practice News presents an open letter from four noted veterinary professionals to AVMA board of directors chairman Chip Price along with responses from Dr. Price and from Western and Lincoln Memorial universities, which the open letter references. Open letter to AVMA board chairman Chip Price Dear Dr. Price, Our profession, concerned about the proliferation and accreditation of veterinary schools that fail to meet Council on Education (COE) standards, has turned a critical eye on the AVMA’s leadership, its culture, judgment, vision for the future and capacity to lead. Membership approval of AVMA policies, procedures, decisions and philosophy can no longer be taken for granted. We hope, therefore, that you will consider using the precious commodity of time left in your tenure as AVMA board chairman to begin a process that will result in a more transparent, responsive, inclusive and accountable organization, an organization that welcomes, rather than scorns, dissenting views. It is also past time to consider seriously whether the AVMA’s top officers, directors and executive staff, whose response to criticism is to circle the wagons, deny the obvious and bend the truth, should be replaced by new blood. Such board action is normal practice by companies, corporations and organizations that have lost the confidence of their investors or membership. The U.S. Department of Education’s “wide acceptance” requirement (Criteria for Recognition 602.13) was a topic of great concern at the recent meeting of the National Advisory Committee for Institutional Quality and Integrity (NACIQI). Preliminary to the meeting, NACIQI had received letters supporting COE autonomy and independence, i.e., separation of the COE from the AVMA, from six state veterinary medical associations: California, Nebraska, New Jersey, New York, Pennsylvania and Texas. These six VMAs represent tens of thousands of veterinarians, an estimated quarter to half of the AVMA’s total membership. NACIQI also had received an avalanche of letters opposing continuing recognition of the COE as the accrediting agency for American veterinary schools from individual practitioners and educators, former COE members, AVMA past presidents, the past executive director of the North American Veterinary Licensing Examination (NAVLE) and the president of Cornell University. Veterinarian-scientists and administrators opposed to continuing recognition included, among many, six members of the National Academies Institute of Medicine, the discoverer of the Ebola and Marburg viruses, a recipient of the National Medal of Science and member of the National Academy of Sciences, two sitting veterinary deans, and former deans and associate deans. During decades of AVMA membership we have witnessed a gradual, now accelerated, disillusionment with the organization, its self-aggrandizement (such as the COE’s “gold standard” refrain), aversion to criticism, narrow vision, conflicts of interest, revolving-door politics and the executive board’s pusillanimous surrender when threatened with a lawsuit by Western University of Health Sciences. The board’s disastrous interference in the Western case has resulted in permanent inestimable harm to the fabric of American veterinary medical education, devaluing the DVM/VMD degree, and encouraging the proliferation of additional substandard for-profit type schools. Although the USDE Criteria for Recognition 602.18 requires that an accrediting agency must consistently enforce its standards, the COE regularly ignores this requirement based on the false premise that veterinary schools have different missions; this, despite the fact that the primary mission of every school is, and remains, the education of competent entry-level practitioners, and that the 11 standards—all of them—were designed to ensure society that this is in fact the case. Even as the COE has steadily weakened its standards, some recently accredited schools still fail to comply with the letter and spirit of standards 3, 4, 6, 8, 9, 10 and 11. It is evident to us that schools recently granted full accreditation, e.g., Western, or provisional status, e.g., Lincoln Memorial, are essentially for-profit trade schools that mistakenly believe there will always be an applicant pool willing to pay very high tuition fees for an inferior education. A striking parallel can be found in Paul Campos’ “The Law-School Scam,” published in the September 2014 issue of The Atlantic, where he wrote that “for-profit schools are a capitalist dream of privatized profits and socialized losses,” i.e., when students default on federally guaranteed loans American taxpayers must bear the burden. Finding itself under increasing pressure, the COE has introduced some cosmetic reforms, e.g., AAVMC participation in the selection of COE membership, and has allowed the COE chair, rather than Drs. Ron DeHaven and David Granstrom, to speak for or respond to criticism of COE policies, procedures and decisions. Perhaps eventually the COE will also consider disallowing the current practice of permitting board members to sit in on COE deliberations and ceasing the practice of expelling COE members whose conscience compels them to speak out in opposition to what they believe are wrongful AVMA-COE actions or policies. NACIQI members were visibly shocked to learn that this is what happened to Drs. William Kay and Mary Beth Leininger. With reference to transparency issues, it was disturbing to hear Drs. Granstrom’s and COE chairman Fred Derksen’s responses to a question posed by a NACIQI member. When asked “Why do foreign schools seek AVMA accreditation?” they gave many reasons—globalization, desire for “gold standard” recognition, incentive to improve programs, etc.—while artfully dodging the main reason: the desire to attract American students who are eligible for U.S.-backed loans and willing to pay exorbitant tuitions. No matter how many reforms are implemented, they likely will be rendered meaningless unless the COE is granted full autonomy and independence with its own budget, staff, working space and legal counsel, and unless the selection process for COE membership is freed of real and apparent conflicts of interest. The statements by Drs. DeHaven and Granstrom that a “firewall” separates the COE from the AVMA are false and disingenuous. Consider, for example, the board’s insistence that the COE must continue to accredit foreign veterinary schools. Regardless of House of Delegates’ approval, this is an outrageous example of the board’s interference with the COE’s autonomy and independence. Among the most egregious conflicts is the fact that the AVMA-COE selection committee consists of AVMA board members, past AVMA presidents and other AVMA insiders. Such a committee, without a single educator, is ill-equipped to identify and choose individuals qualified to evaluate institutions as complex as schools of veterinary medicine. Moreover, they are unlikely to choose individuals who question COE standards, policies, procedures and decisions, or the AVMA’s agenda or philosophy. It may be wise to consider the Liaison Committee for Medical Education’s selection process by allowing the COE, with appropriate guidelines, to select its own replacements. Unfortunately, the AAVMC’s COE member selection process is also rife with real or apparent conflicts of interest, e.g., deans in a position to select fellow deans or members of their own faculties. Some deans serve or have served on the Banfield Pet Hospital board, a major proponent and supporter of schools like Western. And because our 30 veterinary school deans are likely to know each other well, they should be ineligible for COE membership. Dr. Andrew Maccabe, AAVMC’s executive director, and Dr. DeHaven assure the profession that the accreditation process is “standards and evidence driven” and that the COE has taken action to assure it remains in “strategic alignment with the changing needs of the profession and the society it serves.” We find it hard to believe that the changing needs of the profession and society are well-served by encouraging and accrediting veterinary schools whose sole contribution to society is the mass production of marginally educated entry-level graduates. We believe that most veterinarians would agree that the “changing needs” of the profession and society call for more, rather than less, top-quality science in the veterinary curriculum. Because we live in an age when biomedical science is advancing at a pace beyond anything previously witnessed in human history, veterinary school graduates without a solid platform in contemporary science and technology will be poorly prepared to understand and incorporate into their practices the remarkable developments in translational research, molecular medicine, genomics, stem cell biology and so forth. Moreover, at a time when the AVMA and AAVMC, faced with a rapidly growing surplus of entry-level practitioners, are urging veterinary school graduates to consider nonpractice careers, e.g., in research, academia, epidemiology, food safety and security, and industry, the COE is accrediting schools that do not prepare students to be able to consider seriously these exciting and important alternative careers. Also, in advocating the distributive model as practiced by Western as an acceptable substitute for the traditional teaching hospital, Dr. Maccabe and his AVMA-COE colleagues fail to understand that outsourcing students for most or all of their clinical training to private practices has serious shortcomings. In such a distributive model, who is there to continually challenge and encourage students to question deeply, to cross boundaries between clinical disciplines, to make connections that produce deeper insights, to learn appropriate lessons from failure, to be consistent in doing their SOAPs, to experience the thrill of discovery and the potential for careers in research, and to appreciate that much of what they learn will be proven wrong a decade later? For a distributive model to deliver a quality education requires a substantial investment in electronic equipment and faculty personnel to continually train, monitor and evaluate partner practices, excellent on-campus infrastructure for in-house clinical training, a strong basic science faculty, and state-of-the-art laboratories for veterinary student, graduate student and faculty teaching and research. In other words, it requires an environment appropriate for the intensely intellectual nature of veterinary medical education. Located on the campus of a research university, only the Calgary Faculty of Veterinary Medicine, with its small class size (about 32 veterinary students), provincial funding and intimate medical school connections meets these requirements. In sum, we must conclude that Dr. Maccabe’s and the AVMA-COE’s views are dangerously disconnected from and in extreme misalignment with the obvious changing needs of the profession and society. Indeed, rather than “evolving to meet the changing needs of the veterinary medical profession,” as Dr. Maccabe asserts, the COE’s decisions have slammed the brakes on the profession’s progress, moving us back towards an earlier, less science-based era in veterinary medical education and practice. Dr. Maccabe’s assertion that Dr. Marshak believes it is “appropriate to use the accreditation process as a means to regulate or limit the number of veterinary graduates entering the work force” is a gross misreading of what he has written on several occasions, i.e., that while the COE cannot refuse a school’s request to be considered for reasonable assurance, and eventually for full accreditation, it is not obligated to grant either if it is determined that the school clearly cannot now or in the future meet the required standards. Indeed, it is imperative that the COE, despite the threat of lawsuits, refuse to accredit substandard schools, not to limit the number of graduates entering the work force but to ensure that each graduate has been properly trained and educated to begin the practice of veterinary medicine. Unfortunately, NAVLE, in its present iteration—specifically designed for the minimally competent entry-level graduate and with a universal pass rate in the 90s on first try—has little, if any, relationship to a veterinary school’s educational quality. Entirely clinical, and with only 5 percent of new questions each year, the exam fails to test a graduate’s knowledge and understanding of the increasingly complex basic science disciplines that underpin the practice of clinical medicine. In closing, we hope you will consider acting boldly by introducing ideas and initiatives for study and action aimed at making the AVMA a more transparent, responsive, inclusive and accountable organization that welcomes constructive dissent. We believe that refreshing the AVMA’s leadership team, moving as quickly as possible to give the COE complete autonomy and independence—its own budget, staff, working space and legal counsel—and remedying the COE’s unacceptable membership selection process deserve particular attention. Noting your long association with Louisiana State University, it is hard to resist mentioning that LSU’s veterinary dean emeritus Mike Groves is one of Dr. Marshak’s heroes. To the best of our knowledge, his brilliant letter, written in 2006, to the U.S. Department of Education was the first to question the USDE’s continuing recognition of the COE as the accrediting agency for schools of veterinary medicine. Further, in a joint letter to NASIQI written in 2014, LSU Dean Joel Baines and Cornell Dean Michael Kotlikoff endorsed separating the COE from the AVMA. Sincerely, Ralph Brinster, VMD, Ph.D. Richard King Mellon Professor of Reproductive Physiology, University of Pennsylvania School of Veterinary Medicine, Recipient of 2011 National Medal of Science William D. Hardy Jr., VMD, Director, National Veterinary Laboratory Inc. Robert R. Marshak, DVM, Dipl. ACVIM Professor emeritus of medicine and dean emeritus, University of Pennsylvania School of Veterinary Medicine Robert D. Phemister, DVM, Ph.D., Dipl. ACVP Professor emeritus of pathology and dean emeritus, Cornell University College of Veterinary Medicine Dr. Price responds: I appreciate the opportunity to address the concerns presented by Drs. Brinster, Hardy, Marshak and Phemister. Many of their concerns are answered in detail in the professional development section of the AVMA website. Open to all are specific explanations of the rigorous and comprehensive peer review process that every veterinary school undergoes when seeking accreditation. There you will find: • Detailed information about your colleagues serving on the Council on Education, including the Code of Conduct they must follow. • Policies and procedures adhered to by site teams when evaluating whether a college is in compliance with the 11 Standards of Accreditation. • Specific COE site team scoring rubrics, grids and schedules. • Examples of how COE findings are used by the schools to continually improve veterinary education. This information provides insight into the gravity with which site visits are conducted. It also helps clarify how veterinary schools that utilize the distributive clinical education model are evaluated to ensure graduates are fully prepared to practice veterinary medicine. While we know the answers to many of the questions raised by the authors are available and transparent, they are not easily found or explained. There is always room for improvement. For that reason, a listening session with COE representatives was held during the North American Veterinary Community conference and the Western Veterinary Conference. The comments and opinions gathered through these and other information-gathering processes will be considered by the full council at its next meeting in March. Plans are underway for the COE to provide an update of proposed actions at the AVMA convention in July. All AVMA members, whether dissenting or not, are invited to share their thoughts on the AVMA@work blog or to send specific thoughts to coe@avma.org. AVMA volunteer leaders and staff understand that the challenges the COE is facing are part of a larger issue, involving concerns about transparency and the value of AVMA membership. We’re taking strong action to better address member needs and ask for patience as these improvements continue to unfold. We are depending on constructive feedback from our members throughout this process, however repeated condemnation for perceived or even real missteps in the past are not helpful. It is difficult to move forward if you are mired in the past. We are listening and taking action. The AVMA Economics Division was established three years ago to study the veterinary workforce and to provide the information and analysis needed to build programs to ensure the financial well-being of our members. The Early Career Development Committee was formed to build programs that help recent graduates reach their full potential. The new Personal Financial Planning Tool is an example of the type of products the Career Development Committee is developing. The AVMA Veterinary Career Center was expanded to help veterinarians and employers find each other more readily. The AVMA helped initiate and continues to lead the Partners for Healthy Pets program to ensure pets receive the preventive health care they need through regular visits to the veterinarian. When the use of controlled drugs off veterinary premises was threatened, the AVMA advocacy team led a successful campaign to pass the Veterinary Medicine Mobility Act. AVMA volunteers and staff work continuously at the state and national level to keep the profession informed and protected. These are not the activities of people who wish the profession ill or would consider compromising their integrity for personal gain. No, these are the actions of people who have an unwavering commitment to the profession they hold dear and the members they have chosen to serve. These are the actions of those who possess an enduring desire to see that the profession flourishes for all who call it their own. Your colleague, Chip Price, DVM Chairman, AVMA board of directors WesternU responds The open letter to Dr. Price from Dr. Robert Marshak and others is filled with misstatements, inaccuracies and questionable assertions, starting with the misrepresentation of our university’s tax status (WesternU is a nonprofit, 501(c) (3), graduate university of the health professions), which appears to be an unsubtle attempt to characterize the college as nothing more than a money-making enterprise. We take strong issue with such aspersions. WesternU is in the middle of this firestorm because of an inability by some to understand how the COE determined that our CVM met accreditation standards. “The COE must have weakened the standards” is the simplest answer for those who have never taken time to read the standards, the college’s self-study or the COE’s Report of Evaluation. These same forces now question whether the Department of Education should continue to certify the COE as the profession’s accrediting body. Between the time the Letter of Assurance was issued and full accreditation was granted, WesternU CVM generated and submitted: • 10 semiannual reports. • Six annual reports. • 11 progress updates and clarifications of our plans to meet the standards. • Four comprehensive self-studies. • At least 20 in-depth pieces of correspondence between WesternU and the COE, addressing nearly 700 questions, concerns, recommendations, requests for documentation and/or commendations. Once the charter class arrived in 2004, the COE was a nearly constant presence on our campus. The liaison committee (or a subcommittee) visited the campus every year from 2004 to 2008 for comprehensive (two) or focused (three) evaluations. Since 2008, the COE has completed two additional comprehensive evaluations. During each comprehensive site visit, every facility we use to deliver our core curriculum—except for those facilities that belong to other COE-accredited institutions—was visited. Several words could be used to describe the degree of scrutiny this process entailed. “Permissive” is not among them. Ceaseless assertions that the COE has steadily weakened its standards, or has failed to apply them consistently, come from those with the least knowledge and narrowest interpretation of those standards, and little to no knowledge of how we deliver our program. Dr. Marshak asserts that he is familiar with our program. But he has not visited our campus since 2004—more than a decade ago—when our charter class was in its second year of the professional program and the clinical program had yet to be implemented. To our knowledge, none of the other distinguished signatories has ever visited our campus or sought information from us regarding concerns about our program. Repeated requests by members of NACIQI (and others) that Dr. Marshak provide evidence justifying his concerns has not been met by such evidence, but rather the incessant refrain that the COE—and everyone who accepts its assessment—is simply wrong. Refuting vague, evidence-free assertions of compliance failure is virtually impossible. The quality of our program is best reflected in the performance of our graduates in the full breadth and scope of the profession, including their performance on the NAVLE. Dr. Marshak’s argument about the NAVLE is troubling at best. He suggests that an instrument designed to protect the public by assuring minimal competencies should have a relatively high first-time failure rate across all accrediting colleges before he will accept its validity. The implications of actually implementing such a tool are unthinkable and provide further evidence of the lengths being taken to discredit facts that contradict Dr. Marshak’s opinion. My concerns regarding the representations of our college’s interaction with the COE are probably best phrased by Dr. Keiser, a member of NACIQI, in an exchange with Dr. Marshak during the NACIQI hearing held in December 2013: Dr. Keiser: “… My understanding (is) the school was under evaluation for 10 years, had multiple visits by multiple qualified, you know, veterinarians and folks who are part of veterinary science, and then 20 members of an accrediting commission all missed all of these things that you talked about? “… Why do you have a better understanding of the process than probably 50 other people who have been involved in evaluating this institution?” Our graduates continue to prove their worth alongside graduates of other institutions every day. They are broadly dispersed throughout the profession, continue to meet the demands of our society and are as prepared for future challenges as any other graduate. The distribution of our graduates between practice (private and public), government, academic, internships, residencies and graduate education is comparable to that of any other accredited institution. We are proud of the graduates we produce and the curriculum that produced them. As far as we know, every institution has had the liberty to develop their respective mission statement. We reserve the right to do so as well. Our motivation for providing these educational opportunities is the same as any other institution—to serve society. Contrary to the assertion made by Dr. Marshak in his open letter, we did not, nor do we, seek his opinion about what our mission should be. Respectfully, Phillip D. Nelson, DVM, Ph.D., Dean, Western University of Health Sciences College of Veterinary Medicine Lincoln Memorial Responds Former University of Pennsylvania Dean Marshak and three colleagues co-authored a letter repeating Dr. Marshak’s chronic complaints about the AVMA’s Council on Education and its accreditation of three domestic schools of veterinary medicine since 1981. I am writing this letter on behalf of my client, Lincoln Memorial University, which received provisional accreditation from the COE and welcomed its first class of veterinary students in August of 2014. I serve as consultant and counsel for Lincoln Memorial University. I have commented on Dr. Marshak’s theories in other venues, including before the Department of Education both in December 2012 and 2014. However, this letter addresses a more egregious error by Dr. Marshak and his colleagues, for which an apology is owed to Lincoln Memorial University. In the haste or zeal to make his point, Dr. Marshak makes a blatantly false and mean-spirited comment about my client, Lincoln Memorial University, and it reveals unfortunately a wanton lack of respect for the facts and history of a unique institution. Addressing the AVMA’s Dr. Price, they write: “It is evident to us that schools recently granted full accreditation, e.g., Western, or provisional status, e.g., Lincoln Memorial, are essentially for-profit trade schools that mistakenly believe there will always be an applicant pool willing to pay very high tuition fees for an inferior education.” (emphasis added) Lincoln Memorial was founded in 1897 at the direction of Gen. O.O. Howard, who was urged by President Abraham Lincoln during the Civil War in 1863 to found two institutions of higher learning: (1) a university in Washington, D.C., to serve the needs of African-Americans, which became known as Howard University and proudly exists to this day; and (2) a university near the Cumberland Gap where Kentucky, Virginia and Tennessee meet to serve the needs of the people of Appalachia who aided the Union cause during the Civil War. Lincoln Memorial University is a nonprofit institution, like Dr. Marshak’s former employer, the University of Pennsylvania, and has maintained this status for 117 years. Hardly a “trade school,” Lincoln Memorial University has earned the highest level of accreditation available by its Department of Education-recognized regional accrediting body and has awarded degrees in the liberal arts and sciences for its entire history. More importantly, Lincoln Memorial University embraced its mission to serve the needs of Appalachia, the poorest region in the United States, and in the past few decades has developed robust health and other professional programs as follows: nursing, nurse practitioners, osteopathic medicine, physician assistants, education, business administration, law, veterinary medicine, veterinary technology. Not all graduates return to Appalachia, but a significant number of Lincoln Memorial professionals are on the front lines of struggling rural communities throughout the 13-state Appalachian region, providing services needed at all levels. Lincoln Memorial University respects the eminent status and academic contribution of the University of Pennsylvania and understands that this institution does not endorse the views of its former veterinary school dean, in particular his false assertions about Lincoln Memorial’s status, mission and ethics. But the lack of respect for the facts and character of an institution with which Dr. Marshak and his colleagues have no familiarity or firsthand knowledge demands some accountability. And the proud graduates and current students of this fine institution named for President Lincoln, who called for its birth, deserve an apology. Whatever Dr. Marshak thinks about accreditation, he and his colleagues went too far. Mark L. Cushing, Tonkon Torp LLP, Animal Policy Group
