Mark Cushing
JD
Politics & Policy columnist Mark Cushing is a political strategist, lawyer, founding partner of the Animal Policy Group and founding member of the Veterinary Virtual Care Association. Since 2004, he has specialized in animal health, animal welfare, and veterinary educational issues and accreditation. He is the author of “Pet Nation: The Inside Story of How Companion Animals Are Transforming Our Homes, Culture and Economy.”
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We don’t talk much, in public at least, about the system of accrediting new and existing colleges of veterinary medicine. Guests quietly head to the door when someone raises the topic at a dinner party. But it’s on the front burner today, and you may be surprised how much there is to explore. If you’re wondering what’s in it for you, ask yourself whether any of these issues matter:
- Lowering student debt
- Solving the veterinarian shortage
- Supporting access to veterinary care
- Encouraging educational innovation
- Recruiting the best and brightest to consider a veterinary career
- Maintaining and strengthening the animal shelter network
Background
The accreditation authority, the Council on Education, is housed in the American Veterinary Medical Association headquarters in Schaumburg, Illinois, and officially goes by the name AVMA COE. Appointed by the AVMA and the American Association of Veterinary Medical Colleges, COE members serve three- or six-year terms. The staff is led by an AVMA administrative employee and supported by a handful of people. The COE has no permanent governing official, and suffice it to say, the body’s closed-door deliberations are more invisible to the veterinary public and industry than the U.S. Supreme Court.
The COE’s mission is to establish standards for veterinary colleges, accredit or reject new programs, and reaccredit existing programs, of which there are 33 American, five Canadian and 18 international. New accreditations require self-study documents and at least two extensive site visits. Reaccreditation occurs every seven years and involves site visits and documentation.
Put simply, the Council on Education decides the life or death of each North American veterinary school or potential school. It’s a high-stakes job, but does the COE have the tools and structure to execute its responsibilities?
The U.S. Department of Education regulates the COE as a byproduct of the Title 4 student loan program, a lifeblood for U.S. colleges and universities. Like its cousin accreditors of nonveterinary programs, the COE is not supposed to determine the number of professionals in a field but simply ensure the schools are of sufficient quality.
The Education Department has warned trade associations in all fields, including law, engineering, dentistry and medicine, not to influence any decisions of accreditation bodies operating inside their organizations. The mandate arises from the fear of antitrust violations by those associations, which often view their mission as to protect the economic interests of their members, who could be affected by new professionals entering the field.
Accredited and provisionally accredited U.S. veterinary colleges fall into five categories. Here is the breakdown by category and the number of institutions in each group:
- Land-grant schools with a teaching hospital and research focus (24)
- Major private universities with a teaching hospital and research focus (2)
- Private schools with a teaching hospital (2)
- Distributive-rotation programs with a primarily clinical focus (4)
- Public distributive-rotation program with a research focus (1)
The key features I’ll return to are teaching hospital versus distributive rotations for clinical-year training and a research focus versus more of a primarily clinical focus.
The reason for the high number of teaching hospital institutions is they are older and generally received state funding for their hospitals — money that is ordinarily not available to newer programs. Older land-grant institutions were also established to meet a greater agricultural need, opening the door for more research funding.
What Must Be Done
I think these six areas require reform.
1. CHANGE THE COE’S LOCATION AND STAFFING
COE staff members report to AVMA officials and utilize AVMA email addresses. Unfortunately, the AVMA’s generosity and the relationship’s economic terms run afoul of the federal government’s warning that professional trade associations should not influence accreditation decisions made inside their organizations. The AVMA is free to challenge claims of veterinarian shortages (as it does), but the COE must be completely free of AVMA exhortations when it evaluates proposed programs. Only the naïve would think a meaningful wall exists between the two. AVMA comments such as “existing educational infrastructure would meet demand” are not a message the COE should hear from its landlord and employer.
If the COE balks at separation from the AVMA, then keep the AVMA as a landlord and create an independent board to manage the COE. The AVMA and AAVMC could appoint board members, but the board would select site visitors and act on their recommendations one way or the other.
In addition, the COE is woefully understaffed, causing significant delays in processing new accreditations. The COE’s work ethic is formidable, but the accreditor does not have enough people to do the work promptly.
So, let’s consider a simple solution: Have veterinary practices and other industry organizations that need and benefit from new veterinarians fund a blind pool for the benefit of COE staff hires and expenses. This solution isn’t complicated and is much better than raising the costs for AAVMC members, who are already challenged to hold down student tuition.
2. GIVE THE COE A CEO
Little dialogue goes on between the Council on Education, accredited schools, and industry and animal welfare organizations. The COE’s rotating chairs are volunteers who already donate an extraordinary amount of time. No one individual engages with the animal health community about policies of vital importance. If a person or institution has a question or wants to raise an issue with the COE, the matter is handled in terse email exchanges or short hearings rather than meaningful dialogue. Existing processes mute any hope for innovation in regulating veterinary schools. (I write having been a consultant to a host of successfully accredited programs.)
The lack of a chief executive officer also undermines the COE’s accountability to constituent stakeholders in the animal health community and, most importantly, to veterinary schools and would-be schools. Industry groups could easily cover the expense of an experienced and qualified CEO.
3. UNDERSTAND THAT EVERY SCHOOL DOES NOT NEED TO BE A RESEARCH INSTITUTION
The Council on Education increasingly interprets its policies and procedures as demanding that each veterinary school be a high-cost, major research institution. This insistence is neither necessary nor smart. Every school provides access to research careers and opportunities for students to participate in research and stay up to date on it when they are in practice. That approach makes sense and doesn’t cost millions of dollars.
America is blessed with internationally recognized, research-oriented veterinary colleges. However, that shouldn’t be the mission or baseline requirement for every institution, nor should all students bear the cost of research faculty through their tuition. Students in every field know how to select stronger research-based schools if that is their primary interest.
The COE sets no clear benchmark for the required level of research funding. At times, the directive is simply, “You’ll know it when you see it.”
That attitude isn’t helpful. The past 10 to 12 years have witnessed the COE shift from focusing on how students are introduced to research as an ingredient for career development to research as a stand-alone activity. The transformation is challenging for new programs as faculty numbers fall, recruiting research faculty becomes more difficult (sometimes impossible), and newer academicians struggle to attract research funding outside their institution. And bear in mind there’s no guarantee that federal support, such as NIH or USDA research grants, will continue at the same pace.
4. DON’T PRIORITIZE RESIDENCIES AND INTERNSHIPS
A recent shift outside the scope of the Council on Education is the idea that existing and new schools should prioritize exposing students to internships and residencies to open the door to faculty or research careers. Accredited schools with distributive programs are judged on whether virtually every student rotation includes exposure to a resident or intern. The experience can be valuable but need not be mandated. Graduate program representatives regularly visit new and old schools to recruit veterinary students. If asked, no student can claim ignorance about how or why to pursue an internship or residency.
Couldn’t the COE require one rotation in distributive programs that exposes students to a resident or intern and leave it to the student to pursue specialty electives? With no prodding from the COE, distributive programs are graduating students who pursue diverse careers, including academia. Do we need to hamstring the majority of students who aspire to be primary care practitioners? No.
Again, as a reminder, the COE’s job is to accredit programs that produce veterinarians, not to steer students to research or specialty careers.
5. ABANDON PRESCRIPTIVE POLICIES
Accredited veterinary schools have figured out how to deliver successful programs and do not need prescriptive guidance from the Council on Education. Yet that trend accelerates with each batch of new COE policies and procedures. These requirements are raising accreditation costs and erecting hurdles for new and old programs. It would be a different matter if school after school graduated unqualified veterinarians who went on to harm animals throughout the land. Since that scenario hasn’t happened, shouldn’t we trust the schools more? Are we afraid that the accreditation system will not survive if the COE focuses less on prescribing how an institution navigates toward and achieves its goals? A shift from prescribing to goal-setting would be a significant stride forward.
Led by a CEO, a properly funded Council on Education could initiate dialogue with established and prospective schools and the industry regarding the expectations for DVM programs without punishing or choking innovation.
Graduate job performance and North American Veterinary Licensing Examination scores are useful guides to how well schools are doing. The COE could experiment with different methods and let the results and field efforts serve as guideposts. Such an approach surely deserves a chance in contrast to prescriptive rules that attempt to button down every aspect of a well-funded professional program.
6. TREAT DISTRIBUTIVE PROGRAMS EQUALLY
Following the lead of virtually every health care profession, veterinary medicine has enjoyed the arrival of distributive educational models, led initially by Western University in Southern California and accelerated by Tennessee’s Lincoln Memorial University. These and other distributive programs avoid costly teaching hospitals and train clinical year students in veterinary practices, shelters, diagnostic labs, laboratories, industry and other venues.
A relatively new organization, COWBEL (Consortium of Workplace Based Education and Learning), was formed to develop clinical-year best practices. By any measure, distributive training is going well. Distributive programs lower student costs, provide a first-hand taste of real-world environments and help students prepare for the NAVLE through exposure to various animal health experts and settings.
Shockingly, the Council on Education has but one member affiliated with or trained by a distributive program. Therefore, COE decisions are made by graduates of teaching hospital programs who have an element of unfamiliarity with and skepticism about distributive education. These innovative programs are increasingly the target of COE policies that clamp down on innovation and try to standardize experiences in real-world practices. The COE also demands educational training of distributive model practitioners but not the same of instructors in teaching hospitals. Why the difference?
It’s time for the Council on Education, led by a CEO, to institute a twin system of accreditation:
- One panel reviews research-heavy schools that operate teaching hospitals.
- A second reviews clinically focused distributive schools.
Individuals with experience in a respective model would populate each panel. The application of most of the 11 COE standards would be identical, but some would differ, reflecting each model’s unique approach. Isn’t that innovative? Of course, and it’s probably threatening to some people. If the Council on Education officially recognizes the distributive model, as the COE was forced to do more than 25 years ago with Western University, why wouldn’t it recognize the differences between the two models and evaluate schools accordingly?
The Future
Faculty and practitioner shortages, access to care challenges and new generations of pet owners should cause us to welcome open dialogue about how we regulate veterinary programs. Few industries have undergone more scrutiny and change over the past two decades than education.
Ask yourself this:
- Isn’t it time to extend the conversation to veterinary education?
- Might multiple educational models be a good thing?
- Could animal welfare groups and industry become serious partners in funding and providing rich experiences for veterinary students? Shelters critically need more veterinarians, and narrowing the pipeline will harm them the most.
- Like human and osteopathic medicine schools, couldn’t various training models lead to a deep bench of caregivers addressing the range of health issues facing pets and large animals?
Regardless of whether readers agree with my positions, I hope to start a conversation. I also hope you consider the array of reforms presented — and perhaps others.
Finally, keep in mind that talented students have countless career choices. Let’s do what it takes to attract more — and the best — people to animal health care.
11 STANDARDS
The Council on Education applies the 11 standards below when accrediting veterinary medicine programs that award a DVM or an equivalent degree. The standards also define when a school “must” achieve something (“a mandatory requirement”) or “should” achieve it (“the recommended and highly desirable manner in which to attain the standard”). Details are at bit.ly/4b1o66I.
- Standard 1: Organization
- Standard 2: Finances
- Standard 3: Physical Facilities and Equipment
- Standard 4: Clinical Resources
- Standard 5: Information Resources
- Standard 6: Students
- Standard 7: Admission
- Standard 8: Faculty
- Standard 9: Curriculum
- Standard 10: Research Programs
- Standard 11: Outcomes Assessment
POSTWAR RECONSTRUCTION
According to the American Veterinary Medical Association, “In 1946 the entire structure of the AVMA was reorganized, and the Council on Education was formed to replace the Committee on Intelligence and Education. Since that time, the COE has conducted the accreditation program. In the year 2000, the term ‘essentials’ was changed to ‘standards.’ In 2016 the AVMA and the AAVMC [American Association of Veterinary Medical Colleges] established a memorandum of understanding for the COE, which outlines the roles of each organization in providing financial and personnel support for the AVMA COE.”
DID YOU KNOW?
The AVMA Committee on Veterinary Technician Education and Activities accredits veterinary technology programs. Learn more at bit.ly/4gGOkMV.