COE responds to perceived conflict of interest

October 18, 2016

The Council on Education responds to post that explains the root of their problems.

Editor's note: After we posted this letter from Ryan G. Gates, DVM, Don Woodman, DVM, and Carl Darby, DVM, on, the American Veterinary Medical Association Council on Education (AVMA COE) executive committee asked for the opportunity to weigh in on the conversation. Here is their response: 

We welcome the opportunity to provide clarification regarding statements made by Drs. Gates, Woodman and Darby in their October 12 letter to

Much of the recent criticism of the Council on Education has incorrectly compared the COE to other accrediting bodies that are perceived by some to be fully independent. Examination of the policies and procedures of the accrediting bodies referenced in the Oct 12 letter reveals the following:

> Section 130 of the American Dental Association (ADA) bylaws describes the duties of the Commission on Dental Accreditation (CODA) as including submission of an annual report to the ADA House of Delegates, submission of interim reports to the ADA Board of Trustees, submission of the CODA annual budget to the ADA Board of Trustees for approval by a majority vote, and submission of the CODA articles of incorporation and rules and amendments to the ADA House of Delegates for approval by majority vote. Section 120 allows CODA to make only editorial corrections (punctuation, grammar, spelling, name changes, gender references, etc.) to its rules without approval by the ADA House of Delegates.

Based on these bylaws, CODA is less independent than the COE: the COE alone has the authority to change its rules (editorial or otherwise), and the changes do not require approval by any AVMA leadership entity. The letter authors reference a white paper that investigates the option of separation from ADA, but this has not happened and CODA remains a U.S. Department of Education (USDE) -recognized accrediting body. See our website for a thorough comparison of CODA and COE.

> The Liaison Committee on Medical Education (LCME) is not fully independent of the American Association of Medical Colleges (AAMC) or the American Medical Association (AMA). The LCME website itself clearly states that LCME is jointly sponsored by the AAMC and AMA. The LCME staff are hired and paid by the AAMC and AMA. New medical education programs pay an application fee and only new and developing medical education programs pay travel expenses. Once accredited the LCME covers all travel expenses for accreditation visits, meaning that AAMC and AMA bear the costs through LCME.

In contrast, the costs of accreditation visits for veterinary education programs are borne by the schools, and the cost for the COE accreditation program is shared with U.S. and Canadian schools, with international and developing schools paying all costs of accreditation.  The letter's authors cite a 1977 article that makes many of the same allegations they repeatedly make concerning AVMA and COE, yet the LCME remains functionally embedded in the AMA and AAMC as the USDE-recognized accreditor for medical education and the COE is the USDE-recognized accreditor for veterinary medical education. See our website for a thorough comparison of LCME and COE-they are more closely aligned than the letter suggests.

We have more information on our website about how the COE is different from and similar to other accrediting bodies, including a comparison chart.  A number of accrediting bodies remain embedded in or reliant on financial support from the professional associations, including those for optometry, occupational therapy, nutrition and dietetics, osteopathy, psychology and physical therapy.

Regarding legal fees, the letter's authors incorrectly cite a $10,000 appropriation for legal fees as an annual allotment. This is incorrect. A $10,000 allotment was requested and granted in March 2015 for the remainder of that year, and legal fees from 2016 onward were to be included in the COE budget; the recommendation was not for a $10,000 annual expenditure. The letter's authors cite a lawsuit brought by Western University against the AVMA in 2000, which predates the changes that have distanced the COE from AVMA and provided it with independent legal coverage.

The letter authors cite an antitrust judgment against the American Bar Association (ABA) as evidence that the accrediting body was forced to separate from the ABA. This is, however, inaccurate. According to Article 10.1 of the ABA bylaws, the Section of Legal Education and Admissions to the Bar, which is the USDE-recognized accrediting body for legal education, is a division within the ABA. Section 45.9 of those same bylaws requires that the section “shall file a resolution to the House [of Delegates] seeking concurrence of the House in any actions of the Council to adopt, revise or repeal the Standards, Interpretations, or Rules of Procedure for Approval of Law Schools.” In other words, changes to the rules of accreditation for legal education must be approved by the ABA House of Delegates. This is not the case with COE, which has autonomous oversight of its standards, policies and procedures.

We continue to welcome discussion about accreditation and the COE, but we object to continued unfounded criticism regarding the COE's independence. As the USDE-recognized accrediting body for veterinary medical education, we will continue to focus on assuring the quality of veterinary medical education and the production of veterinary graduates to meet societal needs.

Council on Education Executive Committee:

Dr. John Scamahorn, chair

Dr. Patrick Farrell, co-chair

Dr. Spencer Johnston

Dr. Caroline Zeiss