Letter to dvm360: Heres the real problem with accreditation and the COE

October 12, 2016

Three veterinarians explain the root of their COE concerns. (Hint: It isnt the distributive model.)

An article in September 2016's dvm360, “Council on Education affirmed as accreditor,” characterizes critics of the current accreditation structure as “focused largely on the accreditation of schools with a distributive model of clinical education and ‘cronyism' among members of the council and AVMA leadership.”

This characterization is an oversimplification of the concerns surrounding the current structure of the COE. While it's true that some individuals have spoken loudly against the distributive model and the revolving door between the upper echelons of academia, the American Veterinary Medical Association (AVMA) and the Association of American Veterinary Medical Colleges (AAVMC), the major thrust of dissent is rooted in the AVMA's relationship with the COE. As three of the volunteers who raised awareness of this conflict of interest, we wish to clarify our position.

Our profession's gatekeeping accrediting agency is currently housed under the same roof as our profession's largest representative association. This relationship creates an inherent conflict of interest that leads to problems for the COE in thoroughly and consistently upholding accreditation standards, which makes it impossible for the AVMA to fulfill its primary mission of advocating for its membership.

This conflict of interest is not a new or unusual condition-It's why accrediting bodies have such stringent conflict of interest policies. It has led most professional organizations to formally separate themselves from accrediting agencies as a means of protecting their membership from legal liability. In the past, the federal government has challenged the control that the American Medical Association and the American Bar Association have had over their respective accrediting agencies. 

But there is no need to look outside our profession for examples of the problems such conflicts of interest invite. As evidence, consider the following:

  • In 2000, Western University of Health Sciences sued the AVMA when a letter of reasonable assurance was not imminent. Note that they did not sue the COE.

  • Due to a resolution put forth by the Texas VMA, the AVMA convened a committee to study workforce and accreditation issues. However, the committee's mission was thwarted by the AVMA's legal counsel on the grounds that commenting on foreign accreditation would violate Federal Trade Commission regulations. To be clear, this was an example of the AVMA choosing to back away from its mission of advocating for its membership due to the conflict of interest created by its control of the COE.

We have been told that the AVMA and COE are now sufficiently separated by a firewall and that the AVMA has given the COE a $10,000 appropriation to hire its own independent legal counsel. Because this amount is insufficient to cover the annual expense of truly independent counsel for an accrediting agency, this action appears to be mere window dressing.

Kurt Matushek, DVM, MS, editor of the Journal of the American Veterinary Medical Association, writes, “The perception that conflicts of interest could affect the accreditation process is a problem, but this is more a problem of image than substance.” Yet this perception was sufficient enough to bring about improvements in other professions.

Consider that the U.S. Justice Department intervened to resolve the American Bar Association's process for accrediting law schools and that the American Dental Association recently separated from the Commission on Dental Accreditation for the express purpose of avoiding such conflicts of interest. The American Medical Association also separated from the Liaison Committee on Medical Education when the U.S. Department of Education identified a fundamental conflict of interest between the two organizations. The separation was at the insistence of the FTCin the late 1970s. An identical relationship still exists between the AVMA and COE. How is it that leaders in the fields of dentistry and human medicine have come to realize and prevent these conflicts of interest but our veterinary leadership has not?

We are just as troubled that the association's recent alterations have done nothing to sufficiently change the relationship between the AVMA, the AAVMC and the COE. The AVMA would like us to believe that they've come to an understanding of what it is we desire in both our representative association and our accrediting agency as a result of listening sessions. This is simply not true. The nature of the relationship between these two has not changed.

We submit that the time has come for our profession's largest association and accrediting agency to leave the 1970s and enter the 21st century.


Ryan G. Gates, DVM

Don Woodman, DVM

Carl Darby, DVM