The Washington State Chiropractic Quality Assurance Commission (Commission) has filed CR-102 forms for the following rules:
Colleges and Early Remediation WAC 246-808-020 - Accreditation and approval of chiropractic colleges - Policy, 246-808-030 -Accreditation of chiropractic colleges - Procedure, 246-808-040 – Chiropractic colleges-Educational standards required for accreditation and approval. The commission is proposing amending these sections to update, clarify, and modernize the language. The commission also proposes to create the following new sections as an alternative to certain disciplinary actions: WAC 246-808-050 - Early remediation program - Purpose, 246-808-060 - Early remediation program - Definitions, and 246-808-070 -Early remediation program - Criteria.
The commission filed the CR-102 forms with the Office of the Code Reviser on December 5, 2018, under WSR #18-24-121 and WSR #18-24-122.
According to forms filed by the Commission they are proposing to amend WAC 246-808-020, 246-808-030, and 246-808-040, to: “provide clarity and modernize the commission's accreditation and approval process.”
A hearing is being held on January 10, 2019 to entertain public comments.
The Commission did not put their notice out until just before the Christmas and New Years’ Holidays so most likely the public paid little if any attention to it. Some chiropractors claim they did this on purpose so they could pass the rule without resistance.
According to the Commission:
“These rules were last updated in 1996. Since that time, chiropractic professional best practices have evolved relative to policies, procedures, and educational standards required for accreditation of chiropractic colleges.”
In addition to proposing to maintain the commission's authority to accredit chiropractic schools, the rulemaking they want to undertake would:
“. . . identify established national and international chiropractic bodies, such as the Council on Chiropractic Education (CCE) and the Council on Chiropractic Education International (CCEI), citing their expertise in cost-effectively assessing and validating chiropractic schools and colleges that meet Washington's chiropractic educational requirements under chapter 18.25 RCW.”
Despite the assertions being made by the board, there is no reasonable rationale to insert the names of specific accrediting agencies into the rules. In fact, efforts have been underway over the past several years to remove so called “CCE Only” language from statutory and rule language throughout the United States. So if they were actually interested in so called “Best Practices” – they would not insert CCE language as this would be several steps backwards.
Attorneys have argued that such language appears designed to confer an economic advantage by active market players to one particular accrediting agency (CCE and CCEI).
This actions are despite admonitions from the United States Department of Education’s National Advisory Committee on Institutional Quality and Integrity (NACIQI) that this agency operates as a virtual cartel within the chiropractic profession and enjoys a near monopoly control on the educational, regulatory and licensing functions of the entire profession. This is done through language such as what the CQAC is considering for adoption.
In 1974 when the Council on Chiropractic education gained recognition from the United States Department of Education it encouraged the Federation of Chiropractic Licensing boards (FCLB) to push through changes in statutory and rule language in each state to make it mandatory to graduate from a school accredited by the CCE in order to be licensed in each state. The state boards, controlled by CCE supporters who sat on them, followed this instruction dutifully and several decades later the majority of states have CCE only language.
Washington State was NOT one of them – until now.
It is believed that the changes to this language are being pushed by political operatives from both the American Chiropractic Association and the University of Western States. Western States runs a chiropractic program in Washington’s neighboring state Oregon and is reportedly seeking to expand into Washington.
Washington has historically enjoyed a conservative chiropractic scope of practice while Western States and the ACA have been aggressively pushing to expand the chiropractic scope of practice nationwide. The idea is that since CCE trains primary care providers in broad body diagnosis and treatment that adopting them as the model accrediting agency would make it easier to expand the scope.
The Washington State Chiropractic Quality Assurance Commission is being urged to remember that its mandate is to protect the consumer public, and not to promulgate regulations which limit free market competition.
The following accreditation language has been recommended by the Foundation for Vertebral Subluxation and the International Federation of Chiropractors and Organizations in order to avoid any appearance of conflict of interest:
Each applicant shall be a graduate of a chiropractic school, college or program accredited by an accrediting agency recognized by the U.S. Secretary of Education. For those graduating from a chiropractic program outside the United States the applicant must have completed an educational program leading to a degree in chiropractic from an institution authorized to operate by the government having jurisdiction in which it is domiciled.
It is unknown at the time of this writing where the Washington State Chiropractic Association (WSCA) stands on this issue though 5 of the 14 members of the WSCA Board are dues paying ACA Members.
WSCA is the only chiropractic trade organization representing chiropractors in the state.
- Robert Perkes, DC - ACA Member
- Mark S. Jones, DC - ACA Member
- Shawn L. Gay, DC - ACA Member
- Garry Baldwin, DC - ACA Member
- Ron Wilcox, DC - ACA Member
- J. Michael Schweitzer, DC
- Phillip J. Kriss, DC
- Dusty DuBois, DC
- John Sim, DC
- Paul Reed, DC
- David Stemp, DC
- Diane M. Sherwood-Palmer, DC
- C. Randy Baze, DC
- David A. Butters, DC
In addition two of the 11 members of the Chiropractic Quality Assurance Commission are ACA members according to the ACA website:
- Gabe (Gary) Smith
- David Folweiler
The following information was provided by the Commission in regards to the Public Hearing:
You may submit written comments on the proposed rule through January 8, 2019:
Online: Submit your comments on the Department of Health’s rules comment site at
https://fortress.wa.gov/doh/policyreview/
Mail: Send your comments to:
Department of Health
Chiropractic Quality Assurance Commission
Bob Nicoloff, Executive Director
PO Box 47858
Olympia, WA 98504-7858
You may also provide comments in-person at the public hearing for these rules scheduled for:
January 10, 2019 at 10:00 a.m. at:
Doubletree by Hilton Seattle Airport – Meeting Room To Be Determined
18740 International Blvd
Contact via email at bob.nicoloff@doh.wa.gov or phone (360) 236-4924 with questions.
Robert J. Nicoloff
Executive Director
Chiropractic Quality Assurance Commission
Washington State Department of Health
(360) 236-4924| www.doh.wa.gov/CQAC
