The Federation of Chiropractic Licensing Boards (FCLB) has been steadily increasing its influence over chiropractic post graduate education and regulation. Through its Recognized Chiropractic Specialties Program (RCSP), the FCLB aims to centralize control over the approval and recognition of chiropractic specialty programs. This white paper outlines the significant dangers posed by this expansion of power and why it is crucial for state boards, chiropractors, and providers of postgraduate specialty programs to reject these attempts at furthering their monopolistic control.

Background

The FCLB, funded primarily by the National Board of Chiropractic Examiners (NBCE) and state regulatory boards, unfortunately wields considerable power and influence in the chiropractic community.
The FCLB's PACE program already controls much of the postgraduate continuing education (CE) in chiropractic and heir contract includes language that restricts freedom of speech in educational programs. Now, through RCSP, the FCLB seeks to take further its control over post graduate education and assert itself as the authority on chiropractic specialty programs, further consolidating its control over state regulation, postgraduate training and certification.

The FCLB and Its RCSP Network

FCLB's RCSP Leadership

- Beth Ehlich DC (RCSP Chair): District V Director, FCLB Board Chair and South Carolina Chiropractic Board Member
- Beth Kidd: Executive Director of the Oklahoma Board of Chiropractic.
- Laurence Adams DC, DACNB: FCLB Fellow & Vice Chair of the California Board of Chiropractic
- Julie Strandberg: Executive Director of the Nevada Chiropractic Physicians Board
- Julie Mayer-Hunt DC: Representative of the Upper Cervical Council of the ICA
-Steven Gould DC, DACBR: FCLB Fellow & Board Member Kansas State Board of Healing Arts

The RCSP Mission

The RCSP claims its mission is to establish criteria and procedures for the multijurisdictional recognition of chiropractic specialty program providers. It claims to:

1. Provide a dependable basis for choosing chiropractic specialty programs.
2. Assist FCLB member boards in evaluating chiropractic specialty providers and programs.
3. Improve the quality of chiropractic specialty programs.
4. Protect the public through advancements in chiropractic specialty programs.

Analysis of RCSP's Impact

Monopoly on Postgraduate Education

The RCSP allows the FCLB to control which programs are recognized, effectively creating a monopoly on postgraduate chiropractic specialty education. This centralization restricts the diversity of educational opportunities and stifles innovation by limiting program approvals to those that align with FCLB's criteria.

Undermining the Authority and Autonomy of Chiropractic Schools

The Recognized Chiropractic Specialties Program (RCSP) not only poses risks to state regulatory boards and practitioners but also significantly undermines the authority and autonomy of chiropractic schools. These institutions, which house many postgraduate certification programs, are already accredited by the Council on Chiropractic Education (CCE) and regional accrediting bodies. The RCSP’s encroachment into this space threatens the integrity, independence, and academic freedom of these educational institutions.

Chiropractic schools undergo rigorous evaluation of their post graduate programs. These processes ensure that specialty programs meet high standards of educational quality, relevance, and effectiveness. These evaluations encompass curriculum, faculty qualifications, administrative processes, and student outcomes, ensuring that chiropractic programs provide robust and comprehensive specialty education.

RCSP’s Redundant Oversight

By introducing its own layer of recognition and approval, the RCSP creates a redundant and unnecessary oversight mechanism. This duplication not only adds bureaucratic complexity but also undermines the well-established evaluation processes already in place.

The RCSP’s intervention erodes the autonomy of chiropractic schools by imposing external control over their postgraduate certification programs. These programs, tailored to meet the specific educational needs and strategic goals of each institution, are now subject to the RCSP’s standardized criteria. This external imposition will stifle innovation, restrict academic freedom, and limit the ability of chiropractic schools to develop unique and cutting-edge programs that address emerging trends and needs in chiropractic care.

Chiropractic schools are centers of academic excellence and innovation. The RCSP’s standardized and rigid criteria will hinder these institutions’ ability to develop and offer diverse and innovative programs. By constraining program development to fit RCSP’s mold, there is a risk of homogenizing education and limiting the scope for creative and specialized training that responds to the evolving needs of the chiropractic profession and its patients.

The introduction of the RCSP undermines the well-established evaluation frameworks that ensure the quality and integrity of chiropractic specialty education. It imposes redundant oversight, erodes institutional autonomy, and places additional financial and administrative burdens on chiropractic schools.

Financial and Administrative Burden

Specialty programs seeking RCSP recognition must pay significant fees, which can be prohibitive, particularly for non-profit providers.

The fees include:

- Initial application fees ranging from $500 to $1,000.
- Annual recognition fees of $1,000 to $2,000.
- Renewal fees and potential appeal costs, which add further financial strain.

These costs will discourage smaller, innovative programs from seeking recognition, thereby limiting the available options for chiropractors.

In the end the RCSP is simply another mechanism for the self appointed FCLB to extract money unnecessarily from the chiropractic profession in order to fund its attempts to regulate it and dictate how chiropractic is practiced.

Overreach and Lack of Accountability

By positioning itself as the authority on specialty programs, the FCLB effectively usurps the regulatory power of state boards. While the FCLB claims that boards retain ultimate authority, the delegation of program review and approval to the RCSP diminishes the boards' direct oversight capabilities. This overreach is particularly concerning given the potential for conflicts of interest and lack of transparency in the RCSP's review process.

Incestuous Relationships and Conflicts of Interest

Overlapping Roles and Conflicts

The FCLB, NBCE, and state regulatory boards are interlinked through overlapping roles and shared individuals. Members of the FCLB board, RCSP committee, and state boards often circulate between these positions, creating a network of influence that raises serious concerns about impartiality and conflicts of interest. This incestuous relationship compromises the integrity of the regulatory process and undermines the trust of the chiropractic community.

RCSP Leadership

The leadership of the Federation of Chiropractic Licensing Boards (FCLB) Recognized Chiropractic Specialties Program (RCSP) is plagued by overlapping roles and conflicts of interest, raising significant concerns about the integrity and impartiality of the regulatory process. Key members of the RCSP leadership simultaneously hold influential positions within state regulatory boards and trade organizations, creating an incestuous network that compromises their ability to act independently and without bias.

Beth Ehlich DC

- Roles: RCSP Chair, District V Director, FCLB Board Chair, and South Carolina Chiropractic Board Member.
- Conflict: As the Chair of both the RCSP and the FCLB Board, as well as a member of the South Carolina Chiropractic Board, Dr. Ehlich is in a position to influence the approval and recognition of chiropractic specialty programs at multiple levels, potentially prioritizing the interests of the FCLB over state-specific needs and standards.

Beth Kidd

- Roles: RCSP Leadership, Executive Director of the Oklahoma Board of Chiropractic.
- Conflict: Ms. Kidd's dual roles place her in a position where she could influence the regulatory decisions in Oklahoma while promoting the RCSP's agenda, creating a potential conflict between her duties to the state board and her involvement with the FCLB.

Laurence Adams DC, DACNB

- Roles: FCLB Fellow, Vice Chair of the California Board of Chiropractic.
- Conflict: Dr. Adams' involvement as a Fellow of the FCLB and Vice Chair of the California Board of Chiropractic presents a clear conflict of interest, as he can potentially sway both organizations' decisions, undermining the impartiality of the regulatory process.

Julie Strandberg

- Roles: RCSP Leadership, Executive Director of the Nevada Chiropractic Physicians Board.
- Conflict: Ms. Strandberg's dual roles enable her to influence the regulatory framework in Nevada while advancing the FCLB's RCSP agenda, which could lead to decisions that favor the FCLB's interests over those of the state's chiropractors and patients.

Julie Mayer-Hunt DC

- Roles: RCSP Leadership, Representative of the Upper Cervical Council of the International Chiropractors Association (ICA).
- Conflict: Dr. Mayer-Hunt's representation of a specialty council within the ICA, combined with her role in the RCSP, raises concerns about the potential for biased decision-making that favors her council's interests over broader chiropractic education standards.

Steven Gould DC, DACBR

- Roles: FCLB Fellow, Board Member of the Kansas State Board of Healing Arts.
- Conflict: Dr. Gould's roles as both an FCLB Fellow and a board member of the Kansas State Board of Healing Arts create a situation where he influences the regulatory process in Kansas while promoting the

FCLB's initiatives, leading to potential conflicts between state and organizational priorities.

Implications of Overlapping Roles

The overlapping roles and relationships within the RCSP leadership not only compromise the impartiality of the regulatory process but also undermine the trust of the chiropractic community. These incestuous connections create an environment where decisions can be swayed by personal and organizational interests, rather than being based on merit and the best interests of practitioners and patients. It is crucial for the chiropractic community to recognize and address these conflicts of interest. The integrity of chiropractic education and regulation depends on transparent and independent oversight. Rejecting the FCLB's RCSP and advocating for greater separation between regulatory bodies, private corporations and trade organizations will help ensure that decisions are made impartially and in the best interests of the profession and public health.

Financial Ties and Influence

The FCLB is funded primarily by the NBCE, which in turn is funded by student loan money. Additionally, state regulatory boards, using taxpayer dollars, fund their memberships in the FCLB and cover the costs for board members to attend FCLB meetings. This financial interdependence further entangles the interests of these organizations and compromises their ability to operate independently and without bias.

Dangers of FCLB Control

Compromised Autonomy of State Boards

State boards, already under-resourced and overworked, may feel pressured to delegate the review of specialty programs to the RCSP. This delegation can lead to a loss of local control and the ability to tailor program approvals to specific state needs and standards.

Erosion of Educational Quality

The FCLB's control of program approval will lead to a homogenization of chiropractic education, where programs must conform to the FCLB's standards rather than fostering diverse and innovative approaches to chiropractic care.

Financial Exploitation

The substantial fees associated with RCSP recognition place a financial burden on program providers, which could be passed on to chiropractors and, ultimately, to patients. This exploitation undermines the accessibility and affordability of postgraduate chiropractic education.

Recommendations

Reject RCSP Recognition

State boards, specialty program providers, schools, trade associations and practitioners should reject the FCLB's RCSP recognition. By maintaining control over program approvals, state boards can ensure that programs meet local standards and needs without succumbing to the financial and administrative burdens imposed by the FCLB.

Promote Transparency and Accountability

Both state boards and specialty program providers should advocate for greater transparency and accountability in the evaluation and approval of chiropractic specialty programs. This advocacy includes ensuring that review processes are free from conflicts of interest and that decisions are made based on merit and quality instead of a Good Ole' Boy network.

Conclusion

The FCLB's efforts to expand its control over chiropractic specialty programs through the RCSP pose significant dangers to the autonomy of state boards, the quality and diversity of chiropractic post graduate education, and the financial well-being of program providers and practitioners. It is imperative for the chiropractic community to reject these attempts at monopolistic control and to promote a more decentralized and transparent approach to postgraduate education and certification.