CCE Hearing Set for December 2013

Foundation for Vertebral Subluxation
CCE Hearing Set for December 2013

Over 70 Chiropractic Groups Call for Submission of Written Comments

The DaVinci Group, a coalition of more than seventy organizations in the chiropractic profession ranging from national associations to state associations to practice management groups to technique oriented groups to other special interest communities recently issued a Call for chiropractors throughout the profession to provide written comments and requests for oral statements to the United States Department of Education.

Here is the text of the release from the DaVinci Group:

The National Advisory Committee on Institutional Quality and Integrity (NACIQI) hearing to review the Council on Chiropractic Education has been scheduled and we need you to make a comment to the agency by FRIDAY. NACIQI is the agency that makes recommendations directly to the department of education regarding the CCE’s accreditation to be the chiropractic accrediting agency.

Here is what we need you to do:

1 – Submit a written comment by email to NACIQI. If you represent a chiropractic organization this is ESPECIALLY IMPORTANT. Also student comments are also very important to be received. Details on this below.
2 – Request an opportunity to speak at the NACIQI hearing, especially if you represent a group of chiropractors. Details on this below.
3 – Mark you calendars to be at the NACIQI meeting scheduled for December 12-13 in the Washington, DC area. We will send more information as soon as the specific times and location has been announced.

The deadline is FRIDAY SEPTEMBER 6th – so ACT NOW! Your silence equals consent for the status quo and direction the CCE is moving. Take few minutes to RESPOND NOW for the future of chiropractic!

Also please forward this to as many chiropractors and chiropractic students as you know and urge them to also have their voice heard!

The DaVinci Steering Committee

Announcement of an open meeting of the National Advisory Committee on Institutional Quality and Integrity (NACIQI) from the Federal Register

The meeting is scheduled for December 12-13. Written comments are due on September 6. Requests for oral comments are due on September 6

DETAILS AND DIRECTIONS FOR WRITTEN AND ORAL COMMENT SUBMISSIONS – DEADLINE IS FRIDAY SEPTEMBER 6th

Submission of Written Comments:

1) Written comments must be received by September 6, 2013, in the accreditationcommittees@ed.gov mailbox and include the subject line ``Written Comments: re (agency name).''  ALL SUBMITTED COMMENTS BECOME PART OF PUBLIC RECORD SO THE MORE RESPONSES THE BETTER!
2) Email must include the name, title, affiliation, mailing address, email address, telephone and facsimile numbers, and Web site (if any) of the person/group making the comment.
3) Comments should be submitted as a Microsoft Word document or in a medium compatible with Microsoft Word (not a PDF file) that is attached to an electronic mail message (email) or provided in the body of an email message. 
4) Comments should be directed towards the CCE’s compliance with the Criteria for the Recognition of Accrediting Agencies, the Criteria and Procedures for Recognition of State Agencies for Approval of Public Postsecondary Vocational Education, or the Criteria and Procedures for Recognition of State Agencies for Approval of Nurse Education, as appropriate, which are available at http://www.ed.gov/admins/finaid/accred/index.htmlSEE

TALKING POINTS BELOW

5) All of these directions MUST be followed by the deadline to the email address listed in this notice, and in accordance with these instructions, become part of the official record.

Submission of Requests to Make an Oral Comment: 

1) Submit a request by email to the accreditationcommittees@ed.gov mailbox. Please do not send material directly to NACIQI members. 
2) Requests must be received by September 6, 2013, and include the subject line ``Oral Comment Request: re (agency name).'' 
3) The email must include the name, title, affiliation, mailing address, email address, telephone and facsimile numbers, and Web site (if any) of the person/group requesting to speak. 
4) All individuals or groups submitting an advance request in accordance with this notice will be afforded an opportunity to speak. Comments may not exceed three minutes, except at the discretion of the NACIQI Chair exercised on a case-by-case basis during the meeting. 
5) Each request must concern the recognition of a single agency or institution tentatively scheduled in this notice for review, be no more than one page (maximum), and must include:  
a. The name, title, affiliation, mailing address, email address, telephone and facsimile numbers, and Web site (if any) of the person/ group requesting to speak; and,  
b. A brief summary of the principal points to be made during the oral presentation.
6) There will also be an opportunity to sign up to speak the day of HOWEVER it will be limited to a total of 15 minutes for all day-of speakers to be sure to request an oral comment opportunity by Friday.

WHAT TO INCLUDE IN YOUR COMMENTS

Remember that this FRIDAY is the deadline so do this now.  Be sure to FOLLOW THE DIRECTIONS ABOVE for submission and maximum impact. 

Speaking Points for your Comments

You can include anything you like in your comments, and the more unique your comments the better so that everyone does not send the exact same letter. However, the concerns you raise need to be related to the Department of Education Standards.  IT IS CRITICAL THAT GROUPS WRITE LETTERS AS WELL. Here are a few points you can raise in your letter:

Request that the Department of Education place the Council on Chiropractic Education on probation as it is not meeting the needs of the chiropractic profession.

That you believe the CCE is not complying with the Code of Federal Regulations – Title 34 – 602.13
34 CFR 602.13 - Acceptance of the agency by others.

The agency must demonstrate that its standards, policies, procedures, and decisions to grant or deny accreditation are widely accepted in the United States by:
(a) Educators and educational institutions; and
(b) Licensing bodies, practitioners, and employers in the professional or vocational fields for which the educational institutions or programs within the agency's jurisdiction prepare their students.

State that as an organization (or practitioner) you do not accept the direction the CCE is headed and that you feel it does not adequately represent the profession as a whole. 

The CCE has confused and removed essential language to the practice of chiropractic, the term subuxation, and unambiguous language regarding vertebral subluxation is critical for the chiropractic profession.

The CCE continues to advance chiropractic towards the direction of inclusion of drugs and surgery in chiropractic practice, and this is not agreeable to you.

The CCE decision-makers promote an expansive agenda seeking to use the accreditation process to drive the practice of chiropractic in a non-chiropractic, allopathic direction. 

The CCE’s governance is of concern due to its self-propagating nature.

The CCE needs to adopt:

a) Mechanisms for Councilor appointment/election that eliminate the current self-sustaining and perpetuating nature of the Council and broaden the base of participation in the elections process.  
b) Reforms in the current elections processes and procedures to allow for greater autonomy in nomination and voting.
c) An expansion and transparency of the CCE Academy of site team members who go to schools.

FRIDAY IS THE DEADLINE – ACT NOW!
If you care about chiropractic, your comments are needed and plan to be at the hearing in December!

Foundation for Vertebral Subluxation