Provides Facts Regarding Upcoming Hearing
I would like to address some concerns, and provide you with some evidence. I have witnessed heated exchanges involving outrageous statements on both sides. Please, let’s begin by addressing issues rather than unsubstantiated claims and rhetoric attacking individuals and organizations.
There have been claims that if CCE lost recognition by the Department of Education, student loan eligibility would end, licensure would come to a halt in a majority of states, and even that existing DCs could not renew their licenses.
First and foremost, I am not aware of any organization that has asked that CCE’s recognition be withdrawn at this time. For example, the Foundation for Vertebral Subluxation has asked for a deferral. This means that a decision on CCE’s renewal petition would be deferred for one year, during which time CCE would retain recognition.
It must also be remembered that NACIQI serves in an advisory capacity. Final decision making authority is vested in the Secretary of Education, not NACIQI. There has been disagreement in the past. For example, NACIQI’s recommendation that CCE be required to demonstrate compliance with 34 C.F.R. Section 602.13, dealing with wide acceptance of the agency’s standards, policies, procedures, and decisions was rejected by the Assistant Secretary of Education.
What would be the consequences in the unlikely event that CCE was denied continued recognition by the Department of Education?
Some issues are factual in nature, and can be easily verified. In addition to being a chiropractor, I am an attorney who completed a certificate program in legislative drafting. However, don't accept my word on factual issues. Check it out for yourself. Check to see which colleges have regional accreditation. Check the state laws. Demand evidence from anyone making claims regarding student loan eligibility, licensure, and drugs.
*Access to licensure.
If CCE were to lose Department of Education recognition, state boards would not disband. State boards existed long before CCE! Furthermore, in reviewing the list of state requirements forwarded to me by IFCO, it appears that if CCE were to lose Department of Education recognition, it would have very little direct impact on licensure eligibility.
Iowa, NH, Pennsylvania, and perhaps Utah would be affected. I say “perhaps” for Utah because the language is ambiguous and poorly drafted.
Most states requiring CCE accreditation for licensure do not have language requiring Department of Education recognition of CCE. CCE could continue to operate, as it did before it was recognized by the then DHEW. In fact, an agency must have two years of “accreditation activity” before it can apply for Department of Education recognition.
Here is an FCLB link to the various boards if you want to check out what the laws actually say.
Another claim is that existing licensees would not be able to renew their licenses “if CCE went away.” First, there is a significant difference between CCE losing recognition by the Department of Education, and CCE shutting down or “going away.” As previously mentioned, CCE could, and undoubtedly would, continue to operate.
Many DCs (myself included) graduated from chiropractic college before CCE existed, or before it received federal recognition as an accrediting agency. There are also DCs in practice who graduated from schools that are no longer in operation. There is no problem with license renewal provided CE and other requirements are met.
State boards will not shut down were CCE to lose Department of Education recognition.
*Student loans.
All US chiropractic colleges, except Life-West, are regionally accredited as well as holding CCE accreditation for their DC programs. Regionally accredited institutions are eligible for Title IV (student loan) funds.
The suggestion that loss of CCE accreditation would mean the end of student loans for any school other than Life-West is not true. Life-West is currently the only college which holds institutional accreditation with CCE. Furthermore, Brian Kelly, president of Life-West, stated that they would pursue regional accreditation. Even in the highly unlikely even that CCE lost status with the Department of Education, there would be a transition period during which they could seek another accreditor.
To verify the accreditation status of an institution, visit http://www.chea.org/search/default.asp
For a concise description of requirements for an institution to qualify for Title IV (student loan) eligibility, see: http://ifap.ed.gov/fsahandbook/attachments/0910FSAHbkVol2Ch1School.pdf
Please ask anyone who disagrees to cite their sources. In my opinion, student loan fear mongering is disingenuous.
*Drugs
Everyone seems to be missing the clever maneuver to sneak in non-prescription drugs. If the Cartel promoted the inclusion of OTC drugs in the scope of chiropractic practice, there would be controversy. However, by mentioning only prescription drugs, they quietly endorsed, de facto, the inclusion of OTCs. When the OTC issue is brought up in back rooms, dissenters are reportedly told that unless OTCs are included in our scope of practice, DCs will not be permitted to recommend or dispense supplements. This is simply untrue. A scope of practice can be crafted that includes nutritional supplements without including OTC drugs. This was done here in NJ.
In some cases, the only difference between an OTC and prescription drug is dosage and labeling. Some drugs formerly requiring a prescription are now available OTC.
Chiropractic is not drugless if over the counter drugs are included in the practice of chiropractic. A statement excluding only prescription drugs does not make chiropractic drugless.
Please consider the issues carefully, check the facts, and keep in mind the words of Ayn Rand:
“It is a moral crime to give money to support ideas with which you disagree… It is a moral crime to support your own destroyers.” Sanction of the Victim
Christopher Kent DC, JD
President, Foundation for Vertebral Subluxation
