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Final Staff Analysis of the Report Submitted by Dominica

 
Prepared October 2015
 
Background
 
In October 1997, the National Committee on Foreign Medical Education Accreditation (NCFMEA) first determined that the accreditation standards used by the Dominica Medical Board (the Board) to evaluate medical schools in Dominica were comparable to those used in the United States. In 2001 and again in 2007, the NCFMEA reaffirmed its prior determination that the standards and processes used by the Board for the evaluation of medical schools remained comparable. The NCFMEA also requested that the Board submit periodic reports describing its continuing accreditation activities.

The NCFMEA met in October 2013 to review the petition for continued comparability submitted by the Board, to include an update regarding how the Board evaluated the medical program at RUSM in the context of the learning outcomes report. The NCFMEA deferred their decision concerning Dominica's comparability pending the receipt and review of the report of the 2013 on-site visit; data on indicators that the Board will use to flag concerns for monitoring and continuing accreditation; and how the Board determines the adequacy of the medical school system for the assessment of student achievement and the program of monitoring the progress of students through their educational program. The country's submission is the subject of this analysis.
 
Summary of Findings
 
Based on its review of the information submitted by the country, Department staff concludes that Dominica provided information in response to the NCFMEA's request for a report of the outstanding issues requested at the fall 2013 meeting. This report specifically addressed the Board's action regarding the evaluation of the submission data for Ross University School of Medicine (RUSM).

With regard to the Board's review of the data in the assessment of RUSM, Department staff reviewed the information and documentation provided by the Board to include the data submissions from January 2014, October 2014, and April 2015 from RUSM, as well as a document that provided a comparative analysis of those submissions. The Board has stated that it will continue to collect and use the data for ongoing monitoring and accreditation reviews on an institutional level for trend analysis, but does not plan to assess an institution against benchmarks in individual areas, such as USMLE examination pass rates. Therefore, Department staff suggests that the Board provide more information regarding the Board's plans for using the data it collects from RUSM and how it intends to analyze such data to make judgments regarding accreditation and compliance with the country's standards.

With regards to the current accreditation activities, the Board provided accreditation review information and the dates of accreditation activities. In addition, the Board provided the final report from the focused site visit to RUSM in November 2014. That report requires ongoing monitoring that will require another focused site visit by November 2015. Department staff suggests that the Board provide more information regarding the outstanding findings and the Board's policies regarding granting accreditation despite continued compliance concerns with the Board's standards.
 
Staff Analysis
 
 
Current status of medical schools
 
Country Narrative
Ross University School of Medicine (“RUSM”) operates in Dominica and is accredited by the Dominica Medical Board (“Board”). The Board’s last full accreditation visit of the RUSM occurred in 2012. In December 2012, the Board reaccredited RUSM for a period of five years, subject to compliance with the Standards and Procedures for Certification of Medical Education Programmes.

As previously reported to the NCFMEA, All Saints University School of Medicine (“All Saints”) also operates in Dominica. All Saints has not pursued Dominica Medical Board accreditation, and the Board has not recognized or approved All Saints. The Board periodically reviews the All Saints website to determine whether it contains inaccurate or misleading statements regarding its relationship with the Board. For example, as previously reported to the NCFMEA, by letter dated October 14, 2011, the Board advised All Saints to remove promptly from its website an inaccurate and misleading statement regarding All Saint’s accreditation status. See Letter from D. Shillingford to J. Yusuf (Oct. 14, 2011) (Exhibit 1). As of January 19, 2015, All Saints’ website contained no mention of the Board.
 
Analyst Remarks to Narrative
The Board provided information and documentation concerning the current status of the medical schools operating in Dominica. Specifically, the Board provided the current accreditation status and review date of Ross University School of Medicine (RUSM), as well as documentation that the Board periodically reviews the activities of All Saints University School of Medicine to prevent against misleading or inaccurate information regarding its status with the Board.
 
Overview of accreditation activities
 
Country Narrative
On November 24 – 26, 2013, the Board conducted a focused site visit to RUSM at its Miramar, Florida location. The focused site visit was the recommended follow-up visit to the 2012 reaccreditation review. The final site visit report, as adopted by the Board, is located at Exhibit 2.

On November 17 – 19, 2014, the Board conducted a focused site visit to RUSM at its Miramar, Florida location. The focused site visit was the recommended follow-up visit to the 2013 focused site visit. Dominica expects the final site visit report to be finalized in February. Dominica will submit to the NCFMEA a copy of the final site visit report promptly after the Board has acted on it.

On September 8, 2014, the Board conducted a site visit to Queens Hospital and King George Hospital in Romford, Essex. The final site visit report is located at Exhibit 3.
 
Analyst Remarks to Narrative
Dominica provided information and documentation regarding the accreditation activities of the Medical Board of Dominica (Board). Specifically, the Board provided information and documentation concerning site visits to Miramar, Florida, and Essex, United Kingdom campuses of Ross University School of Medicine (RUSM).

With respect to the campuses of RUSM, the Board conducted site visits in November 2013 and November 2014 to the Miramar campus. The final report for the November 2013 site visit recommended a follow-up visit, which occurred in November 2014, to review the items that continue to be of concern to the site visitors. The Board stated that the final report from the November 2014 site visit has not been finalized, but should be available in February 2015. Department staff suggests that the Board provide the final report in response to this draft staff analysis.

Although the Board provided accreditation review information (in the previous section) and the dates of the on-site visits, it did not provide a summary of the meetings held and accreditation decisions reached, nor any accreditation conferences or training sessions held. Department staff suggests that the Board provide that information in response to this draft staff analysis.
 
Country Response
The Dominica Medical Board (Board) in pursuit of its responsibilities has been mindful of the Secretary of Education’s letter dated February 21, 2014, and it believes it has taken the necessary steps responsive thereto.

The Board is submitting as Exhibit A the final Team Report of the Focused Site Visit that was conducted in November 2014. The Team Report reflects the rigor and thoroughness with which the Board assesses a medical school’s compliance with the Board’s accreditation standards. As described in the site visit report, the 2014 focused site visit team concentrated on RUSM’s compliance with standards in the following areas in connection with which it has conducted ongoing monitoring since 2012: the Board-imposed enrollment cap, mission and objectives, governance and administration, clinical programs, faculty involvement, curriculum, resources, medical students, and academic advising (“2012 Standards to Monitor”). In certain of those areas, the focused site visit team found that RUSM is in compliance with pertinent Board standards. In the remaining areas, it found that although RUSM is in compliance with pertinent Board standards, ongoing monitoring is needed because (1) RUSM has appropriate policies, processes, resources or systems in place, but many initiatives have been recently implemented or modified in response to DMB input, and (2) although trends in data related to such policies, processes, resources, and systems are positive and aligned with desired outcomes, more time and data is needed to assess the impact of those initiatives. To carry out such ongoing monitoring, the site visitors recommended that the Board conduct another focused visit by November 2015 and continue to require RUSM to produce the data that the Board requested after the 2013 focused site visit. For more information about the focused site visit team’s findings and recommendations with regard to the 2012 Standards to Monitor as well as the adequacy of RUSM’s system in assessing student achievement and in application of a monitoring program that assesses student progress through the educational program, we refer you to the full text of Exhibit A. On April 16, 2015, the Board approved the site visit team's report and adopted the report's findings and recommendations.

The Board conducts in-person meetings to address accreditation matters and to render accreditation actions and decisions as needed. At this time, as previously reported to the NCFMEA, the Board accredits only RUSM. No formal accreditation decision has been necessary with regard to RUSM since early 2013 -- by letter dated January 9, 2013, the Board notified RUSM that it had decided to recertify the school for a period of five years, subject to compliance with the Board’s standards. Therefore, no such decisions have been rendered, and no in-person meetings to conduct such business have been required. No accreditation conferences or training sessions have been held recently, although the Board has held such training sessions from time to time and has plans to hold a training session before the end of 2015.

To supplement its January 2015 submission, the Board is submitting Exhibit B. On October 25, 2013, the Board conducted a site visit to Atlanta Medical Center in Atlanta, Georgia. Exhibit B is the final site visit report.
 
Analyst Remarks to Response
In response to the draft staff analysis, the Board provided the final report from the November 2014 site visit to RUSM, as well as a site visit to a new RUSM clinical site in Atlanta, Georgia. The final report requires ongoing monitoring in a couple of areas that will require another focused site visit by November 2015. More information is needed regarding the outstanding findings and the Board's policies regarding granting accreditation despite continued compliance concerns with the Board's standards.

The Board also provided additional narrative information concerning the Board and its accreditation activities, as required by this section.
 
Staff Conclusion: Additional Information requested
 
Laws and regulations
 
Country Narrative
Since Dominica’s last submission to the NCFMEA, no changes have occurred with respect to Dominica’s laws and regulations that affect accreditation of medical schools.
 
Analyst Remarks to Narrative
The Board states that there have been no changes in Dominica's laws or regulations that affect the accreditation of its medical schools since its last comprehensive review for comparability in fall of 2013.
 
Standards
 
Country Narrative
Since Dominica’s last submission to the NCFMEA, no changes have occurred with respect to the accreditation standards that the Board uses to evaluate and accredit medical schools.
 
Analyst Remarks to Narrative
The Board states that there have been no changes in the accreditation standards that the they use to evaluate and accredit medical schools in the areas listed since its last comprehensive review for comparability in fall of 2013.
 
Processes and procedures
 
Country Narrative
Since Dominica’s last submission to the NCFMEA, no changes have occurred with respect to the accreditation processes and procedures that the Board uses.
 
Analyst Remarks to Narrative
The Board states that there have been no changes in the accreditation processes and procedures used in the areas listed since its last comprehensive review for comparability in fall of 2013.
 
Schedule of upcoming accreditation activities
 
Country Narrative
The Dominica Medical Board is in the process of scheduling clinical site visits for 2015.
 
Analyst Remarks to Narrative
Although the Board stated that it is in the process of scheduling clinical site visits for 2015, it did not provide a list of any upcoming accreditation meetings and/or on-site visits to medical schools, branch campuses, and/or clinical clerkship sites. Department staff suggests that the Board provide that information in response to this draft staff analysis.
 
Country Response
The Board currently has no accreditation-related meetings scheduled in the immediate future. At this time, the Board accredits only one medical school (i.e., RUSM); accordingly, it meets as required to address accreditation matters related to that medical school. In the final site visit report, the 2014 focused site visit team recommended that the Board conduct another focused site visit to RUSM by November 2015. See Exhibit A at page 20. On April 16, 2015, the Board approved the site visit team's report and adopted the report's findings and recommendations.

In addition, as described in response to Question 4 ("Data on performance indicators..."), on April 15, 2015 RUSM submitted certain requested data and the Board is in the process of reviewing that data. The Board Chair plans to convene at the appropriate time a Board meeting to consider RUSM’s data submission.

As requested by the draft staff analysis, the Board is submitting as Exhibit C a list of clinical clerkship sites to be visited in 2015.
 
Analyst Remarks to Response
In response to the draft staff analysis, the Board submitted additional information and documentation concerning upcoming accreditation meetings and on-site visits to medical schools and clinical clerkship sites of RUSM.
 
Staff Conclusion: Comprehensive response provided
 
Outstanding Issues
The results of the 2013 site visit to the Ross University School of Medicine;
 
Country Narrative
See Exhibit 4.
 
Analyst Remarks to Narrative
The Board provided a narrative explanation of the accreditation process of Ross University School of Medicine (RUSM) and the on-site visit report to RUSM in a prior section. The recommendations of the site visitors were to conduct another on-site visit in 2014 to continue to monitor the progress of RUSM in the cited areas. The Board stated in a previous section that the final report from the November 2014 site visit has not been finalized, but should be available in February 2015. Department staff suggests that the Board provide the final report in response to this draft staff analysis.
 
Country Response
The Board is submitting as Exhibit A the final Team Report of the Focused Site Visit that was conducted in November 2014. For additional information, see our response to Question 1 (“Overview of accreditation activities”).
 
Analyst Remarks to Response
In response to the draft staff analysis, the Board provided the final report from the November 2014 site visit to RUSM.
 
Staff Conclusion: Comprehensive response provided
 
Data on performance indicators and whether these are in compliance with the standards or outcome (or trends of outcomes) that the Board will use to flag concerns for monitoring and continued accreditation; and,
 
Country Narrative
See Exhibit 5.
 
Analyst Remarks to Narrative
The Board provided information and documentation concerning data on performance indicators and whether these performance indicators are in compliance with the standards or outcomes (or trends of outcomes) that the Board will use to flag concerns for monitoring and the continued accreditation of Ross University School of Medicine (RUSM). Specifically, the Board provided the required data submissions from January 2014 and October 2014 from RUSM, as well as a document that provided a comparative analysis of those submissions.

The Board has stated that it will continue to collect and use the data for ongoing monitoring and accreditation reviews on an institutional level for trend analysis, but does not plan to assess an institution against benchmarks in individual areas, such as USMLE examination pass rates. The Board states that no single benchmark provides a comprehensive assessment of the quality of a medical education program.

The Board has already requested the submission of the same data twice in 2015 to provide for a longitudinal analysis. The Board stated that the next submission of the data is due March 1, 2015. Department staff suggests that the Board provide the March 2015 data submission in response to this draft staff analysis.
 
Country Response
As requested by the draft staff analysis, the Board is submitting as Exhibit D a data submission provided to the Board by RUSM. The Board is in the process of reviewing the data submission for purposes of ongoing monitoring. The Board waited for the final report from the November 2014 site visit before it issued the data request to RUSM; as a result, the Board set April 15, 2015 (not March 1, 2015, as previously reported) as the deadline for submission of the data. The data submission that RUSM submitted to the Board on April 15 (Exhibit D) provided a preliminary set of data modeled on prior data requests; the Board plans to request certain follow-up data for purposes of consistent longitudinal assessment. In addition, the Board Chair plans to convene at the appropriate time a Board meeting to consider RUSM’s data submission.
 
Analyst Remarks to Response
In response to the draft analysis, the Board submitted the April 2015 data submission from RUSM. More information is needed regarding the Board's plans for using the data it collects from RUSM and how it intends to analyze such data to make judgments regarding accreditation and compliance with the country's standards.
 
Staff Conclusion: Additional Information requested
 
How the Board determines the adequacy of the medical school system in assessing student achievement and in the application of a monitoring program that assesses the progress of students through their educational programs.
 
Country Narrative
See Exhibit 6.
 
Analyst Remarks to Narrative
The Board provided narrative information concerning its determination of the adequacy of RUSM's system in assessing student achievement, and in the application of a monitoring program that assesses the progress of students through their educational programs. Specifically, the Board noted the accreditation standards that directly address this issue and provided the findings of the 2014 on-site review in these areas to demonstrate the review and assessment.