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Final Staff Analysis of the Report Submitted by RCVS

 
Prepared May 2015
 
Background
 
Effective July 1, 2015, the U.S. Department of Education (Department) is charged with determining whether a foreign accrediting agency or organization (agency) is acceptable to the Secretary of Education for the purpose of evaluating veterinary programs and, therefore, access of those programs to participate in Federal student aid funding programs (Section 600.56(a)(4)). The Royal College of Veterinary Surgeons (RCVS or the agency) currently accredits foreign veterinary programs that participate in such funding programs and has submitted a petition for review.
 
Summary of Findings
 
Based on its review of the information and documentation submitted by RCVS, Department staff concludes that the agency has provided information in response to the Department's request in conjunction with the new U.S. regulatory requirement regarding the review of foreign veterinary accrediting agencies. Therefore, the agency can be determined to be acceptable to the Secretary of Education for the purpose of evaluating veterinary programs for Federal purposes. (See CFR §600.56(a)(4) for the guiding regulation). The agency will receive an official notification letter from the Department which will also explain the length of the acceptability determination.
 
Staff Analysis
 



PART 1: Entity Responsible for the Accreditation/Approval of Medical Schools
 
Accreditation System and Authority, Question 1
 
Agency Narrative
The Royal College of Veterinary Surgeons (RCVS) is the sole statutory regulatory body for the veterinary profession in the United Kingdom of England, Scotland, Wales and Northern Ireland (UK). It operates under primary national legislation (Item 1, The Veterinary Surgeons Act 1966), and is also designated as the “Competent Authority” for the veterinary profession under European Union legislation (VSA, Section 1a). It is constituted under a Royal Charter, the first of which was granted in 1844, followed by various updated Charters, with the most recent Royal Charter (Item 2, Royal Charter) coming into effect on 17th February 2015, bringing veterinary nurses into full regulation under RCVS.
Its role as a Chartered regulator is to set, uphold and advance the educational, ethical and clinical standards of veterinary surgeons and veterinary nurses.
Under the Veterinary Surgeons Act, its primary roles are
a) to keep the register of veterinary surgeons eligible to practise in the UK,
b) set and monitor standards for veterinary education, and
c) regulate the professional conduct of veterinary surgeons through its Disciplinary Committee procedures.

It undertakes other activities under its wider Charter powers, including accrediting veterinary practices and premises, granting accredited Specialist and Advanced Practitioner status to veterinary surgeons of specialist and advanced standing, running examinations for the award of postgraduate certificates and diplomas, and maintaining the professional register of veterinary nurses, setting and monitoring standards for veterinary nursing, and running an investigation and disciplinary process for veterinary nurses, alongside that for veterinary surgeons.

The RCVS’s authority and statutory obligation to accredit veterinary schools comes under primary national legislation, the Veterinary Surgeons Act 1966 (item 1). Section 3 of the Act specifies that those who hold a degree from a UK veterinary school which has received a recognition order are entitled to be registered as Members of RCVS. Only Members of RCVS have the right to practise veterinary surgery in the UK. Membership of the RCVS therefore constitutes the UK “licence to practise” for veterinarians. Section 5 of the Act gives RCVS the duty to supervise courses of study followed by students training to be veterinary surgeons in the UK. The Act specifies that RCVS can appoint visitors to visit universities and to observe examinations. In addition to visiting universities, the Act allows RCVS to request other information from universities “as to the courses of study and examinations leading to the degree to which the recognition order relates”. Under this provision, RCVS is able to monitor standards at UK universities on a regular basis, not just through the formal process of periodic accreditation visits.

Under the Act, RCVS advises the Queen’s Privy Council on whether a UK university should have a recognition order. However, this is a historical technicality and, to all intents and purposes, the decision on whether or not to approve a given degree programme is made by the RCVS. The official statutory Recognition Order is issued by the Privy Council and remains in place until RCVS advises the Privy Council otherwise. RCVS also accredits non-UK veterinary degrees, for example in Australia and New Zealand, and South Africa under a separate section of the Act.

The constitution of RCVS’s governing Council is set out in the legislation (Item 1, VSA, Section 1). The Council currently comprises 42 members: 24 are elected veterinary surgeons, plus two members are appointed from each UK university with a veterinary school (seven universities), of whom one from each university must be a veterinary surgeon; and a further four Council members are appointed by the Privy Council. There is a mix of veterinary surgeons and lay representation on the Council, although registered veterinary surgeons must always be in the majority.
There are a series of senior committees reporting to Council, one of which is the Education Committee which has powers delegated to it by Council and to its sub-committee (the Primary Qualifications Sub-committee) to operate the accreditation process for veterinary degrees.
 
Analyst Remarks to Narrative
The agency is the clearly designated entity responsible for evaluating the quality of veterinary education in the United Kingdom of England, Scotland, Wales and Northern Ireland (UK). Specifically, the agency provided its constitution under Royal Charter (first granted in 1844) and The Veterinary Surgeons Act of 1966 as the legislation that confers the authority to evaluate and accredit veterinary schools in the UK. The agency is also designated as the “Competent Authority” for the veterinary profession under European Union legislation.

 
Accreditation System and Authority, Question 2
 
Agency Narrative
The RCVS has a defined set of accreditation standards and procedures for veterinary degrees. These are reviewed periodically, and the most recent review was completed in February 2015. (Item 3, “RCVS standards and procedures for the accreditation of veterinary degrees”, February 2015). As the sole accreditation agency for veterinary degrees in the UK, RCVS has full statutory authority under the Veterinary Surgeons Act to set standards and operate the accreditation process. For UK veterinary degrees, the Veterinary Surgeons Act requires that RCVS reports to the UK’s Privy Council (the cross governmental and cross departmental chamber reporting to the Queen), and sends the Privy Council a copy of the most recent accreditation report for each university. (See http://privycouncil.independent.gov.uk/privy-council/ for an explanation of the role of the Privy Council and http://privycouncil.independent.gov.uk/work-of-the-privy-council-office/professional-bodies/ for description of its role in overseeing certain statutory regulatory bodies such as the RCVS.)

RCVS works collaboratively with other accrediting agencies in Europe (The European Association of Establishments of Veterinary Education – EAEVE), Australia and New Zealand (The Australasian Veterinary Boards Council – AVBC), North America (The American Veterinary Medical Association’s Council on Education – AVMA) and South Africa (The South African Veterinary Council – SAVC). RCVS invites visitors and observers from these other international agencies to join its visitation teams. RCVS participates in the periodic meetings of the International Accreditors Working Group, which works to harmonise standards and operating procedures to ensure comparable international standards for veterinary education.

When reviewing its own accreditation standards and procedures, RCVS works through its Education Committee and its Primary Qualifications sub-committee to develop standards and procedures, as well as taking these other agencies’ systems into account to ensure systems are comparable internationally. RCVS’s committees are made up of leading veterinary surgeons from practice and academia. Committees are serviced by a team of RCVS full time staff who are responsible for administering the system at operational level.

RCVS accreditation site visits take 5 days, and are undertaken by a team of at least 6 visitors at least every 7 years. The university must provide a Self Evaluation Report (SER) two months before the visit, using the template provided. (see item 9 and 10, Liverpool’s 2-stage self evaluation report, prepared against the template from the old RCVS criteria in operation at the time (item 4, old RCVS criteria 2011) Additional supporting documentation, such as minutes of meetings, staff CPD records, examination and teaching material, and access to internal electronic information systems (intranet) is provided during the visit in a base room for consideration by the visitors. Follow-up visits may be undertaken with a smaller visiting team over a shorter timescale to check on progress in meeting particular recommendations from a previous visit (see items 11 and 12 for example of a follow up visit to Nottingham).
Attached documents:
Item 9, Liverpool SER1, - part 1 of a self evaluation report - prepared in accordance with RCVS's previous accreditation criteria (item 4)
Item 10, Liverpool SER2, - part 2 of a self evaluation report - to be read in conjunction with item 9.
Item 11, Liverpool site visit report 2012 - the resulting visitors' site visit report
Item 12, Nottingham site visit report 2011, - example of a site visit report to a new veterinary school
Item 13, Nottingham follow up visit report 2014 - example of a follow up visit report to the new veterinary school

RCVS requires accredited veterinary schools to report annually, using a standard template. (See item 14, RCVS Annual monitoring form 2014).
The RCVS annual monitoring report form (item 14) requires schools to report on any substantive changes. Data provided in the reports also allows RCVS to monitor trends from one year to the next within each school (eg. in staff student ratios, clinical case load etc.). The reports are considered annually by Primary Qualifications Sub-Committee which will make a judgement as to whether any of the reported changes are significant enough to warrant an additional site visit outside the usual 7 year cycle, or whether additional information needs to be provided by the school. The Veterinary Surgeons Act allows RCVS to ask veterinary schools for information about their programme at any time, and RCVS is able to act upon any intelligence it receives about how a programme is being delivered and its standards. RCVS is also legally entitled under the Veterinary Surgeons Act to send visitors to observe examinations at universities.
 
Analyst Remarks to Narrative
The agency has a clearly defined accreditation system in place for evaluating the quality of veterinary education in the United Kingdom of England, Scotland, Wales and Northern Ireland (UK). Specifically, the agency described comprehensively its accreditation standards and procedures, as well as providing documentation of implementation. The agency is the recognized licensing and accrediting entity for veterinary programs within the UK.
 
Analyst Remarks to Response
Although not included in the e-Recognition system, the agency provided its responses to the questions (d) - (g) of Part 3 in this section. The attached document provides the answers to those specific questions.

Overall, the agency provided documentation to demonstrate that it has and implements a comprehensive on-site review process for veterinary schools, ongoing monitoring and regular reevaluation of veterinary schools, substantive change policy and procedures, and procedures to ensure that accreditation decisions are based on the agency's standards. As documentation, the agency provided its written policies and procedures in those areas, as well as examples self-studies, site visit reports, and annual reports.
 
Staff Conclusion: Comprehensive response provided
 
Part 2: Accreditation/Approval Standards
 
Mission and Objectives
 
Agency Narrative
One of the RCVS’s primary statutory functions is to set the standards required for registration (licensure) in the UK. It does this by defining the standards for accreditation including the “Day One Competences” (Item 3, RCVS standards & procedures, Annex 2, pg 93) required by graduates at the point of graduation. The RCVS accreditation standards (“RCVS standards and procedures for the accreditation of veterinary degrees”, February 2015) set out in detail how schools should prepare students to qualify. Graduation from an RCVS accredited school entitles those graduates to register as Members of RCVS and practise in the UK. The accreditation standards set out the required curriculum, facilities, physical and staff resources, access to animal material/cases, assessment standards, and the RCVS Day One Competences which all graduates must have met at the point of graduation. The Day One Competences (see item 3, pg 93, Annex 2, “RCVS standards and procedures”) set out the standards which new graduates must meet to provide quality veterinary care from their first day in practice. These are supplemented by a set of indicators defined across Europe which set out the benchmarks against which veterinary schools are measured in terms of resources, staff:student ratios, balance of the curriculum, availability of animal cases, etc.
(Prior to February 2015, RCVS’s accreditation criteria were set out in the document “Criteria and Guidance for RCVS approval of veterinary degree courses in the UK and overseas”, November 2011 edition – see item 4 “Old RCVS accreditation criteria 2011”.)

RCVS has also developed a “Student Experience Log”, which forms one part of a life-long learning online system – the Professional Development Record (PDR). Other sections of the PDR include a skills log for new graduates, and an online CPD recording tool for all registered veterinary surgeons. The Student Experience Log is available for all veterinary students in UK schools to record their developing clinical and practical skills, and includes reports from which universities can compile consolidated data to report to RCVS on outcomes. Universities that chose not to use the RCVS online student experience log must have their own comparable system that encourages students to record and reflect on their practical/clinical experience throughout the degree course (Item 3, RCVS standards and procedures, Standard 12 – Outcomes Assessment, pg. 19, para 12.4).

RCVS does not offer a “pre-accreditation” status. Although a new veterinary school is strongly advised to make contact with RCVS before it admits its first cohort of students, consideration for approval of a new veterinary degree can only follow when the first intake has reached its final year and the whole programme has been subjected to RCVS inspection. Students who graduate from a school in the UK that is not RCVS approved are required by the legislation to sit a RCVS examination in order to qualify for licensure in the UK. (“RCVS standards and procedures for the accreditation of veterinary degrees”, chapter 1, pg 8, and chapter 3, pg. 9).
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and that they are appropriate in light of the program's mission and objectives. Specifically, the agency's "Day One Competencies" set the requirements for all veterinary programs to prepare graduates to enter and complete graduate veterinary education, qualify for licensure, provide competent veterinary care, and have the educational background necessary for continued learning.
 
Governance
 
Agency Narrative
Standard 1 – Organisation – (item 3, RCVS standards and procedures, pg 8) states that schools “must be part of an institution of higher learning accredited by an organisation recognised for that purpose by its country’s government.” RCVS only considers schools which are part of a university with government awarded authority to award degrees. Within the UK, all universities are subject to overall quality assurance monitoring by the UK’s Quality Assurance Agency (QAA). The QAA is responsible for advising government (the Privy Council) on the grant of degree awarding powers to institutions of higher education. RCVS is recognised as a Professional Statutory Body by the QAA, and takes part in a collaborative forum of professional bodies with the QAA in order to share best practice on accreditation, and the mutual exchange of relevant information relating to quality.

For overseas veterinary schools accredited by RCVS, the degree of the overseas school must be recognised as a professional veterinary qualification by the relevant authorities (government and/or veterinary licensing body) in its own region/country (item 3, RCVS standards and procedures, Chapter 3, pg. 27)
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that require veterinary school to be legally authorized to provide a program of veterinary education in the country in which it is located. Specifically, the agency's Standard 1 requires all veterinary programs to be "part of an institution of higher learning accredited by an organisation recognised for that purpose by its country’s government."
 
Administrative and Fiscal Capacity, Question 1
 
Agency Narrative
The RCVS accreditation standards require schools to be a major academic administrative division of the parent university, and must be afforded the same recognition, status, and autonomy as other professional schools in that institution. The head or dean of the school must be a veterinarian and must have control of the budget for the veterinary programme. There must be sufficient administrative staff to manage the affairs of the school adequately as appropriate to the enrolment and operation. The school must have a strategic plan and operating plan and must report on how it is complying successfully with its operating plan (see item 3, RCVS standards and procedures, Standard 1 – Organisation, pg. 8).
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the administrative capacity of the veterinary school and that they are appropriate in light of the program's mission and objectives. Specifically, the agency's standards require veterinary schools to be a major academic administrative division of the parent university, and must be afforded the same recognition, status, and autonomy as other professional schools in that institution.
 
Administrative and Fiscal Capacity, Question 2
 
Agency Narrative
Finances must be demonstrably adequate to sustain the programme to enable the school to meet its mission. Resources allocation must be regularly reviewed to ensure it meets the requirements for accreditation of a professional veterinary degree. Detailed questions are asked as part of the accreditation process regarding the finances available for the programme, including income and expenditure for the previous 5 years and projected income and expenditure for the next 5 years. (See item 3, RCVS standards and procedures, Standard 2 – Finances, pg. 9, and Annex 1, Self evaluation report template, Standard 2 Finances, pg. 47).
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the fiscal capacity of the veterinary school and that they are appropriate in light of the program's mission and objectives. Specifically, the agency's standards require the dean of the veterinary school must have control of the school's budget, and the budget must be adequate to sustain the program to meet its mission and objectives.
 
Faculty, Question 1
 
Agency Narrative
RCVS does not define a precise number for the size of the faculty, as the number will be judged in relation to the size of the student cohort, and the varying departmental structures of universities. However, as a guide, RCVS uses the following benchmarks for staff: student ratios which have been agreed across Europe. These indicate there should normally be a ratio of at least 8:1 student/staff overall. (In a previous version of RCVS’s accreditation criteria (item 4, RCVS old criteria 2011, pg.28), a guideline of a minimum of 80 full-time-equivalent veterinary qualified staff was quoted and this would still be the “rule of thumb” guidance to ensure a viable veterinary school. The benchmark indicators are broken down further as follows:

The recommended benchmark ratios are as follows: (item 5, EAEVE indicators, April 2014)

[number of undergraduate vet students] to [(total academic full-time equivalent staff (FTEs) involved with veterinary training]
= 8 : 1

[number of undergraduate students at the faculty] to [number of FTE staff in the faculty]
= 9 : 1 (this ratio covers cases where the faculty/school may be involved in delivering other non-veterinary programmes, eg. bioscience, veterinary nursing)

[number of undergraduate veterinary students] to [number of veterinary qualified FTE staff involved with veterinary training] = 11 : 1

[number of students graduating annually] to [number of veterinary qualified FTE staff involved in veterinary training] 2 : 1

[number of FTE support staff involved with veterinary training] to [number of academic staff involved with veterinary training] = acceptable range between 0.5 – 2 : 1

(support staff includes technicians, nursing staff, administrative staff).
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and require the school's faculty to be of sufficient size, breadth, and depth to provide the scope of the educational program offered. The agency does not set a specific number for the size of the faculty, but determines sufficiency, primarily, in relation to the size of the student cohort. The agency does use as a guide and publishes the benchmarks for staff: student ratios which are used across Europe.
 
Faculty, Question 2
 
Agency Narrative
See Standard 8 – Academic and Support Staff (Item 3, “RCVS standards and procedures for accreditation” pg. 14) for requirements for staff. Veterinary staff must be qualified veterinarians and, for schools in the UK, must be registered to practise with the RCVS (and thereby are subject to RCVS’s investigation and disciplinary processes). All teaching staff must be appropriately trained and there must be programmes for staff development in teaching theory/practice. All staff must be listed in the school’s self evaluation report for accreditation, including their qualifications and whether they are veterinary qualified.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and requires that members of the veterinary school's faculty are appropriately qualified and effective to teach in a veterinary program. Specifically, the agency's standards require veterinary staff to be qualified veterinarians and, for schools in the UK, must be registered to practice with the RCVS.
 
Faculty, Question 3
 
Agency Narrative
Staff who provide core teaching and/or who are involved in assessing students in external off-campus teaching sites (adjunct staff, whether directly employed by the university or not) must be fully competent and experienced in the subject area concerned and ideally hold relevant postgraduate qualifications (eg. RCVS/European Certificates and Diplomas). (item 3, RCVS standards and procedures, Standard 8.3 – Academic and support staff, pg. 14).

Staff at off-campus sites do not necessarily need to be employed by the university, but if external sites are providing core teaching (as distinct from Extra mural studies - EMS, which is less formal, complementary additional work experience), there must be a legal contract between the partner organisation and the university setting out requirements for staffing, facilities and defining the respective roles of staff external to the university. (item 3, RCVS standards and procedures, Annex 5 – “Distributed” veterinary clinical education models”, pg. 118.)

All teaching practices in the UK providing core teaching (whether off or on campus) must also be accredited separately under the RCVS’s Practice Standards scheme, through which they are periodically inspected by RCVS assessors. This includes a requirement that all staff are qualified for their roles, and that they comply with RCVS’s requirements for continuing professional development. Any staff in external sites who are involved in assessment, who are not employed members of the university staff. must also be trained in assessment matters. The university must implement robust quality assurance and monitoring procedures to ensure that teaching and assessment undertaken at distributed sites continues to meet the required standards. This must include regular site visits by veterinary qualified university staff, feedback from students, and feedback from teaching staff at the site. Sufficient monitoring visits must be undertaken by veterinary qualified staff to ensure that appropriate student services are provided, that physical facilities are adequate and the educational programme is being delivered appropriately. Where numerous off-campus sites are employed to deliver the curriculum, there must be effective coordination between them, led by the veterinary school, to minimise the risk of fragmentation across the curriculum and ensure consistency of approach from the student’s perspective. Representatives from all distributed sites/organisations should be included on key veterinary school committees and involved in curriculum planning, teaching and learning and assessment planning.

RCVS has published a detailed policy about “Distributed veterinary clinical education models” which sets out the requirements for universities following this model. (item 3, Annex 5 of “RCVS standards and procedures, pg 118)
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and address the relationship between the instructional staff at remote sites and clinical locations and the veterinary school. Specifically, the agency's standards require that staff who provide core teaching and/or who are involved in assessing students in external off-campus teaching sites must be competent and experienced in the subject area taught. In addition, staff at off-campus sites do not necessarily need to be employed by the university, but if external sites are providing core teaching, there must be a legal contract between the partner organization and the university, which would set out requirements for staffing, facilities and the roles of staff external to the university.
 
Curricula, Question 1
 
Agency Narrative
See Standard 9 – Curriculum in the “RCVS Standards and Procedures for Accreditation” for the curriculum requirements. The programme must prepare students to meet RCVS’s Day One Competences by the time they graduate. (item 3, Annex 2, “RCVS standards and procedures, pg.93).

RCVS does not define the precise structure for the curriculum, and seeks to encourage innovation across the schools in how it is delivered, provided the RCVS Day One Competences and European Directive requirements are met. Curricula may therefore be fully or partially integrated, horizontally and vertically, or may follow a more traditional pattern of pre-clinical, para-clinical and clinical phases.

Faculty staff must have the opportunity to contribute to the on-going development of the curriculum and there must be a defined quality assurance programme of on-going evaluation and continuous improvement based on evidence derived from outcome measures. Schools must supply data on outcomes as part of the accreditation process, and demonstrate the effectiveness of their quality assurance process. (item 3, RCVS standards and procedures, Standard 12 – Outcomes, pg.18.)
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and has requirements with regards to the design, implementation, and evaluation of a veterinary school's curriculum. Specifically, the agency's standards provide requirements with regards to the curriculum, but does not define the precise structure for the curriculum. The agency's standards also require that the faculty must have the opportunity to contribute to the on-going development of the curriculum and there must be on-going evaluation and continuous improvement based on evidence derived from outcome measures.
 
Curricula, Question 2
 
Agency Narrative
All UK veterinary degrees must comply with European Union requirements set out in the European Directive on the recognition of professional qualifications (Directive 2005/36/EC and Directive 2013/55/EU), which states that the professional veterinary degree must be at least 5 years in length. However, schools may admit graduate students on to accelerated programmes of 4 years, provided those students have already achieved at least a Bachelors degree in a relevant bio-science subject before starting the veterinary programme.

UK Veterinary degrees are benchmarked by the UK's Quality Assurance Agency at level 7 of the UK national qualifications framework, ie. at Masters level. See item 3, RCVS standards and procedures, pg. 131, Annex 8.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and has requirements with regards to program length. Specifically, the agency's standards require that all UK veterinary degrees must comply with European Union requirements, which state that the professional veterinary degree must be at least 5 years in length.
 
Curricula, Question 3
 
Agency Narrative
Standard 9 – Curriculum – (item 3, RCVS standards and procedures, pg. 14) requires the curriculum to cover, amongst other things, “knowledge, skills, values, attitudes and behaviours necessary to contribute, as a veterinarian, to promoting animal health and well being…” It must also cover “skills in application of professional ethics…” Furthermore, the RCVS Day One Competences (item 3, RCVS standards and procedures, pgs. 96-99) require students to : “Be fully conversant with, and follow the RCVS Code of Professional Conduct” (which covers ethics), “understand the ethical and legal responsibilities of the veterinary surgeon in relation to patients, clients, society and the environment”. It also requires an underpinning knowledge and understanding of “the ethical framework within which veterinary surgeons should work, including important ethical theories that inform decision-making in procession and animal welfare-related ethics”.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and has requirements with regards to the extent and nature of the educational experience in teaching ethics. Specifically, the agency's standards require the curriculum to cover professional ethics and animal patient care.
 
Curricula, Question 4
 
Agency Narrative
As regards the school’s mechanisms for monitoring and evaluating the success of their instruction in ethics: Standard 10 – Assessment – (item 3, RCVS standards and procedures, pg. 16) includes a requirement for the school to have a process in place to review assessment outcomes and to change assessment strategies when required. For UK schools, RCVS expects universities to have in place a procedure for dealing with students’ Fitness to Practise, and has published guidance on this (item 6, “RCVS Fitness to Practise - A Guide for UK Veterinary Schools and Veterinary Students 2014"). Should students behave unethically, or if there are serious concerns about their professional behaviour whilst they are undergraduates on the course, the university must have a procedure to consider whether they are fit to continue on the programme and graduate with a professional degree. This is over and above purely academic considerations for progression. The procedure should allow the schools, in exceptional cases, to remove a student from the professional programme if they have proven to be unfit to practise.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and evaluates the mechanisms a veterinary school has in place to monitor and evaluate the success of the instruction in ethics. Specifically, the agency's standards require a veterinary school to have a process in place to review assessment outcomes and to change assessment strategies when warranted.
 
Curricula, Question 5
 
Agency Narrative
The humane care of animals is an absolute requirement: all veterinary surgeons and registered veterinary nurses working in the UK must abide by the RCVS Codes of Professional Conduct, the first precept of which says that they “must make animal health and welfare their first consideration when attending to animals”. Failure to abide by the Code renders them liable to RCVS disciplinary action with the possible removal of their licence to practise.

The use of animals in research is tightly regulated by primary legislation within the UK, through The Animals (Scientific Procedures) Act 1986 (ASPA) (item 7, ASPA). Research undertaken by universities involving animals will come under the Act. The Act requires that scientific procedure establishments and breeding and supply establishments are licensed, and must name a specific veterinary surgeon in their licence schedule. The Named Veterinary Surgeon (NVS) is responsible for, monitors and provides advice on the health, welfare and treatment of animals. The NVS must be appropriately trained in ASPA matters, as well as being a registered veterinary surgeon. RCVS publishes guidance as part of the Code of Professional Conduct on the role and responsibilities of the NVS.

Non-veterinary surgeons must also comply with Animal Welfare legislation which ensures that all animals must be treated humanely: The Animal Welfare Act 2006 (which applies in England and Wales), the Animal Health and Welfare (Scotland) Act 2006 and the Welfare of Animals (Northern Ireland) Act 2011 contain provisions to safeguard the welfare of animals. This means that owners and keepers are legally obliged to care for their animals properly and they are responsible for ensuring that the welfare needs of their animals are met. A person with responsibility for an animal may commit an offence if an act, or failure to act, causes an animal to suffer unnecessarily. If a person does not provide for an animal’s welfare needs, they can be banned from owning animals, fined and/or sent to prison.

Any infringement of these Acts by veterinary surgeons or veterinary nurses working in a university in the UK would render them liable for legal prosecution, and investigation by RCVS under its statutory Disciplinary procedure, potentially leading to the loss of their licence to practise. Any infringement by a student would render the student liable for prosecution, as well as sanction under the university’s Fitness to Practise procedure and likely dismissal from the programme.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and has requirements to ensure the humane care of animals when animals are used in teaching and research. Specifically, the agency's standards require the use of the RCVS Codes of Professional Conduct, as well as other UK laws and acts, which govern the humane care of animals.
 
Curricula, Question 6
 
Agency Narrative
Various RCVS standards cover requirements for clinical training, particularly those relating to clinical teaching facilities (Standard 3 - Facilities & Equipment, (item 3, pg 9), the curriculum (Standard 9 – Curriculum, item 3, pg 14), animal resources (Standard 4 - Animal Resources, item 3 pg 10), and the RCVS Day One Competences (item 3, pg 93) which set out 22 separate clinical and practical competences which must be met. Standard 4.5 (item 3, pg 11) requires that “under all situations students must be active participants in the workup of the patient, including physical diagnosis and diagnostic problem oriented decision making.

Standard 9 – Curriculum - requires
• “…expertise in medicine, surgery, and anaesthesia applicable to a broad range of common species. Students must develop entry-level skills in physical examination and laboratory diagnostic techniques and interpretation (including clinical pathology, diagnostic imaging and necropsy), disease prevention, biosecurity, therapy (including surgery and pharmacotherapeutics), patient management and care (including primary care, intensive care, emergency medicine, surveillance and isolation procedures) for individual animals, herds, flocks and other populations
• knowledge, skills, values, attitudes and behaviours necessary to contribute, as a veterinarian, to promoting animal health and well being, within changing societal expectations
• clinical, epidemiological, pathophysiological and regulatory skills in management of animal diseases which are:
- endemic to the UK and the EU
- endemic to and of special consideration in the country in which the school is located;
- exotic to the UK and the EU and which are currently regarded as being of concern as potential emergency animal diseases or diseases of global veterinary significance
- significant emerging diseases
• entry level capability (to OIE standards) in preventive medicine/epidemiology, zoonoses, food safety and hygiene, regulation of animals and animal products, and management of the interrelationship of animals and the environment. This training must include experience in abattoirs.
• professional level problem solving skills in evidence-based diagnosis and clinical management, and data and information management skills
• capacity for professional communication; the ability to acquire information from the owners of animals by direct interaction as well as retrieval of archival data from medical records, communication with colleagues, regulatory bodies and clients…”

In addition to the core curriculum, RCVS requires students to complete 38 weeks of extra-mural studies (EMS), 12 weeks of which is devoted to animal husbandry/pre-clinical work experience, and 26 weeks devoted to clinical work experience placements. See item 3, pg. 108. Annex 4, RCVS standards and procedures, for the RCVS policy and guidance for EMS.

Standard 11 – Research programmes, continuing and higher degree education – (item 3, pg 18) requires schools to “provide advanced postgraduate degree programmes, internships, residencies and continuing education programmes that complement and strengthen the veterinary degree programme and are relevant to the needs of the profession and community. Programmes and the number of students in them must be commensurate with the facilities, clinical and other resources and staff.”

RCVS itself offers a system of modular postgraduate certificates (The RCVS Certificate in Advanced Veterinary Practice), and some UK veterinary schools are involved in its delivery although this is not a specific requirement of the accreditation standards for the primary veterinary degree. Universities may elect to be accredited by RCVS to assess modules from the RCVS Certificate – this is a separate process from the accreditation of the primary professional veterinary degree.

Postgraduate specialist clinical training is mostly undertaken under the auspices of the European Board for Veterinary Specialisation through its various specialty colleges, leading to various European Diplomas. Post graduate Residents within the universities’ clinics will mostly be working towards the appropriate European Diploma for their specialty, working under the direction of Diplomate clinical staff in the faculty.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and has requirements with regards to inclusion of clinical training within a veterinary school's curriculum. Specifically, the agency's "Day One Competencies" set the requirements for the 22 separate clinical and practical competences which must be met by all veterinary programs to prepare graduates to enter and complete graduate veterinary education, qualify for licensure, provide competent veterinary care, and have the educational background necessary for continued learning. The agency also has standards related to clinical training in its curriculum section.

The agency also provided information of postgraduate program offerings, which include internships, residencies, and continuing education programs.
 
Student Achievement, Question 1
 
Agency Narrative
RCVS’s Standard 10 – Assessment – (item 3, RCVS standards and procedures, pg.16) covers detailed requirements for assessment as follows:

“The decision on whether students can progress and ultimately graduate is a serious matter as they are entering into a social contract with the public through entry to the profession. The decision must be based on appropriate assessment of the required broad range of professional and technical skills, knowledge, and attributes demanded of a professional. Assessment policies, methods, standards and quality assurance must be appropriate for admission to the veterinary profession.

Management
10.1 The institution must ensure that there is a clearly identified structure within the school showing lines of responsibility for the assessment strategy to ensure coherence of the overall assessment regime and to allow the demonstration of progressive development across the programme towards entry level competence. The strategy must be underpinned by robust quality assurance mechanisms.

Policy and Regulation
10.2 The assessment tasks and grading criteria for each unit of study in the programme must be clearly identified, and available to students in a timely manner well in advance of the assessment.
10.3 Requirements to pass including the effect of barrier assessments must be explicit.
10.4 Mechanisms for students to appeal against assessment outcomes must be explicit.
10.5 The school must have a process in place to review assessment outcomes and to change assessment strategies when required.

Assessment methods and design
10.6 Programme learning outcomes covering the full range of professional skills and attributes must form the basis for assessment design and underpin decisions on progression.
10.7 Assessment must inform student learning and students must receive timely feedback.
10.8 Assessment load must be planned and managed to achieve appropriate workloads for students and staff.
10.9 Assessment strategies must allow the school to certify student achievement of learning objectives at the level of the programme and individual units of study.
10.10 Methods of formative and summative assessment must be valid and reliable and comprise a variety of approaches. Direct assessment of clinical skills (some of which may be on simulated patients), must form a significant component of the overall process of assessment in the clinical disciplines.

Assessment standards and quality assurance
10.11 There must be procedures in place to maximise the fairness, validity and reliability of assessment outcomes, including but not limited to academic peer review of assessment content, proofing of scripts, supervision and invigilation, maintenance of records and moderation processes.
10.12 Schools must have appropriate moderation processes in place to ensure parity within and between individual units of study, across the programme, with other institutions; and to ensure that each student is fairly treated.
10.13 The school must be able to demonstrate that there are appropriate measures in place to ensure that grades awarded reflect an appropriate standard of performance by students against the relevant learning objectives.”


Students undertaking extra-mural studies (ie work experience placements in veterinary practices and on farms which are in addition to the core training) are required to obtain feedback from their placement providers, which is taken into account as part of formative assessment by their tutors at the veterinary school. (This is not to be confused with students undertaking core clinical training at external practices under the “distributed” model; assessment of core placements must be undertaken in accordance with the above standard for assessment.)
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and that they require the evaluation of student achievement. Specifically, the agency's standards set the detailed requirements for veterinary schools to establish principles and methods for the evaluation of student achievement, including the criteria for satisfactory academic progress and the requirements for graduation.
 
Student Achievement, Question 2
 
Agency Narrative
RCVS has not included within its standards a specific reference to the NAVLE. However, UK schools accredited by AVMA that admit significant numbers of American students will comply with the AVMA requirements. For schools that are not AVMA accredited, it should be noted that the RCVS accreditation standards are benchmarked to the AVMA standards, so the curriculum coverage in UK schools is very similar to those in North America. RCVS expects veterinary schools to support those candidates who need to take the NAVLE (or other country’s licensing exam) by providing tutorial support, guidance about the process and assistance in preparing for the examination. This is a part of Standard 6 – Students – (item 3, RCVS standards and procedures, pg.11) which requires schools to provide learning support and careers advice, and Standard 9 – Curriculum – (item 3, RCVS standards and procedures, pg. 4) which includes “an appreciation…of career opportunities and relevant information about the veterinary profession”. Preparation for the NAVLE for those students who require it is seen as part of a school’s duty to prepare its students for entry to the profession. UK veterinary schools all require final year students to pass their final summative examinations in the final year, and these examinations will capture all the essential elements of the NAVLE. Thus students who also want to sit the NAVLE should all be well prepared to do so.
 
Analyst Remarks to Narrative
The agency does not require its veterinary schools to prepare U.S. students to take and pass the North American Veterinary Licensing Examination (NAVLE), but would expect veterinary schools to support (via tutoring, process guidance, etc.) any students who would need to take the NAVLE. The agency noted that all students must pass a final summative examination, which would encompass all the essential elements of the NAVLE, and therefore adequately prepare any student for the NAVLE. The agency also noted that its standards are benchmarked to the American Veterinary Medical Association's (AVMA's) standards, which would reflect a similar veterinary education as provided in the U.S.
 
Student Achievement, Question 3
 
Agency Narrative
There is no national licensing examination in the UK akin to the NAVLE. All students must meet the RCVS Day One Competences by the time they graduate, and the curriculum and assessment regime of the school must be mapped to these to ensure coverage. In the UK, all universities follow the quality code set out by the UK’s Quality Assurance Agency (item 8, QAA external examiner cost of practice) and must appoint External Examiners to oversee summative examinations. All veterinary programmes have multiple External Examiners for the various components of the programme who monitor assessment processes and final results. The External Examiner system works to ensure that standards within universities are comparable across the sector. Universities must take account of External Examiners’ reports and take action to correct any identified deficiencies. There must be a direct line to senior management for reporting and accountability for External Examiners’ reports. RCVS takes account of External Examiner reports during the accreditation inspection process.

RCVS requires universities to provide data on student attrition as part of the self-evaluation report produced for the accreditation visit. UK veterinary schools will normally have very low attrition rates, and any pattern of high attrition, or high failure rates in final examinations would be considered as a matter of concern by the visiting team as it could indicate problems with tuition or the assessment regime.(item 3, RCVS standards and procedures, pg. 69)

Standard 12 – Outcomes assessment – (item 3, RCVS standards and procedures, pg.18) expects that “all schools with an established quality assurance and enhancement culture will evaluate outcomes at school, programme, module and individual student levels. This will be achieved through results in assessments, feedback forms of various types, surveys, publication counts and a host of other measures. Different schools will place emphasis on different measures, but a report on outcomes should include a matrix that employs a variety of different measures providing information relevant to the foci of the other standards. Repetition of the measures over an extended period (at least five years) will then demonstrate progress in each area. Specifically, evaluation of outcomes related to the veterinary programme, individual students (throughout their studies as well as at graduation) and employability must be included, but RCVS will expect schools to include other outcomes evaluations of their choice. In addition, evidence of quality assurance, together with both reactive and proactive quality enhancement will be expected.”

All UK universities are required by the UK’s Higher Education Statistics Agency (https://hesa.ac.uk) to gather employment destinations data on its students and these data are published nationally. Universities must also take part in the National Student Survey (NSS) run by the Higher Education Funding Council, which gathers students’ opinions on the quality of their courses. Data from the NSS is published, and helps inform the choices of prospective students, and provides data that assist institutions in enhancing the student experience. RCVS requires feedback from employers of veterinary graduates - provided as part of the Outcomes data (item 3, RCVS standards and procedures, pg. 87). RCVS meets with a selection of employers as part of its site visit schedule.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address the quality of the veterinary programs and that they require the collection and evaluation of student performance outcomes. Specifically, the agency's standards set the detailed requirements for veterinary schools to evaluate outcomes at the school, program, module and individual student levels. Examples of outcomes to be reviewed include assessments, feedback forms of various types, surveys, etc.
 
Admissions and Recruiting, Question 1
 
Agency Narrative
Admission criteria must include evidence that the student has a solid background in the chemical, physical and biological sciences and mathematics, unless these are already covered in the early stages of the course (eg. by a pre-veterinary foundation year). Factors other than academic performance must also be considered for admission (eg. personal attributes, commitment to the profession, communication skills etc.) Each university will have its own specific requirements for minimum entry requirements in terms of secondary school grades/subjects, in accordance with its own matriculation regulations.

Standard 7 - Admission and Progression – (item 3, RCVS standards and procedures, pg.12) sets out the following requirements:

“University veterinary schools are in effect the initial ‘gatekeepers’ for the profession in that the majority of students who are admitted to a veterinary degree programme will be entitled to register to practise once they graduate. It is therefore very important to ensure that students are well informed before they are admitted, and that the school undertakes the initial selection process and makes on-going progression decisions with a view to students’ eventual status as veterinary professionals.

7.1 The selection criteria for admission to the programme must be consistent with the mission of the school. The number of students admitted must be consistent with the resources available to the school.
7.2 In relation to enrolment, the school must provide accurate information in all advertisements regarding the educational programme by providing clear and current information for prospective students. Further, printed catalogue or electronic information must state the purpose and goals of the programme, provide admission requirements and procedures, state degree requirements, present faculty descriptions, clearly state information on tuition and fees along with procedures for withdrawal, give necessary information for financial aid programmes, and provide an accurate academic calendar. The information must include the accreditation status of the degree course (whether by RCVS or other relevant accrediting bodies), and the requirements for eventual registration/licence, including fitness to practise.
7.3 The selection and progression criteria must be clearly defined, consistent, defensible, be free of discrimination or bias, and take account of the fact that students are admitted with a view to their entering the veterinary profession in due course.
7.4 An accurate description of the selection criteria and processes must be published and readily available to potential students. The school must regularly review and reflect on the selection processes to ensure they are appropriate for students to complete the programme successfully, including consideration of their potential to meet all the RCVS Day One Competences across the common UK domestic species.
7.5 Adequate training (including periodic refresher training) must be provided for those involved in the selection process to ensure applicants are evaluated fairly and consistently.
7.6 Potential students must be advised of the demands of the veterinary course and RCVS requirements for fitness to practise.
7.7 Factors other than academic performance should be considered for admission, with the aim of selecting students who will be capable of succeeding in a variety of fields within the profession.
7.8 The school must have a strategy for widening participation and engaging students from a variety of social backgrounds.
7.9 If not otherwise covered within the early part of the course, the entry criteria for the programme must include evidence that the student has a solid background in the chemical, physical and biological science and mathematics, in order to meet the requirements of the EU Directive on basic subjects.

Students with a disability
7.10 There must be clear policies and procedures as to how applicants with disabilities or illness will be considered and, if appropriate, accommodated on the programme, taking into account the requirement that all students must be capable of meeting the RCVS Day One Competences by the time they graduate.

Student Progression
7.11 The basis for decisions on progression (including academic progression and professional fitness to practise) must be explicit and readily available to the students. The school must provide evidence that it has mechanisms in place to identify and provide remediation and appropriate support (including termination) for students who are not performing adequately (including areas such as practical animal handling, client communication etc).
7.12 The school must have mechanisms in place to monitor attrition and progression and be able to respond and amend admissions selection criteria and student support if required.

Student Exclusion
7.13 Mechanisms for the exclusion of students from the programme, either for academic reasons or under fitness to practise procedures, must be explicit.

Appeals and misconduct
7.14 School policies for managing appeals against decisions, including admissions, academic and progression decisions, should be transparent and publicly available. The process for exclusion of students on any grounds must be explicit.
7.15 Policies for dealing with student misconduct and fitness to practise must be explicit.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address admission and recruiting requirements. Specifically, the agency's standards do not establish admissions requirements, but require veterinary schools to provide accurate recruiting and admissions information in all advertisements and publications.
 
Admissions and Recruiting, Question 2
 
Agency Narrative
As part of the accreditation inspection (site visit), the school’s management and staff responsible for admissions are questioned on the workings of the admissions process. Documentary evidence is considered, and staff and students questioned about their perceptions of the process. Schools are expected to keep their admissions policy and processes under review and the visiting team will look for evidence of on-going training of admissions team, and evidence that the school monitors the effectiveness of its policies.
 
Analyst Remarks to Narrative
The agency has demonstrated that it evaluates the quality of the veterinary school’s admission practices during the site visit and via self-study documentation.
 
Admissions and Recruiting, Question 3
 
Agency Narrative
Each country in which the RCVS operates may have its own requirements for admission. These are not defined by RCVS and data is not held by RCVS on the admission requirements of other countries. To be accredited by RCVS, however, veterinary schools would need to meet the standard for admission set out in Standard 7 on Admission and Progression.
 
Analyst Remarks to Narrative
There are no admissions requirements set by any country in which RCVS operates.
 
Facilities, Question 1
 
Agency Narrative
The standards relating to facilities, equipment and supplies are as follows: (item 3, RCVS standards and procedures, pgs. 9 and 10)

Standard 3 – Facilities and Equipment

3.1 All aspects of the physical facilities must provide an environment conducive to learning.
3.2 The veterinary school must describe a clear strategy and programme for maintaining and upgrading its buildings and equipment.
3.3 Lecture theatres, teaching laboratories, tutorial rooms, clinical facilities and other teaching spaces must be adequate in number and size, and equipped for the instructional purposes and must be well maintained. Students must have ready access to adequate study, recreation, locker and food services facilities.
3.4 Offices, teaching preparation and research laboratories must be sufficient for the needs of the academic and support staff.
3.5 Facilities must comply with all relevant jurisdictional legislation including health, safety, biosecurity and UK animal welfare and care standards.
3.6 The institutions' livestock facilities, animal housing, core clinical teaching facilities and equipment must:
• be sufficient in capacity
• be of a high standard and well maintained
• be fit for purpose
• promote best husbandry, welfare and management practices
• ensure relevant biosecurity and bio-containment
• be designed to enhance learning.

Clinical teaching facilities
3.7 Core clinical teaching facilities may be provided on campus and/or externally through a ‘distributed’ model. The school must ensure standards of teaching clinics (whether on campus or elsewhere) remain comparable with the best available in the private sector, through regular review. Any hospitals and practices involved with core teaching must meet the relevant RCVS Practice Standards and (for UK schools) be accredited under the RCVS Practice Standards Scheme.
3.8 All core teaching sites (whether on campus or external) should provide dedicated learning spaces including adequate internet access.
3.9 The School must ensure students have access to a broad range of diagnostic and therapeutic facilities, including but not limited to: pharmacy, diagnostic imaging, anaesthesia, clinical pathology, primary care settings, intensive/critical care, surgeries and treatment facilities, ambulatory services and necropsy facilities.
3.10 Operational policies and procedures must be posted for staff, visitors and students.
3.11 Appropriate isolation facilities must be provided to meet the need for the isolation and containment of animals with communicable diseases. Such isolation facilities must be properly constructed, ventilated, maintained and operated to provide for animal care in accordance with accepted modern methods for prevention of spread of infectious agents.

Standard 4 – Animal Resources
4.1 Normal and diseased animals of various domestic and exotic species must be available for instructional purposes, either as clinical patients or provided by the institution. While precise numbers are not specified, the school must provide access to sufficient numbers of animals and quality of animal material to provide the necessary quantity and quality of animal husbandry and clinical instruction.
4.2 It is essential that a diverse and sufficient number of surgical and medical patients be available for the students’ clinical educational experience including patients in primary care settings.
4.3 Experience can include exposure to clinical education at external sites, provided the school quality assures these clinical experiences and educational outcomes to at least the same standard as university owned facilities. Further, such clinical experiences should occur in a setting that provides access to subject matter experts at the appropriate level, reference resources, modern and complete clinical laboratories, advanced diagnostic instrumentation and ready confirmation (including necropsy). Such examples could include a contractual arrangement with nearby practitioners who serve as adjunct faculty members and off-campus field practice centres.
4.4 The teaching hospital(s) must provide nursing care and instruction in nursing procedures. A supervised field service and/or ambulatory programme must be maintained in which students are offered multiple opportunities to obtain clinical experience under field conditions.
4.5 Under all situations students must be active participants in the workup of the patient, including physical diagnosis and diagnostic problem oriented decision making.
4.6 Medical records must be comprehensive and maintained in an effective retrieval system to efficiently support the teaching, research, and service programmes of the school.

Standard 5 - Information resources
5.1 Libraries and information retrieval are essential to veterinary medical education, research, public service, and continuing education. Timely access to information resources, whether through print, electronic media or other means, must be available to students and faculty. The library must be administered by a qualified librarian. The school must have access to the human and physical resources necessary for development of instructional materials.
5.2 The school must provide students with unimpeded access to learning resources which include scientific and other relevant literature, internet and internal study resources, and equipment for the development of procedural skills (e.g. models). It will demonstrate how the use of these resources is aligned with the pedagogical environment and learning outcomes within the programme, and have mechanisms in place to evaluate the teaching value of innovations in learning resources.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address facilities, equipment, and supplies. Specifically, the agency's standards require adequate facilities, equipment, and supplies to fulfill the veterinary schools' educational objectives for all aspects of the program.
 
Facilities, Question 2
 
Agency Narrative
Yes, RCVS’s accreditation policy allows for part of the programme to be delivered at geographically separated locations. A variety of models are in operation:
a) a veterinary programme may be delivered across multiple sites/campuses all of which are owned by and controlled by the university.
b) a university may sub-contract with another organisation for the provision of facilities/access to animals, eg. an external farm, charity rescue organisation, or private practices.
In all delivery models, all core training must be delivered to the same quality standards. The university remains responsible throughout for the quality of training provided. All training, whether undertaken off campus by external organisations under contract, or on campus in facilities owned by the university, must meet the same accreditation standards. Core training sites are visited by RCVS as part of the accreditation inspection process. All staff involved in the assessment and evaluation of students (whether on campus or off-campus as part of a ‘distributed’ model) must be fully qualified and trained in the principles of teaching and assessment. (item 3, “RCVS standards and procedures for accreditation”, pg. 121, Annex 5, Distributed veterinary clinical education models.)
 
Analyst Remarks to Narrative
The agency's policies allow for part of the veterinary education program to be offered at geographically-separated locations. The agency's standards require that all core training at a separate location must meet the same quality standards as at the main campus, and the veterinary school remains responsible for the quality of training provided at all locations. In addition, core training sites are included as part of an on-site visit by the agency.
 
Facilities, Question 3
 
Agency Narrative
See item 3, “RCVS standards and procedures for accreditation” Annex 5, pg 118, which sets out requirements for “distributed” training – ie. training undertaken in off-campus sites which are not a part of the university.

Contracts/agreements with an external teaching providers/sites must be formal, legally binding documents, and these are inspected as part of the RCVS accreditation site visit. Contracts with external clinical teaching sites would be expected to cover the provisions in Annex 5 of the RCVS standards and procedures.

External organisations and any off-campus clinical sites selected by the school to provide core teaching should receive appropriate financial or other ‘in-kind’ remuneration from the school to ensure that students receive on-site supervised instruction.
There should be a formal written contract or signed agreement between the university and the organisation concerned setting out expectations on both sides, to ensure that standards will be maintained for the duration of the students’ training. Such contracts or agreements should include reference not only to resources and staffing, but also to the need for compliance with anti-discrimination policies, data protection, grievance procedures and communications channels for reporting problems on both sides.
There must be evidence (eg. through contracts with each site/organisation) that there are sufficient places available in total to match the training needs of the student intake. For the avoidance of doubt, the availability and timing of placements should be such that students can attend all the necessary placements without having to miss other essential parts of their course.
Taken as a whole, arrangements with off-campus sites/organisations should be secured sufficiently far in advance to ensure stability of provision for students over successive cohorts during the period of accreditation. The university must have suitable contingency plans to cover any possible shortfalls.
Annex 5 goes on to specify further requirements for staff, facilities, the teaching and learning environment, assessment, quality assurance and monitoring, and information and student support.

The Veterinary Surgeons (Practice by Students) (Amendment) Regulations 1993 (item 3, RCVS standards and procedures, pg 122) covers undergraduate students in the clinical part of their course. The Regulations provide that students may examine animals, carry out diagnostic tests under the direction of a registered veterinary surgeon, administer treatment under the supervision of a registered veterinary surgeon and perform surgical operations under the direct and continuous supervision of a registered veterinary surgeon.
RCVS has interpreted these as follows:
a. 'direction' means that the veterinary surgeon instructs the student as to the tests to be administered but is not necessarily present
b. 'supervision' means that the veterinary surgeon is present on the premises and able to respond to a request for assistance if needed
c. 'direct and continuous supervision' means that the veterinary surgeon is present and giving the student his/her undivided personal attention”

These regulations apply across the UK, whether students are treating animals within the university clinic, or in private veterinary practices externally.
 
Analyst Remarks to Narrative
The agency requires written contacts/agreements by the veterinary school with each teaching hospital or clinical facility it uses that define the responsibilities of each party, and the agency inspects the contracts/agreements during on-site visits.
 
Analyst Remarks to Response
Although not included in the e-Recognition system, the agency provided its response to the question regarding sufficient access to the resources and authority needed to effectively instruct students at affiliated locations in this section. The attached document provides the answer to that specific question.

The agency requires written contracts/agreements by the veterinary school with each teaching hospital or clinical facility it uses. These contracts/agreements define the specific responsibilities of each party, to include sufficient access to the resources and authority needed to effectively instruct students. The agency has developed specific requirements in this area based on the legislation that confers the authority to evaluate and accredit veterinary schools in the UK.
 
Staff Conclusion: Comprehensive response provided
 
Student Complaints
 
Agency Narrative
The RCVS Standard 6 – Students – (item 3, RCVS standards and procedures, pg 11) includes the following:
6.3 Provisions must be made, by either the university or school, to support the physical, emotional and welfare needs of students. This includes, but is not limited to, learning support and counselling services, careers advice, and fair and transparent mechanisms for dealing with student illness, impairment and disability during the programme. This shall include provision of reasonable accommodations/adjustments for disabled students, consistent with all relevant equality and/or human rights legislation.
6.4 There must be effective mechanisms for resolution of student grievances (e.g. interpersonal conflict or harassment).
6.5 Mechanisms must be in place by which students can convey their needs and wants to the school.
6.6 The school must provide students with a mechanism, anonymously if they wish, to offer suggestions, comments and complaints regarding compliance of the school with the RCVS standards for accreditation. These materials must be made available to RCVS as part of the annual report.

As part of the accreditation site visit, visitors meet students from all years of the programme without faculty staff members being present (item 3, RCVS standards and procedures, pg 30). A session is also timetabled during the visit for any staff member or student to meet confidentially with the visiting team and to send confidential communications to the team by e-mail before or during the visit. The confidential session must be advertised by the school to staff and students beforehand, and the RCVS Head of Education’s contact details provided so that individuals can communicate privately with the visiting team if they wish. The session must be held in a location where students can attend without faculty staff members being aware of their attendance. (Item 3, “RCVS standards and procedures” Chapter 3, pg 20, and chapter 4, pg 30)
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address student complaints related to the areas covered by the agency's accreditation standards and processes. Specifically, the agency's standards do not establish specific student complaint process requirements, but require veterinary schools to develop effective mechanisms for the resolution of student grievances. The agency also stated that on-site visitors meet with students during the visit as well as provide an opportunity to submit electronic communication as part of the accreditation review process.
 
Part 3: Accreditation/Approval Processes and Procedures
Accreditation Process and Procedures, Question 1
 
Agency Narrative
a) On-site visitors: The requirements and procedures for appointing people to the visiting teams are set out at Chapter 5 and Annex 6 of the “RCVS standards and procedures for accreditation”, (item 3, pgs 33 and123) including a “person specification” for visitors. The panel of experts must comprise individuals with expertise in veterinary basic sciences, animal production, veterinary public health and food hygiene, clinical studies. At least one of the clinical visitors must be a veterinarian in practice. Visitors must hold a degree registerable with RCVS (except for visitors in basic sciences who must hold a PhD in their subject) or be a currently licensed veterinarian in good standing in another jurisdiction acceptable to RCVS. They must be able to interpret and identify significant issues from a large amount of complex data, have good problem solving abilities and good English writing skills. A number of other interpersonal skills and other desirable characteristics are also set out in the “person specification”.
b) RCVS normally expects new visitors to have first taken part as an “observer in training” on a site visit before being appointed as a full visitor on a team. However, if this is not possible, RCVS ensures that the composition of any given site team includes a number of experienced visitors so that no team is made up solely of “new” visitors. Training/briefing is provided to new site team members before the visit on an individual basis with RCVS staff, and a briefing meeting is held with the whole team on the day before the site visit begins at the university.

c) Those who set the accreditation standards: Standards are set and reviewed by RCVS’s Primary Qualifications Sub-Committee (PQSC), which is made up of senior and experienced veterinarians appointed by RCVS’s Operational Board on the recommendation of the Education Committee. All members of PQSC are highly qualified, senior veterinarians, with a mix of expertise from academia and practice. The academics on PQSC are normally at professorial level within their universities. Education Committee (to which PQSC reports) comprises a sub-set of RCVS Council members; all Education Committee members are veterinarians, with a mix of academics and practitioners.

d) Those who decide on the accreditation of specific veterinary schools: consideration of the site visit report and consequent recommendations on accreditation are first made by PQSC (see above for composition). PQSC reports to Education Committee which takes the decision on accreditation status. If the recommendation is to maintain the status quo for a given school (ie. no change in accreditation status since the previous site visit), then the decision of Education Committee is final. However, if the recommendation is that accreditation should be withdrawn or if it concerns a new school that has not previously been accredited by RCVS, then the papers will be considered by the full RCVS Council which will ratify the final decision. In the case of a brand new UK veterinary school, RCVS Council will provide its report and recommendation to the UK Privy Council as required by the Veterinary Surgeons Act. Privy Council comprises senior government ministers advising the Queen; the Privy Councillor taking the lead on the matter will normally be the current government minister/secretary of state for agriculture.
e) RCVS maintains separation between any individuals who have been involved as a site visitor for any given university, and those who consider the report of that visit at PQSC and Education Committee. An individual who has served as a visitor on a particular visit may attend PQSC in order to answer questions on the report if required by the committee, but does not take part in the decision making process. A member of any committee/Council with a conflict of interest would be expected to refrain from voting on a particular accreditation decision.
 
Analyst Remarks to Narrative
The agency provided its requirements regarding the qualification and training of the individuals who participate in on-site evaluations of veterinary schools, the individuals who establish the accreditation standards for veterinary schools, and the individuals who decide whether a specific veterinary school should be accredited.

On-site visitors comprise a panel with expertise in veterinary basic sciences, animal production, veterinary public health and food hygiene, clinical studies, with at least one practicing veterinarian. On-site visitors must hold a degree registerable with the RCVS (except for visitors in basic sciences who must hold a PhD in their subject) or be a currently licensed veterinarian in good standing in another jurisdiction acceptable to RCVS. Training is provided to all on-site visitors on an initial and continuing basis.

The Primary Qualifications Sub-Committee (PQSC) of RCVS sets and reviews the accreditation standards. All members of the PQSC are senior veterinarians with a mix of expertise from academia and practice. The academics on the PQSC are normally at professorial level within their universities.

The PQSC reports to Education Committee which makes the decision on accreditation status. Education Committee comprises a sub-set of RCVS Council members. All Education Committee members are veterinarians, with a mix of academics and practitioners.
 
Accreditation Process and Procedures, Question 2
 
Agency Narrative
In order to ensure that all matters relating to the evaluation process for veterinary schools are conducted in a fair and objective manner, the RCVS applies its conflict of interest policy (item 3, “RCVS standards and procedures” Chapter 5, pg 34, and Annex 7, pg 127). Visitors should not be members of a visitation panel if they have graduated from, or been employed full time by the school being evaluated during the last 10 years. Nor should they have personal, family or business relationships with key personnel at the school being evaluated. If a member of the proposed visiting team has reason to believe that a conflict of interest might exist, he/she should seek the advice of the Head of Education at the RCVS. Nominated visitors are asked to sign a declaration concerning any potential conflicts of interest (Annex 7, "RCVS standards and procedures for accreditation").

The head of the school being visited has the right to challenge the appointment of any member of the visiting team and request that RCVS re-considers the appointment if he or she considers that any of the nominated visitors has a conflict of interest that cannot be managed during the visitation process. The head of school should write to the RCVS Head of Education outlining their concerns no later than two weeks after receipt of the formal notification of the proposed visiting team. The Head of Education will consult with the chairs of the RCVS Education Committee and Primary Qualifications Sub-Committee concerning a replacement visitor. Education Committee has the final authority on the appointment of visitors to any given team. (item 3, "RCVS standards and procedures for accreditation", Annex 7, pg, 128, para 5; and Chapter 5, pg 34)

In addition, RCVS Council members are bound by a Conflict of Interest policy and must declare all interests publicly – these are published on the RCVS website. (http://www.rcvs.org.uk/about-us/rcvs-council/council-members/ )
 
Analyst Remarks to Narrative
The agency has and provided its policies regarding conflict of interest and the procedures the agency uses to ensure the individuals involved in the accreditation process do not have a conflict of interest.

For on-site visitors, the agency has specific conflicts of interest which are provided in the written policy. Potential on-site visitors are informed of the policy and must sign a declaration concerning any potential conflicts of interest. A veterinary school has the opportunity to challenge an on-site visitor if it believes a conflict exists.

RCVS Council members, which include the Education Committee and the Primary Qualifications Sub-Committee, are bound by the conflict of Interest policy and must declare all interests publicly.
 
Accreditation Process and Procedures, Question 3
 
Agency Narrative
The consideration of accreditation visit reports is undertaken by the Primary Qualifications Sub-committee which has a stable membership of experienced evaluators. All members of PQSC will have had previous experience of visitations and are well briefed on the requirements. Consistency of decision making is overseen by an experienced chairman, together with RCVS staff. PQSC’s recommendations are ratified by Education Committee, and (as described above), some decisions are further ratified by Council.

Before final decisions are made about accreditation, the Veterinary Surgeons Act provides that the university must have two months after receiving the final visit report in which to submit its comments and response to RCVS (item 1, Veterinary Surgeons Act 1966, Section 5, Supervisory functions of the Council). RCVS accreditation visit reports are in the public domain and are published on the RCVS website, so that previous decisions and reports are transparent. The minutes of Education Committee and Council meetings are published on the RCVS website, so that decision making is transparent. RCVS is subject to the Freedom of Information Act, and must release any further background documents on request. The ultimate check is that RCVS’s decisions as a public body may be legally challenged through the process of Judicial Review. This system of checks and balances guards against any risk of inconsistency in decision making.

The “RCVS standards and procedures for accreditation” includes a detailed checklist of standards for visitors to use at the conclusion of the visit (item 3, Annex 9, pg 133). The visitor team will tick against each standard to indicate whether the programme is compliant, or has minor or major deficiencies against each component of the standards. This checklist approach has only just been introduced and hence is not reflected in older visit reports.
 
Analyst Remarks to Narrative
The agency provided its policies, procedures and guidance to ensure the consistent application of standards. The agency has demonstrated that it has and applies effective controls against the inconsistent application of its standards, to include: written standards, policies, and procedures; guidance provided via written materials; standardized on-site review documents; training of on-site visitors and RCVS members, and review by on-site visitors and RCVS members.