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U.S. Department of Education

 

Initial Petition

 
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 Grenada National Accreditation Board (GNAB) or the agency) currently accredits foreign veterinary programs that participate in such funding programs and has submitted a petition for review.

Historically the Grenada Ministry of Education has been the functional authority for the accreditation of St. George’s University School of Veterinary Medicine (SGUSVM). SGUSVM first opened in August 1999, under the authority of Grenada Act 18 of 1996 as amended in 2011 and 2014. SGUSVM was first accredited on December 23, 2009 based upon Grenada Ministry of Education Standards. Based on the recommendations of the 2009 Ministry of Education Site Visit Team, SGUSVM submitted an application for a renewed accreditation site visit in 2013.

Subsequent to the submission of the 2010 Ministry of Education accreditation and prior to the 2013 Ministry of Education accreditation, SGUSVM applied for and obtained AVMA accreditation in 2011. .

In 2011, based on Grenada Act 15 (The Accreditation Act), Grenada established the Grenada National Accreditation Board (GNAB) as the authority for the accreditation of veterinary schools in Grenada.
 
Summary of Findings
 
Additional information is requested for the following questions. These issues are summarized below and discussed in detail under the Staff Analysis section.

-- The country needs to clearly define its approval and licensing process for its veterinary schools and how the Ministry of Education works with the licensing body to establish and ensure a system of quality veterinary education. It also needs to provide the appropriate documentation demonstrating it compliance with this requirement. [Accreditation System and Authority, Question 2]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section. [Administrative and Fiscal Capacity, Question 2]

-- The agency does not meet the requirements of this section. It needs to describe how during its evaluation it determines if the institutions faculty is sufficient in size [Faculty, Question 1]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section. [Faculty, Question 2]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section. [Curricula, Question 2]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section. [Curricula, Question 4]

-- The agency does not meet the requirements of this section. It needs to provide documentation of its review of the veterinary school's admission practices via a site review report or self-study. [Admissions and Recruiting, Question 2]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section. [Facilities, Question 3]

-- The agency does not meet the requirements of this section. It needs to provide a narrative which includes specific documentation or evidence of compliance with the section [Accreditation Process and Procedures, Question 1]

 
Staff Analysis
 
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.

PART 1: Entity Responsible for the Accreditation/Approval of Medical Schools
 
Accreditation System and Authority, Question 1
 
Agency Narrative
Historically the Grenada Ministry of Education has been the functional authority for the accreditation of St. George’s University School of Veterinary Medicine (SGUSVM). SGUSVM first opened in August 1999, under the authority of Grenada Act 18 of 1996 as amended in 2011 and 2014. Also included is the original St. George’s University School of Medicine, Limited Act 17 of 1976. The four legislations are included as Attachment 1. SGUSVM was first accredited on December 23, 2009 based upon Grenada Ministry of Education Standards. Evidence of this accreditation is provided as Attachment 2. Based on the recommendations of the 2009 Ministry of Education Site Visit Team, SGUSVM submitted an application for a renewed accreditation site visit in 2013. Evidence of that renewed accreditation is provided as Attachment 3.

Subsequent to the submission of the 2010 Ministry of Education accreditation and prior to the 2013 Ministry of Education accreditation, SGUSVM applied for and obtained AVMA accreditation in 2011. Evidence of that accreditation is provided in Attachment 4.

In 2011, based on Grenada Act 15 (The Accreditation Act), Grenada established the Grenada National Accreditation Board (GNAB) as the authority for the accreditation of veterinary schools in Grenada. A copy of this act is provided as Attachment 5.

In response to Herman Bounds’ letter of January 29, 2015, the GNAB responded that the GNAB intends to file an Acceptability Application with the Department of Education by March 15, 2015. In that letter the GNAB indicates that an initial accreditation of the St. Georges’ University School of Veterinary Medicine has been granted based upon the 2011 AVMA accreditation. This letter is provided as Attachment 6.
 
Analyst Remarks to Narrative
The Country provided documentation which includes the Grenada Accreditation Act of 2011 establishing and designating the Grenada Ministry of Education as the functional authority for the accreditation of Medicals Schools within the country. The Grenada Accreditation Act of 2011 also established and designated the Grenada National Accreditation Board (GNAB) as the accreditor of the countries medical schools which include St. George's University School of Veterinary Medicine (SGUSVM).
 
Accreditation System and Authority, Question 2
 
Agency Narrative
The Grenada National Accreditation Board (GNAB), as its name implies, has authority in the country of Grenada only. The GNAB is very similar, however, in structure to accreditation boards formed in a number of nearby CARICOM countries in recent years based upon a template circulated by the Organization of Eastern Caribbean States in 2005. The GNAB was established in Grenada via act 15 of 2011, operates under the authority of the Minister of Education and has been under development since 2011. Since the Ministry of Education’s standards for Veterinary medicine (Attachment 7) were based largely on the standards of the AVMA and applied by consultants knowledgeable in the field of veterinary medical education, the choice by GNAB to use AVMA accreditation in its accreditation of Grenada veterinary schools was a natural outgrowth.

The GNAB accreditation of veterinary schools in Grenada is based on the veterinary school having current, accredited status by the AVMA. GNAB’s initial accreditation of SGUSOM is evidenced in Attachment 6.

AVMA-COE Standards, Section 10.14, “loss of Legal Authority to Provide Postsecondary Education”, Section 10.15, “Loss of Institutional Accreditation”, Section10.16, “Decisions of Other Accrediting Agencies” and section 10.17, Policies on Reporting to USDE” also address this question. See Below:

10.14. Loss of Legal Authority to Provide Postsecondary Education

If the COE learns that a school it accredits or preaccredits, or an institution that offers a program it accredits or preaccredits, is the subject of an adverse action by another recognized accrediting agency or has been placed on probation or an equivalent status by another recognized agency, the COE will promptly review the accreditation or preaccreditation of school to determine if it should also take adverse action or place the program on probation or show cause.
The COE will share information about the accreditation or preaccreditation status of a program and any adverse actions it has taken against an accredited or preaccredited program upon request with other appropriate recognized accrediting agencies and recognized State approval agencies. This includes Probationary Accreditation.

10.15. Loss of Institutional Accreditation

The Council will revoke the accreditation of a college which has lost its institutional accreditation. The Council will notify the Secretary of Education within 30 days of the action to revoke accreditation. Further, the Council will notify the appropriate postsecondary institutional accrediting body and the public no later than 24 hours following the withdrawal of accreditation or after any appeal has been resolved. The Council will not consider evaluating a college that has lost its institutional accreditation.

10.16. Decisions of Other Accrediting Agencies

The COE monitors programs throughout the accreditation cycle via annual reports, third party comment, and focused site visits. The Council will respond to any program not meeting the standards, even if the parent institution or program is involved in litigation. Conditions could exist within an institution where compliance with a Standard of Accreditation or reasonable assurance may change to noncompliance, due to action of another agency. If any of the following conditions are confirmed, the Council will notify the institution in writing, within 30 days of confirmation, that accreditation will not be renewed based upon an unfavorable outcome wherein:
1. An institution is subject to an interim action by a recognized institutional accrediting agency which could lead to suspension, revocation, or termination of accreditation or reasonable assurance.
2. An institution is subject to an interim action by a recognized state agency which could lead to suspension, revocation, or termination of accreditation or reasonable assurance.
3. An institution has been notified of a threatened loss of accreditation and due process procedure is not complete.
4. An institution has been notified of a threatened suspension, revocation, or termination by the state of the institution’s legal authority to provide postsecondary education and the due process procedure is not complete.

10.17. Policies on Reporting to USDE

An updated listing of accredited colleges of veterinary medicine, noting those institutions wherein an adverse action has been taken or those that have voluntarily withdrawn from the accreditation process, will be submitted to the Secretary of the Department of Education within 30 days of the decision. Additionally, a listing of colleges and the accreditation status of each is submitted annually. The COE will notify the Department of Education within 30 days regarding the following:
• A list of the accreditation and reasonable assurance decisions made.
• A decision by the COE to award provisional accreditation or reasonable assurance to a newly formed college.
• A final decision by the COE to deny, withdraw, suspend, or terminate the accreditation or provisional accreditation of a college; or to take other adverse action against a college.*
• A decision by the COE to place a college on probationary accreditation. Within 24 hours of notification of the program, the COE will notify the public of its decision via the AVMA web site.
• A decision by an accredited college to withdraw voluntarily from accreditation or provisional accreditation.
• A decision by an accredited college to let its accreditation or provisional accreditation lapse.

If the Secretary requests additional information on a preaccredited or accredited program, the COE will respond in a timely manner. The COE will forward a copy of its annual data noting major accrediting activities during the previous year, if so requested by the USDE. The COE does not currently prepare an annual report of its accreditation activities. However, if such a report is developed at a future date, the document will be forwarded to the USDE on an annual basis. If the COE believes a college or school is failing to meet its Title IV, Higher Education Authority responsibilities or is engaged in fraud or abuse, the name of that institution will be provided to the USDE.
The Secretary will be provided with information regarding any proposed change that will alter the COE’s scope of recognition or compliance. Within 60 days of a final decision regarding accreditation or reasonable assurance status, the COE will make available to the Department of Education, appropriate state postsecondary education review entities; and to the public upon request, a brief statement summarizing the reasons for the final decision to deny, withdraw, suspend, or terminate accreditation or provisional accreditation of a college, and the comments the college may wish to make with regard to the decision.
 
Analyst Remarks to Narrative
While the country has established that the legal authority to operate a school of Veterinary medicine within Grenada is from the Ministry of Education. It is not clear what specific body serves as the licensing authority within the country, or how the Ministry of Education works with the licensing body to establish and ensure a system of quality veterinary education.
 
Agency Response
As outlined in Grenada Act Number 15 (the Accreditation Act), the Grenadian National Accreditation Board (GNAB) is the accrediting arm of the Ministry of Education. (Attachment 5). GNAB has been under development since 2011. Pursuant to Part II, Section 4 of the Accreditation Act, GNAB is responsible for evaluating and accrediting institutions operating in Grenada, including veterinary schools. In addition, GNAB advises the Ministry of Education on the issuance of charters and licenses to post-secondary institutions to operate or continue to operate in Grenada. (See Attachment 5: The Accreditation Act, Part II, Section 4(q)). All private post-secondary educational institutions must be accredited by GNAB in order to operate in Grenada. As a result, GNAB’s accreditation operates as Grenada’s licensing approval process for institutions and programs. (See Attachment 5: Accreditation Act, Section 30(3); “Any entity found operating in Grenada … without accreditation from [GNAB] shall be penalized pursuant to the provisions of section 37.”).

In performing its functions and assuring the quality of veterinary education, GNAB/Ministry of Education has authority to establish relationships with national and external accrediting and quality assurance bodies, and review and adopt their systems of accreditation, procedures, and practices. (See Attachment 5: The Accreditation Act, Part II, Section 4(j)). With respect to veterinary schools, GNAB uses the AVMA standards and procedures in determining whether a school’s programs are of sufficient quality, just as the Ministry of Education relied on AVMA standards. In practice, this means that if the AVMA accredits an institution, it is considered accredited by GNAB. (See Attachment 14 March 5, 2015 Letter from GNAB to U.S. Department of Education). In addition, GNAB may, at its discretion, consult with AVMA or other professional accrediting bodies and may require a school to provide further information as necessary to assist GNAB in reaching an accreditation decision. (See Attachment 5: The Accreditation Act, Part III, Section 18).

Schools must petition GNAB to review and accredit their programs. Accreditation lasts for a period of 5 years at which point it must be renewed. (See Attachment 5: The Accreditation Act, Part III, Section 22). GNAB has authority to recommend to the Ministry of Education that an institution that operates without accreditation from GNAB or otherwise violates the Accreditation Act be closed permanently. (See Attachment 5: The Accreditation Act, Part VII, Section 40).

 
Analyst Remarks to Response
In response to the staff draft analysis, the agency has clarified that GNAB is the accrediting arm of the Ministry of Education and is responsible for evaluating and accrediting institutions operating in Grenada, including veterinary schools. In addition, GNAB advises the Ministry of Education, which is the licensure body, on the issuance of charters and licenses to post-secondary institutions to operate or continue to operate in Grenada.
 
Staff Conclusion: Comprehensive response provided
 
Part 2: Accreditation/Approval Standards
 
Mission and Objectives
 
Agency Narrative
The GNAB uses, based on AVMA accreditation and via AVMA standards requires the following as published in the Accreditation Policies and Procedures of the AVMA, Council on Education, March 2014, revised September 2014, (AVMA-COE Standards) (Attachment 8). The following is excerpted from AVMA-COE Standards section 7.9, Standard 9, curriculum:

The curriculum shall extend over a period equivalent to a minimum of four academic years, including a minimum of one academic year of hands-on clinical education. The curriculum and educational process should initiate and promote lifelong learning in each professional degree candidate.

The curriculum in veterinary medicine is the purview of the faculty of each college, but must be managed centrally based upon the mission and resources of the college. There must be sufficient flexibility in curriculum planning and management to facilitate timely revisions in response to emerging issues, and advancements in knowledge and technology. The curriculum must be guided by a college curriculum committee. The curriculum as a whole must be reviewed at least every seven (7) years. The majority of the members of the curriculum committee must be full-time faculty. Curriculum evaluations should include the gathering of sufficient qualitative and quantitative information to ensure the curriculum content provides current concepts and principles as well as instructional quality and effectiveness.

The curriculum shall provide:

a. an understanding of the central biological principles and mechanisms that underlie animal health and disease from the molecular and cellular level to organismal and population manifestations.

b. scientific, discipline-based instruction in an orderly and concise manner so that students gain an understanding of normal function, homeostasis, pathophysiology, mechanisms of health/disease, and the natural history and manifestations of important animal diseases, both domestic and foreign.

c. instruction in both the theory and practice of medicine and surgery applicable to a broad range of species. The instruction must include principles and hands-on experiences in physical and laboratory diagnostic methods and interpretation (including diagnostic imaging, diagnostic pathology, and necropsy), disease prevention, biosecurity, therapeutic intervention (including surgery), and patient management and care (including intensive care, emergency medicine and isolation procedures) involving clinical diseases of individual animals and populations. Instruction should emphasize problem solving that results in making and applying medical judgments.

d. instruction in the principles of epidemiology, zoonoses, food safety, the interrelationship of animals and the environment, and the contribution of the veterinarian to the overall public and professional healthcare teams.

e. opportunities for students to learn how to acquire information from clients (e.g. history) and about patients (e.g. medical records), to obtain, store and retrieve such information, and to communicate effectively with clients and colleagues.

f. opportunities throughout the curriculum for students to gain an understanding of professional ethics, influences of different cultures on the delivery of veterinary medical services, delivery of professional services to the public, personal and business finance and management skills; and gain an understanding of the breadth of veterinary medicine, career opportunities and other information about the profession.

g. knowledge, skills, values, attitudes, aptitudes and behaviors necessary to address responsibly the health and well-being of animals in the context of ever-changing societal expectations.

h. fair and equitable assessment of student progress. The grading system for the college must be relevant and applied to all students in a fair and uniform manner.
 
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 addresses AVMA's curriculum standards as one example of how the veterinary programs 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
These requirements are stated in Grenada act 15 of 2011 (the Accreditation Act), Part II, Section 4, Paragraphs (p) and (q). Please see Attachment 5:

“(p) to establish the requirements and regulations with which an institution and/or a programme of study must comply, in order to be accredited, reaccredited or validated, or have their awards recognized by the Board;

(q) to advise the Minister on the issuance of charter, licenses or other authorizations to institutions to operate or to continue their operations, on the basis of an appropriate evaluation.”
 
Analyst Remarks to Narrative
The agency has provided documentation demonstrating (via its Grenada Accreditation Act of 2011) that it has accreditation standards that require veterinary schools to be legally authorized to provide a program of veterinary education within an institution of higher education in the country in which it is located.

 
Administrative and Fiscal Capacity, Question 1
 
Agency Narrative
These requirements are outlined in AVMA-COE standards Sections 7.1, Standard 1, Organization and 7.2, Standard 2 (Attachment 8),Finances as follows:

1.1. Standard 1, Organization
The college must develop and follow its mission statement.

An accredited college of veterinary medicine must be a part of an institution of higher learning accredited by an organization recognized for that purpose by its country’s government. A college may be accredited only when it is a major academic administrative division of the parent institution and is afforded the same recognition, status, and autonomy as other professional colleges in that institution.

The chief executive officer or dean must be a veterinarian, and the officer(s) responsible for the professional, ethical, and academic affairs of the veterinary medical teaching hospital must also be (a) veterinarian(s).

There must be sufficient administrative staff to adequately manage the affairs of the college as appropriate to the enrollment and operation.

1.2. Standard 2, Finances

Finances must be adequate to sustain the educational programs and mission of the college.

Colleges with non DVM undergraduate degree programs must clearly report finances (expenditures and revenues) specific to those programs separately from finances (expenditures and revenues) dedicated to all other educational programs.

Clinical services, field services, and teaching hospitals must function as instructional resources. Instructional integrity of these resources must take priority over financial self-sufficiency of clinical services operations.
 
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, There must be sufficient administrative staff to adequately manage the affairs of the college as appropriate to the enrollment , operation and finances must be adequate to sustain the educational programs and mission of the college.

 
Analyst Remarks to Response
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, There must be sufficient administrative staff to adequately manage the affairs of the college as appropriate to the enrollment , operation and finances must be adequate to sustain the educational programs and mission of the college.
 
Staff Conclusion: Comprehensive response provided
 
Administrative and Fiscal Capacity, Question 2
 
Agency Narrative
See Response to C. above
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements.
 
Agency Response
These requirements are outlined in AVMA-COE standards Sections 7.1, Standard 1, Organization and 7.2, Standard 2 (Attachment 8),Finances as follows:

1.1. Standard 1, Organization
The college must develop and follow its mission statement.

An accredited college of veterinary medicine must be a part of an institution of higher learning accredited by an organization recognized for that purpose by its country’s government. A college may be accredited only when it is a major academic administrative division of the parent institution and is afforded the same recognition, status, and autonomy as other professional colleges in that institution.

The chief executive officer or dean must be a veterinarian, and the officer(s) responsible for the professional, ethical, and academic affairs of the veterinary medical teaching hospital must also be (a) veterinarian(s).

There must be sufficient administrative staff to adequately manage the affairs of the college as appropriate to the enrollment and operation.

1.2. Standard 2, Finances

Finances must be adequate to sustain the educational programs and mission of the college.

Colleges with non DVM undergraduate degree programs must clearly report finances (expenditures and revenues) specific to those programs separately from finances (expenditures and revenues) dedicated to all other educational programs.

Clinical services, field services, and teaching hospitals must function as instructional resources. Instructional integrity of these resources must take priority over financial self-sufficiency of clinical services operations.

The AVMA requires schools to report direct and indirect expenses for the past five fiscal years across a variety of subjects. In addition, schools are required to provide detailed information on all sources of school revenue for the past five fiscal years. These reporting requirements are outlined in Section 12.2 of the AVMA accreditation standards.

The E-Recognition system, thus far, has not allowed the copying of the pertinent tables used in this evaluation. Tables A, B,
C and D referenced above must, therefore, be given by reference. These tables are given in Attachment 8, Section 12.2 on pages 40 through to 43 together with footnotes and definitions.


 
Analyst Remarks to Response
In response to the staff draft analysis the agency's provided its standards which require that the institution provide an analysis of the financial trends(expenditures and revenues) specific to the DMV program. The analysis includes:

Comments on the strengths and weaknesses in revenues over the past five years . Which include A comprehensive trend analysis of revenue sources that have supported the professional teaching program over the past five years; An explanation of how revenues over the past five years have impacted the college's ability to provide a contemporary professional teaching program and ancillary support services; A comparison of the percentage of hospital income to total hospital operational costs, and A description of anticipated trends in future revenues and expenditures.
 
Staff Conclusion: Comprehensive response provided
 
Faculty, Question 1
 
Agency Narrative
These requirements are outlined in AVMA-COE Standards(Attachment 8) section 7.8, Standard 8, faculty:
1.1. Standard 8, Faculty
Faculty numbers and qualifications must be sufficient to deliver the educational program and fulfill the mission of the college. Participation in scholarly activities is an important criterion in evaluating the faculty and the college. The college shall give evidence that it utilizes a well-defined and comprehensive program for the evaluation of professional growth, development, and scholarly activities of the faculty.

Academic positions must offer the security and benefits necessary to maintain stability, continuity, and competence of the faculty. Part-time faculty, residents, and graduate students may supplement the teaching efforts of the full-time permanent faculty if appropriately integrated into the instructional program.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that address the quality of the veterinary programs and requirements for the school's faculty to deliver the educational program and fulfill the mission of the college. However, It is not clear to the Department how the agency determines if the institution’s faculty's numbers are sufficient in size.

 
Agency Response
The AVMA requires that schools demonstrate that faculty numbers and qualifications are sufficient to deliver the educational program and fulfill the mission of the college. Participation in scholarly activities is an important criterion in evaluating the faculty and college. Colleges must give evidence that they utilize a well-defined and comprehensive program for the evaluation of the professional growth and development, and scholarly activities of the faculty.

The requirements for determining if the institutions faculty numbers are sufficient in size are set forth in AVMA-COE Standards (Attachment 8), Section 12.8 as follows:

The following system is used by AVMA in self study, site visits and the subsequent site visit reports:

12.8.1. Complete Tables A and B, and assess the strengths of the faculty and support staff in fulfilling the college mission.
12.8.2. State the current number of academic faculty (head count) who possess credentials as listed in Tables C and D.
12.8.3. Assess the challenges for your college in maintaining faculty numbers and quality.
12.8.4. Provide information on the loss (what discipline/specialty) and recruitment of faculty (Table A).
12.8.5. Provide a concise summary of promotion and tenure policies, and the policy to assure stability for non-tenured, long-term faculty.
12.8.6. Provide an estimate of the weight assigned to promotion/tenure and or compensation for teaching, research, service, or other scholarly activities.
12.8.7. Briefly describe faculty professional development opportunities available in the college/university.
12.8.8. Describe current plans or major changes in program direction that would be affected by faculty retirements, recruitment and retention.
12.8.9. Describe measures taken to attract and retain a diverse faculty.
12.8.10. Describe programs for on-campus delivery of curricular content by individuals not employed full time by the institution (other than occasional guest lecturers), including subjects taught. Estimate the percentage of core curricular content delivered in this way.
12.8.11. Describe the role of interns, residents, and graduate students in teaching and evaluating veterinary students.

The E-Recognition system, thus far, has not allowed the copying of the pertinent tables used in this evaluation. Tables A, B,
C and D referenced above must, therefore, be given by reference. These tables are given in Attachment 8, Section 12.8 on pages 51, 52 and 53 together with footnotes and definitions.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency provided its faculty standard, documenting the requirements for determining if institutions have sufficient faculty . The data collected is used to:

Assess the strengths of the faculty and support staff in fulfilling the college mission; Identifies the current number of academic faculty (head count) who possess the appropriate credentials. The agency also uses the collected data to; assess the challenges for the college in maintaining faculty numbers and quality; provide information on the loss (what discipline/specialty) and recruitment of faculty, and to provide a concise summary of promotion and tenure policies, and the policy to assure stability for non-tenured, long-term faculty.
 
Staff Conclusion: Comprehensive response provided
 
Faculty, Question 2
 
Agency Narrative
See response to D. above
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements.
 
Agency Response
Through the self-study and site visit, the AVMA requires schools to demonstrate that its faculty has qualifications sufficient and appropriate to deliver the educational program and fulfill the mission of the college. Participation in scholarly activities is an important criterion in evaluating the faculty and college. Colleges must give evidence that they utilize a well-defined and comprehensive program for the evaluation of the professional growth and development, and scholarly activities of the faculty.

Site visit teams evaluate college faculty on factors such as qualifications, scholarly activities and research, and service activities and look for evidence that the college consider such factors in their tenure policies and annual faculty performance review processes. Colleges must demonstrate that fulltime, permanent faculty provide adequate supervision of any part-time faculty, residence and interns (Attachment 8). AVMA-COE Standards Appendix 1 – Site Visit Team Evaluation Rubric, standard 8 Faculty, pages 122 to 123.

In addition, as discussed above, schools must include detailed information on their faculty numbers, faculty qualifications and areas of specialization in their self-study. The reporting requirements are set forth in AVMA-COE Standards (Attachment 8), Section 12.8 as follows:

The following system is used by AVMA in self-study, site visits and the subsequent site visit reports:

12.8.1. Complete Tables A and B, and assess the strengths of the faculty and support staff in fulfilling the college mission.
12.8.2. State the current number of academic faculty (head count) who possess credentials as listed in Tables C and D.
12.8.3. Assess the challenges for your college in maintaining faculty numbers and quality.
12.8.4. Provide information on the loss (what discipline/specialty) and recruitment of faculty (Table A).
12.8.5. Provide a concise summary of promotion and tenure policies, and the policy to assure stability for non-tenured, long-term faculty.
12.8.6. Provide an estimate of the weight assigned to promotion/tenure and or compensation for teaching, research, service, or other scholarly activities.
12.8.7. Briefly describe faculty professional development opportunities available in the college/university.
12.8.8. Describe current plans or major changes in program direction that would be affected by faculty retirements, recruitment and retention.
12.8.9. Describe measures taken to attract and retain a diverse faculty.
12.8.10. Describe programs for on-campus delivery of curricular content by individuals not employed full time by the institution (other than occasional guest lecturers), including subjects taught. Estimate the percentage of core curricular content delivered in this way.
12.8.11. Describe the role of interns, residents, and graduate students in teaching and evaluating veterinary students.

The E-Recognition system, thus far, has not allowed the copying of the pertinent tables used in this evaluation. Tables A, B,
C and D referenced above must, therefore, be given by reference. These tables are given in Attachment 8, Section 12.8 on pages 51, 52 and 53 together with footnotes and definitions.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency has clarified its requirements for DMV program faculty and administrator positions, and provided the AVMA standards used to evaluate the requirements of this section. (AVMA Standards Appendix 1 - Site Visit Team Evaluation Rubric, standard 8 Faculty, pages 122 to 123).
 
Staff Conclusion: Comprehensive response provided
 
Faculty, Question 3
 
Agency Narrative
These requirements are set forth in AVMA-COE Standards(Attachment 8), section 8, Off-Campus and Distributive Sites, Subsection 8.1, “Off-Campus Clinical Education sites for Colleges with Teaching Hospitals” and Subsection 8.2 “Guidelines for Implementation of a Distributive Veterinary Clinical Education Model”, as follows:


8.1. Off-campus Clinical Education Sites for Colleges with Teaching Hospitals
a. An off-campus site where a specific educational objective is offered.

b. The site is externally located from the main campus and is (usually) not administratively associated with the degree granting institution.

c. Professional staff providing education might not be employees of the degree granting institution but may be receiving remuneration as a contractor, fee-for-service provider, etc. for time/effort devoted to the educational program.

d. The off-campus site must be reviewed to ensure that the educational program is being delivered appropriately.
e. There must be a written description of the educational objectives expected to be achieved at the site and a mechanism for assessing the success of the educational process, i.e. proof that educational objectives are being met.

f. These guidelines do not apply to off-campus educational experiences that are attended sporadically by individual students to augment their on-campus education.

8.2. COE Guidelines for Implementation of a Distributive Veterinary Clinical Education Model

a. The clinical sites selected by a college to serve in a distributive clinical educational model should receive appropriate financial remuneration per student from the college in order to help ensure that students receive on-site supervised clinical instruction, with formal written contract of expectations.

b. The college must prepare and distribute appropriate materials for clinical site educators that detail objectives of the program, expectations of the site coordinators, clinical site educator training
materials, instructions concerning the format the college wants used to evaluate student performance and provide feedback to students on progress/deficiencies associated with site experience.

c. Additionally the college must provide to the students, and clinical site educators alike, the expectations of the college for student safety and security while the student is on site.

d. Distributed clinical sites must be selected on the basis of specific criteria and identified for instruction in precise disciplines (defined by the college) such as, but not limited to: Food Animal/Equine/Small Animal Medicine; Food Animal/Equine/Small Animal Surgery or Food Animal or Equine or Small Animal Medicine and Surgery; Dermatology, Imaging (radiology, etc.), Neurology, Cardiology, Critical Care Emergency Medicine, etc.

e. For distributed clinical sites the college must take steps to ensure that the educational objectives and anticipated outcomes are thoroughly promulgated and understood by students and clinical site coordinators alike.

f. The college must designate to the COE what clinical sites are considered as primary instructional sites as defined by Standard 9 (c) and these will be considered by COE as core instructional sites. These sites must be in compliance with AVMA-COE Standards.

g. The college must document/assess that students and educators clearly understand how evaluation and grading practices will be conducted at each clinical site including clinical competencies.

h. Veterinarians must be licensed and technicians should be certified, licensed, or registered as appropriate to that jurisdiction.

i. The college must document that students are fully informed concerning their ability to report any and all safety, physical, and emotional concerns to the college.

j. The college must put in place a system to regularly monitor/supervise the instructional activities at each clinical site and report this system with any subsequent changes and outcomes to the COE.

k. Each clinical site educator must abide by a process devised by the college to provide a written evaluation of the performance of each student.

l. Students must provide the college with an evaluation of each site (after the respective rotation) including an evaluation of teaching at the site and the student’s opportunity to perform hands-on procedures at the site. The college must summarize this information for the COE.

m. The COE may inspect clinical sites at any time students are present; these inspections, including travel and per diem costs, will be at the expense of the college.

n. The college must put in place a system to measure and document clinical competencies outcomes at clinical sites as specified by the COE (see Section 12.11.2) to assess clinical sites.
 
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. 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.
 
Curricula, Question 1
 
Agency Narrative
These requirements are outlined in AVMA-COE Standards (Attachment 8), Section 7.9 “ Standard 9, Curriculum”, as follows:


7.9. Standard 9, Curriculum
The curriculum shall extend over a period equivalent to a minimum of four academic years, including a minimum of one academic year of hands-on clinical education. The curriculum and educational process should initiate and promote lifelong learning in each professional degree candidate.

The curriculum in veterinary medicine is the purview of the faculty of each college, but must be managed centrally based upon the mission and resources of the college. There must be sufficient flexibility in curriculum planning and management to facilitate timely revisions in response to emerging issues, and advancements in knowledge and technology. The curriculum must be guided by a college curriculum committee. The curriculum as a whole must be reviewed at least every seven (7) years. The majority of the members of the curriculum committee must be full-time faculty. Curriculum evaluations should include the gathering of sufficient qualitative and quantitative information to ensure the curriculum content provides current concepts and principles as well as instructional quality and effectiveness.
The curriculum shall provide:

a. an understanding of the central biological principles and mechanisms that underlie animal health and disease from the molecular and cellular level to organismal and population manifestations.

b. scientific, discipline-based instruction in an orderly and concise manner so that students gain an understanding of normal function, homeostasis, pathophysiology, mechanisms of health/disease, and the natural history and manifestations of important animal diseases, both domestic and foreign.

c. instruction in both the theory and practice of medicine and surgery applicable to a broad range of species. The instruction must include principles and hands-on experiences in physical and laboratory diagnostic methods and interpretation (including diagnostic imaging, diagnostic pathology, and necropsy), disease prevention, biosecurity, therapeutic intervention (including surgery), and patient management and care (including intensive care, emergency medicine and isolation procedures) involving clinical diseases of individual animals and populations. Instruction should emphasize problem solving that results in making and applying medical judgments.

d. instruction in the principles of epidemiology, zoonoses, food safety, the interrelationship of animals and the environment, and the contribution of the veterinarian to the overall public and professional healthcare teams.

e. opportunities for students to learn how to acquire information from clients (e.g. history) and about patients (e.g. medical records), to obtain, store and retrieve such information, and to communicate effectively with clients and colleagues.

f. opportunities throughout the curriculum for students to gain an understanding of professional ethics, influences of different cultures on the delivery of veterinary medical services, delivery of professional services to the public, personal and business finance and management skills; and gain an understanding of the breadth of veterinary medicine, career opportunities and other information about the profession.

g. knowledge, skills, values, attitudes, aptitudes and behaviors necessary to address responsibly the health and well-being of animals in the context of ever-changing societal expectations.

h. fair and equitable assessment of student progress. The grading system for the college must be relevant and applied to all students in a fair and uniform manner.
 
Analyst Remarks to Narrative
The agency provided documentation demonstrating 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 curriculum in veterinary medicine is the purview of the faculty of each college, but must be managed centrally based upon the mission and resources of the college. There must be sufficient flexibility in curriculum planning and management to facilitate timely revisions in response to emerging issues, and advancements in knowledge and technology. The curriculum must be guided by a college curriculum committee. The curriculum as a whole must be reviewed at least every seven (7) years. The majority of the members of the curriculum committee must be full-time faculty. Curriculum evaluations should include the gathering of sufficient qualitative and quantitative information to ensure the curriculum content provides current concepts and principles as well as instructional quality and effectiveness.
 
Curricula, Question 2
 
Agency Narrative
See response to E. above
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements.
 
Agency Response
GNAB relies on the AVMA standards with respect to program length. These requirements are set forth in AVMA-COE Standards (Attachment 8), Section 7.9, Curriculum in the first paragraph as follows:

“The curriculum shall extend over a period equivalent to a minimum of four academic years, including a minimum of one academic year of hands-on clinical education”.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency has clarified the country's requirements for DVM program length and provided AVMA standards which document a minimum of four academic years, including a minimum of one academic year of clinical practice. (AVMA Standards (Attachment 8), Section 7.9, Curriculum)
 
Staff Conclusion: Comprehensive response provided
 
Curricula, Question 3
 
Agency Narrative
These requirements are addressed in AVMA-COE Standards, (Attachment 8), Section 7.9, “Standard 7.9 Curriculum”, under the heading, “The curriculum shall provide”, Subsection f. g. and h. as follows:

f. opportunities throughout the curriculum for students to gain an understanding of professional ethics, influences of different cultures on the delivery of veterinary medical services, delivery of professional services to the public, personal and business finance and management skills; and gain an understanding of the breadth of veterinary medicine, career opportunities and other information about the profession.

g. knowledge, skills, values, attitudes, aptitudes and behaviors necessary to address responsibly the health and well-being of animals in the context of ever-changing societal expectations.

h. fair and equitable assessment of student progress. The grading system for the college must be relevant and applied to all students in a fair and uniform manner.

Requirements for general assessment of educational outcomes are addressed in AVMA-COE Standards, Section 7.11, Standard 11, ”Outcomes Assessment” as follows:


7.11. Standard 11, Outcomes Assessment

Outcomes of the DVM program must be measured, analyzed, and considered to improve the program. Student achievement during the pre-clinical and clinical curriculum and after graduation must be included in outcome assessment. New graduates must have the basic scientific knowledge, skills, and values to provide entry-level health care, independently, at the time of graduation.
The school/college must develop relevant measures and provide evidence that graduating students have attained the following competencies:
1. comprehensive patient diagnosis (problem solving skills), appropriate use of clinical laboratory testing, and record management
2. comprehensive treatment planning including patient referral when indicated
3. anesthesia and pain management, patient welfare
4. basic surgery skills, experience, and case management
5. basic medicine skills, experience and case management
6. emergency and intensive care case management
7. health promotion, disease prevention/biosecurity, zoonosis, and food safety
8. client communications and ethical conduct
9. critical analysis of new information and research findings relevant to veterinary medicine.

The Council on Education expects that 80% or more of each college’s graduating senior students sitting for the NAVLE will have passed at the time of graduation.*
*The Council will calculate a 95% exact binomial confidence interval for the NAVLE scores for colleges whose NAVLE pass rate falls below 80%. Colleges with an upper limit of an exact 95% binomial confidence interval less than 85% for two successive years will be placed on Probationary Accreditation. Colleges with an upper limit of an exact 95% binomial confidence level less than 85% for four successive years will, for cause, be placed on terminal accreditation.
 
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. The agency's standards also require the curriculum to cover professional ethics and animal patient care.
 
Curricula, Question 4
 
Agency Narrative
See response above
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements
 
Agency Response
Requirements for evaluating the mechanisms a school has in place to monitor and evaluate the success of the instruction in ethics are addressed in the AVMA-COE general assessment standards (Attachment 8), Section 7.11, Standard 11, ”Outcomes Assessment” as follows:

7.11. Standard 11, Outcomes Assessment

Outcomes of the DVM program must be measured, analyzed, and considered to improve the program. Student achievement during the pre-clinical and clinical curriculum and after graduation must be included in outcome assessment. New graduates must have the basic scientific knowledge, skills, and values to provide entry-level health care, independently, at the time of graduation. The school/college must develop relevant measures and provide evidence that graduating students have attained the following competencies:

1. comprehensive patient diagnosis (problem solving skills), appropriate use of clinical laboratory testing, and record management
2. comprehensive treatment planning including patient referral when indicated
3. anesthesia and pain management, patient welfare
4. basic surgery skills, experience, and case management
5. basic medicine skills, experience and case management
6. emergency and intensive care case management
7. health promotion, disease prevention/biosecurity, zoonosis, and food safety
8. client communications and ethical conduct
9. critical analysis of new information and research findings relevant to veterinary medicine.

As evidenced in the site team evaluation rubric, schools must demonstrate that they evaluate student outcomes across all subject areas within the program, including ethics. AVMA-COE Standards Appendix 1 – Site Visit Team Evaluation Rubric, standard 8 Faculty, pages 109, 131.

The Council on Education expects that 80% or more of each college’s graduating senior students sitting for the NAVLE will have passed at the time of graduation.*

*The Council will calculate a 95% exact binomial confidence interval for the NAVLE scores for colleges whose NAVLE pass rate falls below 80%. Colleges with an upper limit of an exact 95% binomial confidence interval less than 85% for two successive years will be placed on Probationary Accreditation. Colleges with an upper limit of an exact 95% binomial confidence level less than 85% for four successive years will, for cause, be placed on terminal accreditation.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency's narrative documents the AVMA standard used to evaluate outcome Assessment in client communications and ethical conduct.. The agency also provided a Site Team Evaluation Report demonstrating the evaluation of the requirements of this section. (Appendix-1)
 
Staff Conclusion: Comprehensive response provided
 
Curricula, Question 5
 
Agency Narrative
These requirements are addressed in AVMA-COE Standard 7.3, Physical facilities and Equipment, in the final paragraph as follows:

Facilities for the housing of animals used for teaching and research shall be sufficient in number, properly constructed, and maintained in a manner consistent with accepted animal welfare standards. Adequate teaching, laboratory, research, and clinical equipment must be available for examination, diagnosis, and treatment of all animals used by the college. Safety of personnel and animals must be assured.
 
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.


 
Curricula, Question 6
 
Agency Narrative
St. George’s University School of Veterinary Medicine does not have internships or residencies within its program. The standards regarding clinical training within Veterinary programs are given in AVAM-COE Standards (Attachment 8), Section 8.1and 8.2 were provided in response to PART 2, (d), “Faculty”, Question 2 but are repeated here for ease of review:


8.1. Off-campus Clinical Education Sites for Colleges with Teaching Hospitals

a. An off-campus site where a specific educational objective is offered.

b. The site is externally located from the main campus and is (usually) not administratively associated with the degree granting institution.

c. Professional staff providing education might not be employees of the degree granting institution but may be receiving remuneration as a contractor, fee-for-service provider, etc. for time/effort devoted to the educational program.

d. The off-campus site must be reviewed to ensure that the educational program is being delivered appropriately.

e. There must be a written description of the educational objectives expected to be achieved at the site and a mechanism for assessing the success of the educational process, i.e. proof that educational objectives are being met.

f. These guidelines do not apply to off-campus educational experiences that are attended sporadically by individual students to augment their on-campus education.

8.2. COE Guidelines for Implementation of a Distributive Veterinary Clinical Education Model

a. The clinical sites selected by a college to serve in a distributive clinical educational model should receive appropriate financial remuneration per student from the college in order to help ensure that students receive on-site supervised clinical instruction, with formal written contract of expectations.

b. The college must prepare and distribute appropriate materials for clinical site educators that detail objectives of the program, expectations of the site coordinators, clinical site educator training
materials, instructions concerning the format the college wants used to evaluate student performance and provide feedback to students on progress/deficiencies associated with site experience.

c. Additionally the college must provide to the students, and clinical site educators alike, the expectations of the college for student safety and security while the student is on site.

d. Distributed clinical sites must be selected on the basis of specific criteria and identified for instruction in precise disciplines (defined by the college) such as, but not limited to: Food Animal/Equine/Small Animal Medicine; Food Animal/Equine/Small Animal Surgery or Food Animal or Equine or Small Animal Medicine and Surgery; Dermatology, Imaging (radiology, etc.), Neurology, Cardiology, Critical Care Emergency Medicine, etc.

e. For distributed clinical sites the college must take steps to ensure that the educational objectives and anticipated outcomes are thoroughly promulgated and understood by students and clinical site coordinators alike.

f. The college must designate to the COE what clinical sites are considered as primary instructional sites as defined by Standard 9 (c) and these will be considered by COE as core instructional sites. These sites must be in compliance with AVMA-COE Standards.

g. The college must document/assess that students and educators clearly understand how evaluation and grading practices will be conducted at each clinical site including clinical competencies.

h. Veterinarians must be licensed and technicians should be certified, licensed, or registered as appropriate to that jurisdiction.

i. The college must document that students are fully informed concerning their ability to report any and all safety, physical, and emotional concerns to the college.

j. The college must put in place a system to regularly monitor/supervise the instructional activities at each clinical site and report this system with any subsequent changes and outcomes to the COE.

k. Each clinical site educator must abide by a process devised by the college to provide a written evaluation of the performance of each student.

l. Students must provide the college with an evaluation of each site (after the respective rotation) including an evaluation of teaching at the site and the student’s opportunity to perform hands-on procedures at the site. The college must summarize this information for the COE.

m. The COE may inspect clinical sites at any time students are present; these inspections, including travel and per diem costs, will be at the expense of the college.

n. The college must put in place a system to measure and document clinical competencies outcomes at clinical sites as specified by the COE (see Section 12.11.2) to assess clinical sites.
 
Analyst Remarks to Narrative
While St. George’s University School of Veterinary Medicine does not have internships or residencies within its program. 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.
 
Student Achievement, Question 1
 
Agency Narrative
The requirements by which veterinary schools are to evaluate student achievement are provided in AVMA-COE Standards (Attachment 8) Section 7.11, “Standard 11, Outcome Assessment”, and were provided in response to Part 2, (e), Question 2 and are repeated below for ease of review:
7.11. Standard 11, Outcomes Assessment

Outcomes of the DVM program must be measured, analyzed, and considered to improve the program. Student achievement during the pre-clinical and clinical curriculum and after graduation must be included in outcome assessment. New graduates must have the basic scientific knowledge, skills, and values to provide entry-level health care, independently, at the time of graduation.
The school/college must develop relevant measures and provide evidence that graduating students have attained the following competencies:
1. comprehensive patient diagnosis (problem solving skills), appropriate use of clinical laboratory testing, and record management
2. comprehensive treatment planning including patient referral when indicated
3. anesthesia and pain management, patient welfare
4. basic surgery skills, experience, and case management
5. basic medicine skills, experience and case management
6. emergency and intensive care case management
7. health promotion, disease prevention/biosecurity, zoonosis, and food safety
8. client communications and ethical conduct
9. critical analysis of new information and research findings relevant to veterinary medicine.

The Council on Education expects that 80% or more of each college’s graduating senior students sitting for the NAVLE will have passed at the time of graduation.*

*The Council will calculate a 95% exact binomial confidence interval for the NAVLE scores for colleges whose NAVLE pass rate falls below 80%. Colleges with an upper limit of an exact 95% binomial confidence interval less than 85% for two successive years will be placed on Probationary Accreditation. Colleges with an upper limit of an exact 95% binomial confidence level less than 85% for four successive years will, for cause, be placed on terminal accreditation.

While and accredited veterinary School is free to set its own standards with regard to this requirement, the school must meet the AVMA-COE standard.
 
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. While and accredited veterinary School is free to set its own standards with regard to this requirement, the school must meet the AVMA-COE standard.


 
Student Achievement, Question 2
 
Agency Narrative
The AVMA requirements relating to passing the NAVLE examinations are directly related to student performance and the outcome analysis of this data rather than prescribing detailed policy and practice within the school. The standards for this analysis are outlined in the response immediately above and the following paragraphs.


Section 17.9. Review of NAVLE Scores

The NAVLE assesses entry-level competency for licensure to practice veterinary medicine. The SRG evaluates NAVLE results annually, by noting significant changes in scores and passing rates over time and significant differences in scores or passing rates among graduates from different veterinary colleges. Decreasing scores may indicate a reduction in the adequacy of the standards, while significant differences among graduates from different colleges may suggest the standards are not relevant.

During the fall meeting the Academic Affairs Committee reviews the SRG analysis. Recommendations from this committee are used to assess the potential for needed changes in or application of the standards. Processes are initiated by the COE to make necessary changes.
 
Analyst Remarks to Narrative
The Department was not able to identify any agency requirement that the school specifically prepare US students for taking and passing the North American Veterinary Licensing Examination (NAVLE). However, the AVMA standards do require the essential elements of the NAVLE within the school’s curriculum which are directly related to student performance and outcomes.

 
Student Achievement, Question 3
 
Agency Narrative
This is also addressed in the response above.

The AVMA-COA requirement for data collection for this standard is defined in AVMA-COE Standards (Attachment 8), Section 12.11, “Outcomes Assessment” as follows:


12.11. Outcomes Assessment
*The Council will calculate a 95% exact binomial confidence interval for the NAVLE scores for colleges whose NAVLE pass rate falls below 80%. Colleges with an upper limit of an exact 95% binomial confidence interval less than 85% for two successive years will be placed on Probationary Accreditation. Colleges with an upper limit of an exact 95% binomial confidence level less than 85% for four successive years will, for cause, be placed on Terminal Accreditation.

Data to demonstrate outcomes of the educational and institutional program(s) may be collected by a number of means including, but not limited to, surveys, interviews, focus groups, self-assessments, third-party provider, information held by the college, and other. Where appropriate, the data must be analyzed/summarized for brevity.

Except for North American Veterinary Licensing Examination (NAVLE), the Council does not assign numerical values to document levels of achievement for students in any of the outcome delineators, but closely analyzes trends for the college. Trends that imply significant decrease(s) in student achievement over a five-year period may imply deficiencies in the program. The trends are used by the Council in its analysis of the compliance of the college with the Standards. In the case of declining trends in the delineators, the college must provide an explanation for the decline(s), and must provide a plan to reverse the trend(s).



12.11.1. Student educational outcomes must include, but are not limited
to:

12.11.1.a. NAVLE school score report data and passage rates over the past five years (Table A),

Each college must submit a copy of the annual NAVLE School Score Report with the AVMA-COE Interim Report each year.
12.11.1.b. student attrition rates with reasons (Table B),

Each college must submit data on absolute attrition every year. The Council on Education expects that an increasing (positive) trend in absolute attrition from the college will be explained, and that the college will implement steps for arresting the trend.

12.11.1.c. the learning objectives for each of the nine listed competencies, and a summary of the analysis of evidence-based data collected for each of the nine listed competencies used to ensure that graduates are prepared for entry level practice (please note that a listing of core and elective blocks does not constitute evidence of learning). Evidence of student learning outcomes for clinical competencies must be obtained by direct measures. These may include capstone experiences, student portfolios, standardized clinical proficiency exams, or other evaluations of clinical performance based on measurable and published program objectives. Indirect measures should not be used as the sole determinants of clinical competency outcomes. Examples include employer surveys and student course or rotation grades

12.11.1.d. employment rates of graduates (within one year of graduation) (Table C),
Each college must submit data on one-year post –graduate employment every year. The Council on Education expects that a declining (negative) trend in proportionate employment from the college will be explained, and that the college will implement steps for arresting the trend, if possible.

12.11.1.e. assessments of graduating seniors; and assessments of alumni at some post-graduation point (for example, three and/or five years post-graduation) assessing educational preparedness and employment satisfaction,

12.11.1.f. assessments of employers of graduates to determine satisfaction with the graduates,

12.11.1.g. assessments of faculty (and other instructors, for example interns and residents) related to such subjects as adequacy of clinical resources, facilities and equipment, information resources, etc.; and preparedness of students entering phases of education, and

12.11.1.h. additional assessment that might assist the college in benchmarking its educational program.

12.11.2. Institutional outcomes.

12.11.2.a. Describe how the college evaluates progress in meeting its mission (for example, benchmarking with other institutions, etc.).

12.11.2.b. Describe the adequacy of resources and organizational structure to meet the educational purposes (dean should provide).

12.11.2.c. Describe outcomes assessed for college activities that are meaningful for the overall educational process (for example, scholarly activity of the faculty, faculty awards, faculty and staff perception of teaching resources, student satisfaction with the educational program, teaching improvement benchmarks, and others). If your program assesses other outcomes, briefly describe the results.

12.11.2.d. Describe how outcomes findings are used by the college to improve the educational program (give examples).


Table A – NAVLE

Year Students Taking Exam(s) Students Passing Exam(s) Average scores




Table B- Attrition
Reason For Relative Attrition Absolute Attrition**

Entering Class Attrition* Academic Failure/
Additional Program Personal Number Percentage




* Students that are either withdrawing from the program or moving to a different (earlier) class
** Students who leave and never return


Table C
Graduating Class # Graduates Who Received Employment or Advanced
Training Offers / # Completing This Question, and (%) Mean # Employment or Advanced Training Offers Received
 
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. Also,
data to demonstrate outcomes of the educational and institutional program(s) are collected by a number of means including, but not limited to, surveys, interviews, focus groups, self-assessments, third-party provider, information held by the college, and other. Where appropriate, the data must be analyzed/summarized for brevity .

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
A single response is provided to this and the following two questions. Neither GNAB nor AVMA-COE defines specific requirements for admission to veterinary school. AVMA-COE does require the following as stated in AVMA-COE Standards (Attachment 8) Section 7.7. Standard 7, “Admissions” as follows:


7.7. Standard 7, Admission
The college shall have a well-defined and officially stated admissions policy. The policy shall provide for an Admissions Committee, a majority of whom shall be full-time faculty members. The Committee shall make recommendations regarding the students to be admitted to the professional curriculum upon consideration of applications of candidates who meet the academic and other requirements as defined in the college's formal admission policy.

Subjects for admission shall include those courses prerequisite to the professional program in veterinary medicine, as well as courses that contribute to a broad general education. The goal of preveterinary education shall be to provide a broad base upon which professional education may be built, leading to lifelong learning with continued professional and personal development.

Factors other than academic achievement must be considered for admission criteria.

The following information is required by AVMA-COE Standards (Attachment 8) under Section 12.7 for the evaluation of the admissions practices:


12.7.1. State the minimum requirements for admission.
12.7.2. Describe the student selection process, including measures to enhance diversity.
12.7.3. List factors other than academic achievement used as admission criteria.
12.7.4. Complete Table A.
12.7.5. Describe current plans for assessing the success of the selection process to meet the mission of the college.
12.7.6. Describe your policies and procedures for admitting transfer students who will receive a degree from your institution, and state the number of transfer students admitted per year for the last five years.



Table A

Year State Residents Non-Residents Contract Students Total
A/P* O/A** A/P O/A A/P O/A A/P O/A





*A/P=Applications/Positions Available
**O/A=Offers made/Acceptances
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address admission and recruiting requirements. 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
See response immediately above
 
Analyst Remarks to Narrative
The agency failed to provide documentation demonstrating that it evaluates the quality of the veterinary school's admission practices during the site visit and/or via self-study documentation.
 
Agency Response
Colleges must have a well-defined and officially stated admissions policy. The policy must provide for an admissions committee, a majority of whom shall be full-time faculty members. The committee shall make recommendations regarding the students to be admitted to the professional curriculum upon consideration of applications of qualified candidates. Factors other than academic standards achievements must be considered for admission criteria.

The following information is required by AVMA-COE Standards (Attachment 8) under Section 12.7 for the evaluation of the admissions practices:

12.7.1. State the minimum requirements for admission.
12.7.2. Describe the student selection process, including measures to enhance diversity.
12.7.3. List factors other than academic achievement used as admission criteria.
12.7.4. Complete Table A.
12.7.5. Describe current plans for assessing the success of the selection process to meet the mission of the college.
12.7.6. Describe your policies and procedures for admitting transfer students who will receive a degree from your institution, and state the number of transfer students admitted per year for the last five years.

Colleges must demonstrate that they satisfy the AVMA’s admissions standards in their self-study by completing a detailed table and describing its policies and procedures. (Attachment 8) Standard 7.

The E-Recognition system, thus far, has not allowed the copying of the pertinent tables used in this evaluation. Tables A referred to above must, therefore, be given by specific reference in the standard. This table is given in Attachment 8, Section 12.7 on page 50, together with footnotes and definitions. The colleges' admissions policies and procedures are also reviewed by the site visit team. Appendix 1 – Site Visit Team Evaluation Rubric, standard 8 Faculty, pages 120 to 122. Colleges are expected to communicate their admissions criteria clearly to perspective students.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency documented the process required by (AVMA Standards Attachment 8) under Section 12.7 for the evaluation of the admissions practices. The standards require the institution to demonstrate that they satisfy the AVMA’s admissions standards in their self-study by completing a detailed table and describing its policies and procedures.


 
Staff Conclusion: Comprehensive response provided
 
Admissions and Recruiting, Question 3
 
Agency Narrative
See Above. (Attachment 8, Section 12.7)
 
Analyst Remarks to Narrative
The agency's documentation demonstrates that it has comprehensive admissions requirements set by the country in which the agency operates.
 
Facilities, Question 1
 
Agency Narrative
These requirements are addressed in AVMA-COE standards (Attachment 8), Sections 7.3, “Physical Facilities and Equipment” and 7.4, “Clinical Resources” as follows:


7.3. Standard 3, Physical Facilities and Equipment

All aspects of the physical facilities must provide an appropriate learning environment. Classrooms, teaching laboratories, teaching hospitals, which may include but are not limited to ambulatory/field services vehicles, seminar rooms, and other teaching spaces shall be clean, maintained in good repair, and adequate in number, size, and equipment for the instructional purposes intended and the number of students enrolled.

Administrative and faculty offices and research laboratories must be sufficient for the needs of the faculty and staff.

An accredited college must maintain an on-campus veterinary teaching hospital(s), or have formal affiliation with one or more off-campus veterinary hospitals used for teaching. Appropriate diagnostic and therapeutic service components, including but not limited to pharmacy, diagnostic imaging, diagnostic support services, isolation facilities, intensive/critical care, ambulatory/field service vehicles, and necropsy facilities must be provided to support the teaching hospital(s) or facilities with operational policies and procedures posted in appropriate places.

Facilities for the housing of animals used for teaching and research shall be sufficient in number, properly constructed, and maintained in a manner consistent with accepted animal welfare standards. Adequate teaching, laboratory, research, and clinical equipment must be available for examination, diagnosis, and treatment of all animals used by the college. Safety of personnel and animals must be assured.

7.4. Standard 4, Clinical Resources

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, in-hospital patients and outpatients including field service/ambulatory and herd health/production medicine programs are required to provide the necessary quantity and quality of clinical instruction.

It is essential that a diverse and sufficient number of surgical and medical patients be available during an on-campus clinical activity for the students’ clinical educational experience. Experience can include exposure to clinical education at off-campus sites, provided the college reviews these clinical experiences and educational outcomes. Further, such clinical experiences should occur in a setting that provides access to subject matter experts, 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 centers. The teaching hospital(s) shall provide nursing care and instruction in nursing procedures. A supervised field service and/or ambulatory program must be maintained in which students are offered multiple opportunities to obtain clinical experience under field conditions. Under all situations students must be active participants in the workup of the patient, including physical diagnosis and diagnostic problem oriented decision making.

Medical records must be comprehensive and maintained in an effective retrieval system to efficiently support the teaching, research, and service programs of the college.
 
Analyst Remarks to Narrative
The agency has demonstrated that it has accreditation standards that effectively address facilities, equipment, and supplies the agency's standards also require adequate facilities, equipment, and supplies to fulfill the veterinary schools' educational objectives for all aspects of the program.
 
Facilities, Question 2
 
Agency Narrative
The requirements for education at geographically separated sites was provided earlier in response to Part 2, (e) ”Curricula”, Question 4 based upon AVAM-COE Standards (Attachment 8), Section 8.1and 8.2 repeated here for ease of review.

8.1. Off-campus Clinical Education Sites for Colleges with Teaching Hospitals

a. An off-campus site where a specific educational objective is offered.

b. The site is externally located from the main campus and is (usually) not administratively associated with the degree granting institution.

c. Professional staff providing education might not be employees of the degree granting institution but may be receiving remuneration as a contractor, fee-for-service provider, etc. for time/effort devoted to the educational program.

d. The off-campus site must be reviewed to ensure that the educational program is being delivered appropriately.

e. There must be a written description of the educational objectives expected to be achieved at the site and a mechanism for assessing the success of the educational process, i.e. proof that educational objectives are being met.

f. These guidelines do not apply to off-campus educational experiences that are attended sporadically by individual students to augment their on-campus education.

8.2. COE Guidelines for Implementation of a Distributive Veterinary Clinical Education Model

a. The clinical sites selected by a college to serve in a distributive clinical educational model should receive appropriate financial remuneration per student from the college in order to help ensure that students receive on-site supervised clinical instruction, with formal written contract of expectations.

b. The college must prepare and distribute appropriate materials for clinical site educators that detail objectives of the program, expectations of the site coordinators, clinical site educator training
materials, instructions concerning the format the college wants used to evaluate student performance and provide feedback to students on progress/deficiencies associated with site experience.

c. Additionally the college must provide to the students, and clinical site educators alike, the expectations of the college for student safety and security while the student is on site.

d. Distributed clinical sites must be selected on the basis of specific criteria and identified for instruction in precise disciplines (defined by the college) such as, but not limited to: Food Animal/Equine/Small Animal Medicine; Food Animal/Equine/Small Animal Surgery or Food Animal or Equine or Small Animal Medicine and Surgery; Dermatology, Imaging (radiology, etc.), Neurology, Cardiology, Critical Care Emergency Medicine, etc.

e. For distributed clinical sites the college must take steps to ensure that the educational objectives and anticipated outcomes are thoroughly promulgated and understood by students and clinical site coordinators alike.

f. The college must designate to the COE what clinical sites are considered as primary instructional sites as defined by Standard 9 (c) and these will be considered by COE as core instructional sites. These sites must be in compliance with AVMA-COE Standards.

g. The college must document/assess that students and educators clearly understand how evaluation and grading practices will be conducted at each clinical site including clinical competencies.

h. Veterinarians must be licensed and technicians should be certified, licensed, or registered as appropriate to that jurisdiction.

i. The college must document that students are fully informed concerning their ability to report any and all safety, physical, and emotional concerns to the college.

j. The college must put in place a system to regularly monitor/supervise the instructional activities at each clinical site and report this system with any subsequent changes and outcomes to the COE.

k. Each clinical site educator must abide by a process devised by the college to provide a written evaluation of the performance of each student.

l. Students must provide the college with an evaluation of each site (after the respective rotation) including an evaluation of teaching at the site and the student’s opportunity to perform hands-on procedures at the site. The college must summarize this information for the COE.

m. The COE may inspect clinical sites at any time students are present; these inspections, including travel and per diem costs, will be at the expense of the college.

n. The college must put in place a system to measure and document clinical competencies outcomes at clinical sites as specified by the COE (see Section 12.11.2) to assess clinical sites.
 
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.
 
Facilities, Question 3
 
Agency Narrative
The response to this question and the question immediately below are provided in the response immediately above
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements.
 
Agency Response
The AVMA requires colleges to identify clinical sites to the AVMA. The AVMA also requires that colleges have a formal written contract in place with any site where students receive supervised clinical instruction. The contract must outline the colleges’ expectations with respect to the instruction provided and remuneration per student. In addition, all core instructional sites must be in compliance with all applicable AVMA standards.

The requirements for education at geographically separated sites are provided in AVMA-COE Standards (Attachment 8), Section 8.1and 8.2

8.1. Off-campus Clinical Education Sites for Colleges with Teaching Hospitals

a. An off-campus clinical education site where a specific educational objective is offered.
b. The site is externally located from the main campus and is (usually) not administratively associated with the degree granting institution.
c. Professional staff providing education might not be employees of the degree granting institution but may be receiving remuneration as a contractor, fee-for-service provider, etc. for time/effort devoted to the educational program.
d. The off-campus site must be reviewed to ensure that the educational program is being delivered appropriately.
e. There must be a written description of the educational objectives expected to be achieved at the site and a mechanism for assessing the success of the educational process, i.e. proof that educational objectives are being met.
f. These guidelines do not apply to off-campus educational experiences that are attended sporadically by individual students to augment their on-campus education.

8.2. COE Guidelines for Implementation of a Distributive Veterinary Clinical Education Model

a. The clinical sites selected by a college to serve in a distributive clinical educational model should receive appropriate financial remuneration per student
from the college in order to help ensure that students receive on-site supervised clinical instruction, with formal written contract of expectations.
b. The college must prepare and distribute appropriate materials for clinical site educators that detail objectives of the program, expectations of the site
coordinators, clinical site educator training materials, instructions concerning the format the college wants used to evaluate student performance and provide feedback to students on progress/deficiencies associated with site experience.
c. Additionally the college must provide to the students, and clinical site educators alike, the expectations of the college for student safety and security while the student is on site.
d. Distributed clinical sites must be selected on the basis of specific criteria andidentified for instruction in precise disciplines (defined by the college) such as, but not limited to: Food Animal/Equine/Small Animal Medicine; Food
Animal/Equine/Small Animal Surgery or Food Animal or Equine or Small Animal Medicine and Surgery; Dermatology, Imaging (radiology, etc.), Neurology, Cardiology, Critical Care Emergency Medicine, etc.
e. For distributed clinical sites the college must take steps to ensure that the educational objectives and anticipated outcomes are thoroughly promulgated and understood by students and clinical site coordinators alike.
f. The college must designate to the COE what clinical sites are considered as primary instructional sites as defined by Standard 9 (c) and these will be considered by COE as core instructional sites. These sites must be in compliance with AVMA-COE Standards.
g. The college must document/assess that students and educators clearly understand how evaluation and grading practices will be conducted at each clinical site including clinical competencies.
h. Veterinarians must be licensed and technicians should be certified, licensed, or registered as appropriate to that jurisdiction.
i. The college must document that students are fully informed concerning their ability to report any and all safety, physical, and emotional concerns to the college.
j. The college must put in place a system to regularly monitor/supervise the instructional activities at each clinical site and report this system with any subsequent changes and outcomes to the COE.
k. Each clinical site educator must abide by a process devised by the college to provide a written evaluation of the performance of each student.
l. Students must provide the college with an evaluation of each site (after the respective rotation) including an evaluation of teaching at the site and the student’s opportunity to perform hands-on procedures at the site. The college must summarize this information for the COE.
m. The COE may inspect clinical sites at any time students are present; these inspections, including travel and per diem costs, will be at the expense of the college.
n. The college must put in place a system to measure and document clinical competencies outcomes at clinical sites as specified by the COE (see Section 12.11.2) to assess clinical sites.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency provided a detailed narrative documenting the requirements of this section and the evaluation process for geographically separated sites. ( AVMA Standards (Attachment 8), Section 8.1 and 8.2)

 
Staff Conclusion: Comprehensive response provided
 
Student Complaints
 
Agency Narrative
These procedures are provided in AVMA-COE Standards (Attachment 8), Section 7.6 “Standard 6, Students”, last paragraph, as follows:
Each accredited college must provide a mechanism for students, anonymously if they wish, to offer suggestions, comments, and complaints regarding compliance of the college with the Standards of Accreditation. These materials shall be made available to the Council annually.
Student complaints are also addressed in AVMA-COE Standard (Attachment 8) Section 5.5.2,”Complaints Addressed at a College and its Accreditation Status” as follows:

5.5.2. Complaints Directed at a College and its Accreditation Status

Students, faculty, constituent veterinary medical associations, veterinary state boards, and other interested parties may submit an appropriate signed complaint to the COE regarding an accredited veterinary or developing college which has made application for accreditation. The COE will take every responsible precaution to protect the identity of the complainant from being revealed to the college; however, the Council cannot guarantee confidentiality of the complainant.

An appropriate complaint is defined as one alleging: 1) an accredited or pending college program is not in compliance with the Standards of Accreditation and 2) the practice, condition, or situation of a continuing or pervasive nature, as opposed to an unfair or arbitrary act of an individual or an act isolated in nature. In accord with the role of COE, matters will be addressed in an investigative manner rather than as a mediator. Only written signed complaints will be considered by the COE. The COE strongly encourages all parties to attempt resolution of complaints before they are brought to the Council. If the complaint includes issues already being addressed by other entities, the Council will take no action on the complaint until such adjudication or litigation is concluded.

Any written complaint by a third party (individual such as faculty, staff, public, or organization) concerning the quality of ethical conduct of an accredited college of veterinary medicine will be received by staff, who will acknowledge receipt of the complaint within seven (7) working days. AVMA staff will make a preliminary investigation of the initial complaint and report to the COE Executive Committee within 30 days. As part of this review, the staff will determine whether the complaint is appropriate for review by the Council, that the complaint is related to items which have specific impact on the educational process and/or the Standards. The Council is not the appropriate body to review allegations of malpractice.

After review of the complaint and the report of the staff investigation, the Executive Committee will report its findings to the Council and the complainant within 30 days from receipt of the staff report. If, in the judgment of the Executive Committee, the complaint appears to be of sufficient substance to affect the accreditation status of the college, it will be investigated further by the Council. Upon completion of the investigation, the Council will take appropriate action to bring the accreditation status of the college into conformity with the established classifications. If an investigation of the complaint by the Council is deemed necessary, it should be completed within a period of not more than six (6) months after receiving the report from the Executive Committee.

If an adverse decision is made concerning the accreditation classification of a college, the college shall have the right of appeal (see Section 10.12, Appeals of Adverse Outcomes). In any case, the college complained against will be informed of the nature and source of the complaint and the resultant action, if any, contemplated by the Council before such action is taken. The complainant will be notified in writing of the results of the investigation and any action taken.
 
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

 
Part 3: Accreditation/Approval Processes and Procedures
Accreditation Process and Procedures, Question 1
 
Agency Narrative
See response at Attachment 13
 
Analyst Remarks to Narrative
The agency needs to provide a narrative that includes specific documentation for each criteria which verifies and or documents compliance with the requirement and demonstrates how it meets the requirements
 
Agency Response
The requirements regarding the individuals who evaluate schools, develop standards and make accreditation decisions are provided in the AVMA-COE Standards (Attachment 8), Sections 18.1, 19.1, 19.2, 20, 17.1, 17.2, 17.3, 17.4, 17.5, 17.6 and 17.7.

18.1. Site Visit Team
Site visit teams are selected to represent educators, practitioners, and others (including public members) in the proportion necessary to evaluate a college and its programs.

• US – Accreditation site teams are composed of at least five trained site visitors, at least four of whom shall be trained site visitors selected by the COE (one of whom will serve as chair) and one trained site visitor selected by the CVMA. In addition the team will be accompanied by one or two current COE member(s) (non-voting observers), one state veterinary medical association (VMA) observer (optional at state VMA discretion and expense, non-voting), and one AVMA staff member (non-voting).
• Canada – Accreditation site teams are composed of at least five trained site visitors, at least two of whom shall be trained site visitors (one of whom will serve as chair) selected by the COE and three trained site visitors selected by the CVMA. In addition the team will be accompanied by one or two current COE member(s) (non-voting observers), one provincial observer (optional at the discretion and expense of the province, non-voting), and one AVMA staff member (non-voting).
• Foreign – Accreditation site teams are composed of six trained site visitors; three trained site visitors (one of whom shall serve as chair) selected by the COE, one trained site visitor selected by the CVMA, and two members from the country wherein the college is located, with the exception of joint site visits where the make-up of the team shall be decided by the accrediting bodies. In addition the team will be accompanied by one or two current COE member(s) (non-voting observers), and one AVMA staff member (non-voting).
• Advisory/Consultative site team – These site teams are composed of at least three trained site visitors and one AVMA staff member (non-voting).

COE site visitors will be veterinarians or former COE public members who have undergone training to conduct site visits. Such training shall include review of an on-line training module and a two and one half-day initial training session and annual refresher training online. Site visitors without previous site team experience will serve as an observer on their first site visit. Training must be updated annually to continue to serve as a site visitor. Current
COE members may not serve as voting COE site visitors.

Site visitors will serve six-year, staggered terms. A call for applications and nominations will be distributed broadly. The COE will review the credentials of the applicants and nominees and select site visitors. A pool of no less than 30 will be maintained.

Observers may not vote at the site visit. Current COE members serving as observers may not vote on the accreditation status of the institution visited.

Site visitors are identified and assigned to each team by the chair of the Evaluation Committee. These individuals participate as volunteers and are not eligible for honorariums, but may be reimbursed, when necessary, for transportation, food, lodging, and incidental expenses. Public members may be included on site visits, but because of their limited number, are not included in every visit. However, public members shall fulfill all the duties of a team member and have the right to vote.

An effort will be made to balance the areas of expertise on the site visit team. Each site visit team includes a representative of the CVMA appointed and supported by that organization. No member is assigned to a site visit team until they have completed training and orientation.

An AVMA staff member will accompany each site team and assist in coordinating activities. Staff will consider how each of the standard requirements is being met by the college and note any points not covered in the self-evaluation report. If major deficiencies are found in the material presented, staff is requested to ask the college for supplemental material.

19.1. New Member Training

The Council provides substantive training and mentoring for new Council members, who must be trained prior to participation as an evaluation committee member. This training allows members to assume increased responsibility as their knowledge and understanding of the policies and procedures of the Council is demonstrated. The Council’s Committee on Evaluation Chair assigns site visit teams in accordance with the competence and readiness of site visitors appointed to serve.

Newly-elected COE members receive an orientation manual, the current COE policies and procedures manual, an instructional video on interpretation of the standards of accreditation, and a book published by CHEA on the history and future of higher education accreditation in the US. New members attend the annual COE site visitor training and receive two hours of formal training the evening before their first COE meeting. The COE Chair assigns a senior COE member as a mentor to each incoming COE member; mentors also attend the evening training session. All training focuses on member responsibilities and COE practices.

The Chair and COE mentors review each standard, citing examples of activities conducted to ascertain compliance with the standards at the colleges, and outcomes related to deficiency in meeting the standards. General information regarding such matters as confidentiality, non-confrontational conduct of the visit, time commitment for the visit, and expected level of involvement are also discussed.

During the first COE meeting attended by new members (fall), a minimum of two hours are devoted to continuing education of all COE members. The topic is selected by the incoming Council Chair.

19.2. On-site Training

Site team members are required to arrive at the college one-half day early. The site team chair and COE staff provide refresher training based on initial site team training and the instructional video in the interpretation of standards, which are provided to novice members at least two weeks in advance of the site visit. Further, prior to each site visit, the chair of the site visit team meets with all team members in executive session, to outline the plan for the visit, describe situations arising in the self-study which may require special attention, and reemphasize the specific assignments of each team member. This orientation session must be attended by all site team members.

We have provided as much information in response to this question as the online application interface will allow based on its limitations with respect to answer length. Additional important information responsive to this question appears in (Attachment 8), sections 20,”Training and Orientation Materials”. And with regard to the development of standards, please see Sections 17.1, “Development of Accreditation Standards, 17.2, “Review of Established Standards”, 17.3, “Adding or Revising a Standard”, 17.4, “Assessment of Revised standards”, 17.5, “Application of Standards”, 17.6, “Ongoing Review of Standards” and 17.7, “Annual Review of Standards.

Please see Attachment 15 for GNAB`s responses to the last five questions in Part 2 and Part 3.
 
Analyst Remarks to Response
In response to the staff draft analysis, the agency has provided detailed narrative documenting the the agency's requirements for the use of competent and knowledgeable individuals, who are qualified by experience and training in the basic or clinical sciences, for on-site evaluations of veterinary schools, policy-making, and decision-making. ( AVMA Standards (Attachment 8), Sections 18.1, 19.1, 19.2, 20, 17.1, 17.2, 17.3, 17.4, 17.5, 17.6 and 17.7.)
 
Staff Conclusion: Comprehensive response provided
 
Accreditation Process and Procedures, Question 2
 
Agency Narrative
The requirements regarding controls against conflicts of interest by those individuals involved in the accreditation process addressed AVMA-COE Standards (Attachment 8), Sections 18.2, “Conflict of Interest/Confidentiality Statement” and 21.1, “Appendix A – “Conflict of Interest/Confidentiality Statement” repeated below:

8.1. Conflict of Interest / Confidentiality Statements
Each site team member is required to sign a Conflict of Interest/Confidentiality Statement (see Section 21.1, Appendix A).


AVMA COUNCIL ON EDUCATION CONFLICT OF INTEREST STATEMENT
AVMA Staff Member

Although AVMA staff members do not participate directly in decisions regarding accreditation of colleges, they are in a position to influence the outcomes of the process. On the other hand, staff provides continuity to the evaluation process.

No AVMA Staff Member will serve on a site visit team who:
1. Has graduated during the past five years from a college being evaluated.
2. Has been employed during the past five years by the college being evaluated.
3. Has close personal or familial relationships with key personnel in the college being evaluated.


AVMA COUNCIL ON EDUCATION CONFIDENTIALITY AGREEMENT
AVMA Staff Member

In accordance with AVMA policy, all information related to the Council on Education (COE) accreditation of a veterinary medical college is strictly confidential. This includes but is not limited to reports of evaluation, letters, self-evaluation and accreditation materials, interim/annual reports, correspondence, and the content of any discussion related to the veterinary medical college or its accreditation. All requests for information related to a specific institution and/or veterinary medical college must be referred to AVMA staff, or the respective institution.

Freedom of Information Acts which may be applicable in a given state, province, or country do not apply to AVMA confidential information related to the accreditation of veterinary medical colleges. It is our understanding that information requested through such acts may be obtained through due process from the respective institution or state/province/country office.

By signing your name below you are agreeing to abide by AVMA policy with respect to the accreditation of veterinary medical colleges.

I have read the conflict of interest policy and confidentiality agreement for AVMA Staff participating as a COE site visit team member and by signing this document confirm no conflict exists for me to serve as a site team member in evaluating the ____________________.




(Staff Member Name) Signature_________________ Date:_____________________
 
Analyst Remarks to Narrative
The agency has provided its policies and documentation 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.

 
Accreditation Process and Procedures, Question 3
 
Agency Narrative
The AVMA-COE, through consistent application of the AVMA-COE Standards, provided as Attachment 8, and applied to all site visits and visitors, is committed to consistency in the application of its standards. Section 16 of the Standards addresses this issue directly:

16. STANDARD OPERATING PROCEDURES

16.1. Consistency of Application
The COE is committed to consistency in application of the 11 Standards used as a basis for veterinary college accreditation. Because of turnover in COE membership and the potential for variation in individual interpretations of the standards, the Council provides several means to ensure a clear understanding of member responsibility and interpretation of documentation in making accreditation decisions.

16.2. Database Retrieval
Staff of the Division of Education and Research, along with the Chair of the COE, maintain a database on interpretation of site visit results and outcomes. The database uses information from the past ten years of accreditation history and will be evolutionary as new sites are visited and data entered. Use of the database ensures that similar situations and concerns are subject to analogous interpretation. Factual information from the database is used in evaluating similar situations (standard findings) at differing locations (colleges). Further, this activity ensures consistency of application of policy in making accreditation decisions.

16.3. Training
Orientation and annual training for COE members and initial and annual training for site team members is conducted using in-person training sessions, videotapes, a training manual, and online presentations. The training ensures a common understanding of standard interpretation and site visit conduct. AVMA staff accompanies all site teams to provide reference and consistency.

16.4. Records
The Council maintains complete records of each veterinary medical college or school indefinitely. The records are confidential and include reports of evaluation, annual interim reports, self-study and reaccreditation reports, and all related correspondence. These files are available for inspection by representatives of the Department of Education.

16.5. Sharing Information
The Council shares information related to the accreditation or preaccreditation status of a veterinary medical program, and/or any adverse action taken, with appropriate accrediting agencies and state agencies.
 
Analyst Remarks to Narrative
The agency provided its policies, procedures and guidance to ensure the consistent application of standards.