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U.S. Department of Education

 

American Veterinary Medical Association, Council on Education

 
Prepared April 2015
 
Background
 
The American Veterinary Medical Association (AVMA) was formed in 1863 to recognize the veterinary medical profession in the United States. It began accrediting schools of veterinary medicine in 1906 through its Committee on Intelligence and Education. In 1946, the AVMA was reorganized, and the Council on Education (COE) replaced the Committee on Intelligence and Education.

The COE of the AVMA is a programmatic accrediting agency that is currently recognized by the Secretary of Education for its domestic accrediting activities. The COE of the AVMA currently accredits 28 schools of veterinary medicine located in regionally accredited universities.

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 agency`s foreign accreditation activities encompass 19 programs in 11 countries.The agency has submitted a petition for review as a result of the new Department of Education regulations..



 
Summary of Findings
 
Based on its review of the materials submitted by the agency, Department staff concludes that the requested information has been provided, and has been found to be satisfactory. Therefore, the agency can be determined to be acceptable to the Secretary of Education for the purpose of evaluating veterinary programs for Federal purposes. (See CFR §600.56(a)(4) for the guiding regulation). The agency will receive an official notification letter from the Department which will also explain the length of the acceptability determination.
 
Staff Analysis
 
PART 1: Entity Responsible for the Accreditation/Approval of Medical Schools
 
Accreditation System and Authority, Question 1
 
Agency Narrative
The American Veterinary Medical Association (AVMA) Council on Education (COE) is the only accrediting agency for the accreditation of veterinary medical colleges in Canada. The Canadian Veterinary Medical Association (CVMA) National Examining Board (NEB) is responsible for issuing a Certificate of Qualification (Exhibit 1-VetPractice Acts_Canada Acts; Exhibit 2-NEB Applicants Info Section 1) which is the credential required for registration and the ability to practice veterinary medicine in Canada. The CVMA NEB selects a representative to the Council who is a voting member (Exhibit 3-COE 2014-2015 Roster).

For international colleges outside of Canada, accreditation by the AVMA COE is limited to established veterinary medical colleges. Prior to the accreditation of a veterinary medical college in a foreign country the AVMA COE must have a signed agreement with the licensing body of that country which recognizes that graduates of US and Canadian AVMA COE accredited colleges have met the same educational standards as graduates of the AVMA COE accredited foreign college. This agreement must also have a provision that the foreign country confers licenses to graduates of AVMA COE accredited veterinary colleges that are identical to those conferred on graduates of that country’s AVMA COE accredited veterinary college, by a licensing process no more rigorous than that required of graduates of that country’s AVMA COE accredited veterinary college (Exhibit 4-RCVS Agreement; Exhibit 5- AVBC Agreement; Exhibit 6- Netherlands Agreement; Exhibit 7- Mexico Agreement; Exhibit 8- Grenada Agreement; Exhibit 9-St Christopher-Nevis Agreement; Exhibit 10- Ireland Agreement; Exhibit 12- France Agreement).
 
Analyst Remarks to Narrative
The agency has attached nine memoranda from foreign veterinary boards which document acceptance of AVMA accreditation as meeting equivalent educational requirements for licensure in the respective country. Such memoranda does not specifically confer the authority to the agency as the entity responsible for evaluating the quality of veterinary education in the respective country, but rather, recognizes graduation from an AVMA-accredited school as meeting educational equivalency for licensure.
 
Accreditation System and Authority, Question 2
 
Agency Narrative
The CVMA NEB participates in the AVMA COE accreditation processes through representation on the COE and through participation of COE site visitor who are appointed by the CVMA NEB (Exhibit 2-NEB Applicants Info Section 1). All comprehensive visits at US veterinary colleges have one COE trained site visitor that is appointed by the CVMA NEB. Canadian site visit teams consist of two AVMA COE site visitors and three CVMA COE site visitors. In addition, an AVMA staff member may accompany the team as staff support and one or two COE members and a representative from the province (optional at the discretion of the province) where the college is located may accompany the site team as non-voting observers. (Exhibit 12--P&P Section 11-3)

For all international site visits, with the exception of Canadian veterinary colleges, the geographically closest veterinary licensing body or association is asked to appoint two representatives to the site team. The representatives must have no conflict of interest with the college. No conflict of interest is verified by having the appointed site team members sign the AVMA Conflict of Interest Statement for Site Team Members (Exhibit 13-P&P Section 6-4-4; Exhibit 14-Conflict of Interest Statement). The purpose of these representatives is to assure knowledge of veterinary practice and the regulatory environment in the country being visited.

The AVMA COE has been working with accrediting and licensing agencies, the Royal College of Veterinary Surgeons (United Kingdom) and the Australasian Veterinary Boards Council (Australia and New Zealand), since 2002 through joint meetings that include discussions of best practices in accreditation, mutual understanding of each agencies accreditation practices, and the initiation of joint accreditation visits for veterinary medical colleges accredited by all three agencies. The COE reviews the report submitted by the site team and makes its accreditation decision independently based on AVMA COE Standards of Accreditation. The last meeting of the International Accreditors Working Group was held in London in January 2014. (Exhibit 15-IAWG 2014 Minutes).
 
Analyst Remarks to Narrative
The agency has written policies and procedures for the conduct of its accreditation visits to foreign schools that include representatives from licensing bodies in the respective country. The agency has also been conducting formal meetings with accrediting and licensing agencies to discuss best practices in veterinary education accreditation. Aside from the participation of licensing boards on the agency's site visit team, the agency acts independently from the country's own oversight of veterinary education.
 
Part 2: Accreditation/Approval Standards
 
Mission and Objectives
 
Agency Narrative
The Council will only accredit colleges that grant the DVM or equivalent degree. Each college must provide a mission statement that reflects its educational goals as well as its service and research goals. The mission statement must speak to the commitment of delivering a quality education that leads to the DVM ore equivalent degree (Exhibit 16- P&P Section 12-1 [12.1.1]).

The Council evaluates each college seeking accreditation through the use of a self-study, site visit, and evaluation of the college as it relates to its mission (Exhibit 17- Self-Study X, Standard 1, Exhibit 18-X Report of Evaluation).

Standard 11, Outcomes Assessment requires colleges to demonstrate that new graduates have the knowledge, skills, and values to provide entry-level veterinary health care, independently, at the time of graduation (Exhibit 19-P&P Section 12-11 [12.11.1]).

Each college is required to provide the Council with proposed changes to its mission statement or objectives prior to adoption to allow for Council review and approval (Exhibit 20-P&P Section 9-1 and 9-2).
 
Analyst Remarks to Narrative
The agency demonstrates that it has a standard that requires veterinary programs to demonstrate that graduates have the knowledge, skills, and values to provide entry-level veterinary health care. The agency has provided a sample self-study and evaluation report to demonstrate the application of its mission and objectives standard.
 
Governance
 
Agency Narrative
Standard 1, Organization. Within the context of its mission, each college is required to part of an institution of higher learning accredited by an organization recognized for that purpose by its country’s government (Exhibit 21-P&P Section 7). The college must provide the organization responsible for this accreditation (Exhibit 17-Self-Study X [Standard 1]; Exhibit 18-Report of Evaluation [Standard 1]). Each college is monitored for continued compliance with the Organization Standard through required annual interim reports (Exhibit 22-Interim Report_redacted).
 
Analyst Remarks to Narrative
The agency has a standard requiring programs to be part of an institution of higher learning accredited by an organization recognized for that purpose by its country's government. The agency has provided a sample self study and evaluation report that demonstrates it evaluates programs against this standard.
 
Administrative and Fiscal Capacity, Question 1
 
Agency Narrative
Standard 1, Organization, and Standard 2, Finances. Within the context of its mission, each college must have a reporting line to the institution administration that allows the college to support its program and to report its accomplishments with the same considerations as other colleges with in the institution. The college must be a major academic administrative unit of the institution. The dean of the college and the hospital director must be veterinarians to ensure that the profession is properly represented in the institution and the community. There must be sufficient administrative staff to adequately operate the educational program of the college. The college must provide a flow chart of the organizational design of the college, listing the names, title, academic credentials, and assignment of the college administrators (Exhibit 16-P&P Section 12-1; Exhibit 17- Self-Study X [Standard 1 and Appendix 1]; Exhibit 18- Report of Evaluation_redacted [Standard 1])
 
Analyst Remarks to Narrative
The agency has standards outlining requirements for the adminstrative and fiscal capacity of accredited programs. The agency has provided a sample self study and evaluation report that demonstrates it evaluates programs against these standards.
 
Administrative and Fiscal Capacity, Question 2
 
Agency Narrative
The resources of the college must be sufficient to accomplish the educational mission as related to student enrollment (Exhibit 23- P&P Section 12-2) Colleges are required to complete tables that provide a detailed accounting of revenues and expenditures in various categories over the previous five years and must provide a comprehensive trend analysis of each category. Compliance with Standard 2 is judged based on the adequacy and projected sustainability of resources to deliver the professional educational program, retain faculty, and provide teaching and service resources (Exhibit 23- P&P Section 12-2; Exhibit 17- Self-Study X [Standard 2]; Exhibit 18- Report of Evaluation_redacted [Standard 2]). Each college is monitored for continued compliance with the Organization and Finance Standards through required annual interim reports (Exhibit 22-Interim Report_redacted).
 
Analyst Remarks to Narrative
The agency's fiscal capacity standard requires that finances are "adequate" to sustain the educational programs and mission of the college, with subparts that require analysis of revenues and expenditures for the past five years. The agency has provided a sample evaluation report where concerns regarding fiscal capacity were flagged for further interim monitoring.
 
Faculty, Question 1
 
Agency Narrative
Standard 8, Faculty. In the context of its mission, each college must have adequate faculty numbers with appropriate qualifications to deliver the DVM program. The adequacy of the faculty is based on site team observation and interviews with faculty, students, and staff, taking into account student enrollment in the professional program (Exhibit 17 Self-Study X, [Standard 8 and Appendix 8]; Exhibit 18-Report of Evaluation_redacted [Standard 8]).
 
Analyst Remarks to Narrative
The agency has faculty standards that require faculty to be appropriately qualified and sufficient in number. The agency has provided a sample evaluation report that demonstrates it evaluates programs under these standards.
 
Faculty, Question 2
 
Agency Narrative
Standard 8, Faculty. In the context of its mission, each college must have faculty with appropriate qualifications to deliver the DVM program. Data are collected on faculty qualifications, vacancies, employment stability, promotion and tenure regulations, and faculty support in relation to teaching and research missions. Faculty must have opportunities for professional growth and security in employment (Exhibit 24-P&P Section 12-8). Faculty are interviewed regarding faculty peer review of teaching effectiveness and student evaluation of teaching faculty. Each college is monitored for continued compliance with the Organization and Finance Standards through required annual interim reports (Exhibit 22- Interim Report_redacted).

As stated in Standard 9, Curriculum (Exhibit 25-P&P Section 7-9) the curriculum of the veterinary medical program is considered be the purview of the faculty of each college, however, the curriculum must be managed centrally based upon the mission and resources of the college. The curriculum as a whole must be regularly reviewed and managed by a college curriculum committee. The majority of the members of the curriculum committee must be full-time faculty. Curricular evaluation must include the assessment of instructional quality and effectiveness.
 
Analyst Remarks to Narrative
The agency has a standard that requires faculty to be appropriately qualified to deliver the DVM program. The agency has provided documentation of its evaluation of a program under this standard.
 
Faculty, Question 3
 
Agency Narrative
Requirements for clinical site educators are in place for those colleges which use the distributive veterinary clinical education model (Exhibit 31-P&P Section 8). Clinical site educators do not have to be members of the faculty. All clinical sites are required to have a written contract of expectations and provide materials for the clinical site educators that include the objectives of the program, training materials for the clinical site educators, instruction on the method of format to provide feedback to students on progress associated with the site experience, and each clinical site educator must provide a written evaluation of each student’s performance. Students and clinical site educators must be aware of the expectations for safety and security and that both students and clinical site educators understand the educational objectives and expected clinical outcomes. A process must be in place to supervise the instructional activities at each clinical site. At the time of the site visit, the clinical site educator must be present to interact with site visitors (Exhibit 26-P&P Section 20). Site visitors are provided guidance in the Distributive Model: Off-site Inspection Guide (Exhibit 47-P&P Section 21-4) on the information that should be gathered from the clinical site educators.
 
Analyst Remarks to Narrative
The agency employs a distributive veterinary clinical education model which does not require clinical site educators to be faculty. However, the agency has guidelines for its clinical education sites that clinical sites adhere to contractual agreements with the programs and that clinical site educators provide written evaluations of student performance.
 
Curricula, Question 1
 
Agency Narrative
Standard 9, Curriculum, The curriculum evaluated as part of the accreditation process is specific for the DVM or equivalent degree program. Within the context of the mission of the college and the resources available the curriculum must be managed centrally. The curriculum is the purview of each college’s faculty and a college curriculum committee, of which a majority are full-time faculty, must regularly review the curriculum as a whole and guide the curriculum. The process of curriculum management must be such that revisions in the curriculum to meet developing issues and new advancements in veterinary medicine can be addressed in a timely fashion. The curriculum must include a strong basic science foundation along with instruction in critical thinking and clinical skills necessary for a new graduate to practice entry-level veterinary medicine independently (Exhibit 25-P&P Section 7-9). The site teams and the Council will evaluate the curriculum in such areas as patient care and management, diagnostic methods and interpretation, information management, epidemiology and zoonosis, professional development, and clinical techniques and skills (Exhibit 25-P&P Section 7-9, Exhibit 17- Self-Study X [Standard 9 and Appendix 9], Exhibit 18-Report of Evaluation_redacted [Standard 9]). Colleges must update the Council on any changes to the curriculum through annual interim reports (Exhibit 22- Interim Report_redacted).

There must be a mechanism for ongoing assessment of the curriculum and its components to assure students are gaining and using contemporary knowledge and skills (Exhibit 27-Section 12-9). This Standard works in step with Standard 11, Outcomes Assessment to ensure ongoing curricular review is based on based on the collection, analysis, and use of appropriate outcomes assessments to drive continuous curricular improvement.

The Council also requires colleges of veterinary medicine to have substantial research activities. This requirement is made because the Council feels that a rigorous research program using capable and talented investigators creates a rich learning environment for the students and exposes them to professional activities other than clinical practice as possible career choices within the profession. Further, the Council feels that graduates should have an appreciation for research as it impacts their professional activities and, therefore, enforces the standard to reach those goals (Exhibit 28-P&P Sect 12-10).

Also impacting the curriculum are Standard 5, Information Resources, and Standard 4, Clinical Resources. The Council is aware that access to information is changing (driven by the internet) and that traditional libraries are not as extensive as in the past. However, the Council wants to ensure that adequate resources are available, especially those providing teaching materials for faculty and learning materials for students (Exhibit 29-P&P Section 12-5). Clinical resources are necessary for preclinical and clinical education. The Council follows trends in healthy animal and patient numbers to ensure that the DVM students will have these resources in the educational program. As with libraries, clinical settings for veterinary education are changing to include private practice segments and the Council monitors faculty oversight and student performance carefully in these non-college owned facilities (Exhibit 30-P&P Section 12-4; Exhibit 31-Section 8).
 
Analyst Remarks to Narrative
The agency has requirements for the curriculum to be appropriate for the DVM degree and for new graduates to practice entry-level veterinary medicine independently. Program faculty and the college curriculum committee are responsible for regularly reviewing the curriculum.
 
Curricula, Question 2
 
Agency Narrative
As stated in the Standard (Exhibit 25-P&P Section 7-9), the curriculum must extend for a period of four academic years with a minimum of one academic year of hands-on clinical education.
 
Analyst Remarks to Narrative
The agency has a standard that requires the DVM curriculum to extend for a period of four academic years with one academic year of clinical education.
 
Curricula, Question 3
 
Agency Narrative
Standard 9, Curriculum requires that the curriculum include opportunities to gain an understanding of professional ethics (Exhibit 25-P&P Section 7-9). This requirement is also impacted by Standard 5, Information Resources. The Council believes that it is essential that appropriate information resources, including resources relating to professional ethics, are readily available to faculty and students as instructional resources.
 
Analyst Remarks to Narrative
The agency has curriculum requirements to include opportunities to gain an understanding of professional ethics.
 
Curricula, Question 4
 
Agency Narrative
The Curriculum standard is in line with Standard 11, Outcomes Assessment, as colleges must develop relevant measures and provide evidence that graduates have achieved an entry-level competence in client communications and ethical conduct. Colleges also use employer surveys to analyze the impact of the curriculum on the development of ethical conduct (Exhibit 32 P&P Section 7-11, Exhibit 27-P&P Section 12-9 [item 6], Exhibit 17 Self-Study X [Standard 9 and 11 and Appendix 9 and 11]) Site teams and ultimately the Council assess the curriculum to assure inclusion of ethical principles within the curriculum (Exhibit 18-X Report of Evaluation_redacted [Standard 9 and 11]).
 
Analyst Remarks to Narrative
The agency employs employee surveys as one way in measuring student performance and success in the instruction of ethics. Programs are further required to employ relevant measures to demonstrate students achieve entry-level competence in communication and ethical conduct.
 
Curricula, Question 5
 
Agency Narrative
Standard 3, Physical Facilities requires that along with safety of personnel, animal safety must be assured. All facilities housing animals for teaching and research be appropriate for the number and species of animals; be constructed and maintained consistent with animal welfare standards. (Exhibit 33-P&P Section 7-3) The college must document facility management plans (Exhibit 34- P&P Section 12-3 [item 3], Exhibit 17-Self-Study X [Standard 3 and Appendix 3]) and the site team and ultimately the Council will review the mechanisms in place to assure that animals are cared for humanely (Exhibit 18- X Report of Evaluation_redacted [Standard 3, item 3.7, 3.8-3.9])
 
Analyst Remarks to Narrative
The agency has standards for the safety of personnel and animals, including requirements for the appropriateness of the facilities housing animals and to ensure that such facilities are consistent with animal welfare standards.
 
Curricula, Question 6
 
Agency Narrative
Standard 9, Curriculum requires that the curriculum must have, at minimum, one academic year of hands-on clinical education (Exhibit 25-P&P Section 7-9; Exhibit17- Self-study X [Standard 9 and Appendix 9]; Exhibit 18-X Report of Evaluation_redacted [Standard 9]). The COE requires that students are assessed by faculty and evidence provided that graduates have achieved competence evidence that its graduates have gained competence through in nine broad clinical areas, such as, basic surgery skills, case management, client communication, etc. (Exhibit 25-P&P Section 7-9). As stated in Standard 6, Students, colleges should establish postgraduate educational opportunities. These opportunities may be as internships, residencies, post-doctoral degrees, or via dual degree Masters and PhD programs (Exhibit 35-P&P Section 7-6; Exhibit 17- Self-study X [Standard 6 and Appendix 6]; Exhibit 18-X Report of Evaluation_redacted [Standard 6]). Professional student interactions with interns, residents, and graduate students enrich the learning environment of the students in the professional program.
 
Analyst Remarks to Narrative
The agency's curriculum standard requires a minimum of one academic year of hands-on clinical education. The agency's standards further require opportunities for post-graduate educational opportunities.
 
Student Achievement, Question 1
 
Agency Narrative
Standard 11, Outcomes Assessment. In context with its mission, each college is required to document student learning outcomes (achievement) and each college must collect, analyze, and use information regarding student outcomes for program improvement (Exhibit 19-P&P Section 12-11). Multiple qualitative and quantitative measures of assessment are required. These include: 1) North American Veterinary Licensing Examination (NAVLE), an examination of clinical knowledge, with scores reported annually. A college must document that the minimum average pass rate for its graduates that sit for the NAVLE is greater than 80%; 2) student attrition (completion) rates; 3) employment rates for the graduates; 4) measures of graduating seniors and alumni assessing satisfaction with the program and preparedness of the graduates for entry level employment; 5) measures of employer satisfaction with the graduates; 6) faculty’s assessment of its resources for teaching and an assessment of graduate preparedness for entry level employment. Each college is required to provide evidence that its graduates have gained competence through direct faculty assessment of student achievement in nine broad clinical areas, such as, basic surgery skills, case management, client communication, etc.; 7) any other measures the college wishes to provide.

With the exception of Canada, the NAVLE is not required for licensure in the international colleges accredited by the COE and it is not unusual for only a small percentage of the graduating class to have sat for the NAVLE. In order for the Council to assess the pass rate of the NAVLE in a fair and equitable manner given the small sample size taking the NAVLE, the Council will calculate an exact 95% binomial confidence interval for any college that has a pass rate of less than 80%. Except for the NAVLE, the Council does not assign numerical values to describe levels of achievement for students in any of the outcome delineators, but closely analyzes and monitors trends for the college. Trends that imply significant decrease(s) in student achievement over a five-year period may imply deficiencies in the program. 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) (Exhibit 19-P&P Sections 12-11 and Exhibit 36-P&P Section 11-4 [11.4.1]). Most importantly, colleges must use the information gained from outcomes assessment activities to improve the curriculum.

Each college is required to submit outcomes assessment documentation annually along with changes in its curriculum resulting from the knowledge gained (Exhibit 19-P&P Section 12-11; Exhibit 17-Self-Study X [Standard 11 Self-Study Narrative]; Exhibit 17-Self-Study X [Standard 11 Self-Study Appendix 11]). The site team through the self-study, review of college websites, and interviews with students, faculty, alumni, and administration confirm the use of outcomes assessments to assess student competence and to improve the program. The Council analyzes the data provided and assesses compliance with the standard (Exhibit 18-X Report of Evaluation_redacted; Exhibit 37-X Status Letter_redacted).
 
Analyst Remarks to Narrative
The agency requires programs to collect, analyze, and use student outcomes data for program improvement. Programs must report NAVLE pass rates, student attrition rates, employment rates, student and graduate satisfaction data, as well as any other measures that the program can provide. The agency establishes an 80% pass rate for its licensure exam and employs a 95% binomial confidence interval for colleges that have a pass rate of less than 80%. The agency has provided evaluation reports that document the agency's evaluation of its student achievement standard.
 
Student Achievement, Question 2
 
Agency Narrative
The COE does not specifically require colleges, domestic or international, to provide preparatory courses for the NAVLE. Completion of the curriculum of accredited colleges will provide the knowledge base needed for candidates to pass the NAVLE or other licensing examinations.

The objective of the COE is to ensure that accredited colleges produce graduates that have the fundamental principles, scientific knowledge, and physical and mental skills that will prepare these graduates for a diverse array of career options in clinical patient care, research, and other non-clinical positions related to animal and human health (Exhibit 38-P&P Section 4-2). These career activities may or may not require licensure. The standards have been developed and have been updated using wide stakeholder input to insure the standards meet the needs of society. The application of these minimum standards of veterinary medical education ensures that graduates of an accredited college have had an education that will prepare them for entry-level positions in the profession. The COE does expect that 80% or more of each college’s graduating senior students sitting for the NAVLE will have passed at the time of graduation as described in the previous section.
 
Analyst Remarks to Narrative
The agency attests that preparation for the NAVLE is embedded in the agency's curriculum requirements which provide the knowledge base needed to pass the NAVLE exam at the threshold established by the agency.
 
Student Achievement, Question 3
 
Agency Narrative
Standard 11, Outcomes Assessment, states that the Council expects that 80% of the graduating senior students who sit for the NAVLE will have passed at the time of graduation. This is only one of many outcomes assessment measures that the Council uses to assess the college’s ability to produce an entry-level veterinarian who is ready to enter practice. With the exception of Canada, the NAVLE is not used as a licensing examination in other countries and not all countries use the passage of a licensing examination as a prerequisite for licensing (registration). For those colleges that do not have senior students who sit for the NAVLE, the Council uses all other outcomes assessment data, including assessment of the attainment of the nine clinical competencies in assessing the ability of the college to produce a competent entry-level veterinarian.

Colleges must provide evidence of NAVLE pass rates, employer surveys assessing satisfaction with graduates, senior and alumni surveys assessing satisfaction with the program and preparedness of the graduates for entry level employment, documentation of the attainment of the nine clinical competencies. Colleges that have a pass rate less than 80% have an exact 95% binomial confidence interval calculated. If the exact 95% binomial confidence interval is less than 85% for two successive years the college is placed on Probationary Accreditation and if the pass rate is less than 85% for two successive years the college may be placed on Terminal Accreditation (Exhibit 19- P&P Section 12-11).

The NAVLE is the only requirement that is assigned a benchmark. Colleges must provide evidence that students have attained competency in patient diagnosis, medical and surgical skills, emergency medicine, client communications, preventative care, ethical conduct, and biosecurity. In addition the Council monitors trends in absolute attrition and employment rates. Colleges with trends that are declining are expected to provide reasons for those trends, a plan to reverse those trends, and the implementation of the actions taken to reverse those trends. The COE has proposed outcome measures for job placement and attrition which are pending stakeholder feedback.
 
Analyst Remarks to Narrative
As part of its student achievement standard, the agency requires an 80% passage rate on the NAVLE and requires programs to ensure that graduates demonstrate the competencies of an entry-level veterinarian. The agency also monitors trends in attrition and employment rates; schools with declining trends must provide reasons for those trends and a plan to reverse those trends.
 
Admissions and Recruiting, Question 1
 
Agency Narrative
Standard 7, Admission. Within the context of its mission, each college must provide a fair and unbiased admissions process. The process must be transparent so that all elements of the process are known to prospective students, their parents, and the public. Colleges must consider factors other than grades in the admission process (Exhibit40-P&P Sect 7-7 and Exhibit 41-P&P Section 12-7).
 
Analyst Remarks to Narrative
The agency has a standard for admission that requires transparency in the admissions process and that each college provide a fair and unbiased process. Factors other than grades must be considered.
 
Admissions and Recruiting, Question 2
 
Agency Narrative
The site team reviews the documentation provided with the self-study and compares it with the evidence collected on the college web site and through observation and interviews with students, faculty, and staff during the site visit. The college catalog is submitted under Standard 6, Students (Exhibit 42-P&P Sect 12-6).
 
Analyst Remarks to Narrative
The agency reviews the college catalog and other documentation and conducts observation and interviews with students, faculty, and staff during the site visit. The agency's standard requires that programs accurately portray their admissions requirements.
 
Admissions and Recruiting, Question 3
 
Agency Narrative
The governments of the Netherlands, France and Mexico set admissions requirements for the Faculties of Veterinary Medicine which are located in each respective country (Exhibit 43- Admissions_Utrecht; Exhibit 44- Admissions_VetAgro Sup Exhibit 45- Admissions_UNAM). The Council acknowledges that each country has the ability to set requirements; however, each veterinary medical college must also meet the requirements in Standard 7, Admission.
 
Analyst Remarks to Narrative
The agency has provided admissions requirements for the Netherlands, France, and Mexico. The agency also accredits programs in Canada, Australia, England, Ireland, New Zealand, Scotland, St. Kitts, and Grenada.
 
Facilities, Question 1
 
Agency Narrative
Standard 3, Physical Facilities and Equipment. In context to its mission, an accredited college must provide an adequate, well-maintained teaching/learning environment for students, including adequate classroom and laboratory space, and the components necessary to operate animal hospitals on or off-campus for clinical instruction. Adequate faculty office space also is required.

Equipment and supplies must be made available to support the teaching program for DVM students. The COE does not require highly sophisticated equipment (for example, CT scanners, MRI, linear accelerator, etc.), but requires that equipment be modern and similar to that found in a veterinary clinical practice. Most of the programs have acquired very sophisticated equipment that students develop an appreciation for but are not required to become adept at using.

The Council is especially concerned with animal, faculty, staff, and student physical safety in regards to the educational environment and, therefore, carefully monitors factors that impact safety (Exhibit 34-P&P Sect 12-3).
 
Analyst Remarks to Narrative
The agency has a standard for physical facilities that assesses the adequacy of the teaching/learning environment and the availability of equipment and supplies to support the educational environment.
 
Facilities, Question 2
 
Agency Narrative
If clinical teaching is done in facilities other than a hospital owned by the college, the teaching components required are the same as in a traditional setting (college teaching hospitals). Colleges which use a distributive veterinary clinical educational model must identify which specific disciplines are taught at off-campus locations. All primary instructional sites are identified by the college and the COE designates those sites as core instructional sites. All core sites are visited by representatives of the site team and evaluated in the same manner as an on-campus veterinary teaching hospital (Exhibit 31- P&P Section 8). To guide site teams an off-site Inspection Guide, which may be tailored to the specific educational program, is used must be completed for each site visited (Exhibit 46- P&P Section 21-6, Exhibit 47- P&P Section 21-4). Personnel who supervise and evaluate the professional students must be available to meet with the site team representatives at the time of the site visit (Exhibit 26-P&P Section 20).

In addition, if colleges have off-campus sites, regardless of the presence of an on-campus veterinary teaching hospital, they must identify core sites where all of the students in the professional program are required to assemble for learning and core track sites where all students in a specific educational track are required to assemble for learning. These core sites are visited by the site team and supervisors and students interviewed to assure the quality of education delivered (Exhibit 48-P&P Section 13).
 
Analyst Remarks to Narrative
The agency requires site visits to all geographically-separated locations including those clinical sites under a distributive veterinary educational model. Core instructional sites must be visited and evaluated by the site team under the agency's standards.
 
Facilities, Question 3
 
Agency Narrative
Veterinarians at clinical teaching sites must be licensed in the jurisdiction and the sites are selected based on the instruction in specific disciplines to be provided. Veterinary technicians at the clinical teaching sites should be credentialed. All off-campus locations must be reviewed to ensure that the educational program is being delivered in an appropriate manner and a written description of the educational objectives expected to be accomplished and how assessment of student achievement of these objectives will occur at the site must be in place. The college must provide clinical site educators with training materials, expectations of the clinical site coordinators, and instruction on the format to evaluate student performance and to provide feedback to students. Documentation must exist that students and educators understand how evaluations of the student will occur including the evaluation of clinical competencies; understand the expectations for safety and security at the site and how to report concerns to the college (Exhibit 31-P&P Section 8-2). Site team members interview students and clinical site educators at the site to confirm students and educators knowledge of their responsibilities.
 
Analyst Remarks to Narrative
While the agency has guidelines for off-campus and distributive sites, it is not clear whether these are requirements or suggestions. For example, 8.2a of the guidelines states that a formal contractual agreement of expectations should be enacted, however, it is not clear whether the items included in the guidelines are formally evaluated during the site visit.
 
Agency Response
Site teams review the agreement/contract between the college and the clinical instructional site to ensure that the document adequately covers compliance with the standard and to formulate questions asked on campus and at the clinical sites. All clinical teaching sites that are designated as primary instructional sites are considered core instructional sites by the Council and during a site visit to the college are visited by at least two members of the team. The length of the site visit may be extended to ensure that all core instructional sites are visited. Each core instructional site is evaluated using a standardized survey that is completed by the members of the site team at the core instructional site. (Exhibit 26-P&P Section 20; Exhibit 46-P&P Section 21.6; Additional Question 1-APP_ 82- Distributive Site Forms_redacted). The survey includes questions that cover the facilities used for instruction and questions to address the requirements found in Section 8.2 (Exhibit 31-P&P Section 8) of the P&P (e.g. training provided to the clinical instructors; communication with students and the college; student evaluations). The site team also reviews handbooks and other training materials developed for clinical instructors at primary instructional sites and those developed for students (Exhibit 93-Clinical Instructor Handbook_redacted).
 
Analyst Remarks to Response
Details provided in the narrative states that the site teams have responsibility for ensuring the contract between the institution and clinical sites are appropriate and in compliance with the standards set forth by the agency.

Additional information provided by the agency includes a sample review of the offsite clinical facility. The site name was redacted from the materials, so the Department reached out to the agency to confirm which location was reviewed: University of Calgary Faculty of Veterinary Medicine.

The documentation provided includes a review of standards related to facilities, specifically the adequacy of safety measures, as well as instructional environment and equipment. Also included was a review of the standards related to monitoring/supervision, student involvement/responsibilities, medical records, and information resources.



 
Staff Conclusion: Comprehensive response provided
 
Student Complaints
 
Agency Narrative
Accredited colleges 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 (Exhibit 35-P&P Sect 7-6). Student complaints may come directly to the COE or be collected by the college for inclusion in the annual report (Exhibit 42-P&P Sect 12-6).

Signed, written complaints received by the COE are reviewed by staff for content to ensure that one of two conditions are applicable: 1) a pre-accredited or accredited college is not in compliance with the standards, or 2) the practice, condition, or situation is of a continuing or pervasive nature, as opposed to an unfair or arbitrary act of an individual or an act isolated in nature (Exhibit 49-P&P Sect 5-5-2). AVMA staff acknowledges receipt of complaints within seven working days, makes a preliminary investigation to determine the relevance of the complaint, If a preliminary investigation is warranted, the complaint is redacted to conceal the identity of complainant (if necessary), and forwards it to the dean of the college outlining the standards affected and a request for a response. Staff reports to the COE Executive Committee within 30 days of receipt of the complaint if relevance is found. The Executive Committee reports its findings to the COE within 30 days of receipt of the staff report. If the complaint is deemed by the Executive Committee to be of sufficient substance the complaint will be investigated further by the COE. Upon completion of the investigation, the COE will take appropriate action to bring the accreditation status in conformity. The entire process should be completed within six months. If an adverse decision is made regarding the college an appeal may be made. In any case, the college will be informed in writing of the complaint and any action the COE takes. The complainant is notified in writing of the outcome of the complaint.
 
Analyst Remarks to Narrative
The agency has policies and procedures that require programs to provide a mechanism for students to submit complaints to the accrediting agency regarding areas covered by the agency's accreditation standards.
 
Part 3: Accreditation/Approval Processes and Procedures
Accreditation Process and Procedures, Question 1
 
Agency Narrative
The COE uses a group of trained site visitors to conduct on-site evaluations of veterinary medical colleges. The site visitors are recruited via a public announcement. Applications of reviewed and approved by the Council according to criteria listed in the application form (Exhibit 50-Call for Visitor Applications). Site visitors are selected to provide the site teams with broad professional experience of practitioners and academics and serve six-year terms.

Site visitors from the United States and Canada are required to attend an in depth site visitor training program prior to actively participating in a site visit. Initial site visitor training is done in residence at AVMA headquarters over a two and a half day period. It includes lectures, small group learning, role playing exercises, and a mock site visit. Attendees review a self-study and subsequent site visit report from a college under active consideration and are guided through the evaluation process including identification of strengths and weaknesses, site visit etiquette, development of appropriate questions, interview techniques, facility inspection, compliance, report writing, and exit interviews (Exhibit 51- Site Visitor Training). The site teams are also trained in the use of the detailed evaluation rubric which contains guidance on compliance with the standard (Exhibit 52-P&P Section 21.9). Training culminates with attendance at a COE meeting. Trainees observe the COE deliberation and accreditation decision for a college to more fully appreciate how the Council uses professional judgment to interpret and apply the standards consistently across all programs (Exhibit 26-P&P Section 20). Annual retraining is also required. Site visitor performance is evaluated by the college, site team chair, and other site visitors. Survey results are reviewed by the Council annually. The two regional representatives do not undergo the training at AVMA headquarters; however, two hours of training is provided on-site prior to the beginning of the site visit and they are provided with a video that provides information on the standards and their application (Exhibit 53- Site Team List-Dublin).

Site teams are assembled by the Evaluation Committee Chair from the pool of trained site visitors based on a balanced distribution of expertise, i.e. academic and private practitioner with small and large animal expertise. The dean of the college being evaluated is asked to review proposed site team visitors and observers to avoid conflicts of interest missed by team members.

Academics, educators, practitioners, and public members make up the policy, and decision-making bodies of the COE (Exhibit 54-P&P Section 2; Exhibit 55-P&P Section 15; Exhibit 56-AVMA Bylaws_Article VIII) that has as its purpose accreditation of veterinary medical colleges. The policy and decision making body is the full Council, which is composed of 20 voting members. Appropriate expertise is provided by 6 veterinary practitioners, 6 veterinary academics, and one veterinary member-at-large, one member representing veterinary preventive medicine, one member representing non A practice/non A academics, one CVMA NEB member, one Association of American Veterinary Medical Colleges (AAVMC) member, and three public members. Many geographical areas, veterinary disciplines and veterinary species interests are represented by the variety of COE members.

The six veterinary practitioner members, the veterinary member-at-large, and the non-practice/non-academic member, representing a broad cross-section of employment types in veterinary medicine, are selected by a Council on Education Selection Committee who reviews and selects members based on criteria listed in the application (Exhibit 57-Call for COE Nominations). The COE Selection Committee consists of two members of the AVMA Board of Directors, one member of the AVMA House of Delegates, and two former COE members. A similar committee of the Association of American Veterinary Medical Colleges (AAVMC) selects six academic members and the veterinary preventative medicine member of the Council.

The Association of American Veterinary Medical Colleges and the Canadian National Examining Board each appoint one voting member of the Council.

The Council elects three public members from nominations received. Each public member serves a six year term (Exhibit 54-P&P Section 2, Exhibit 55-P&P Section 15). No public member shall be appointed to the COE who: holds the Doctor of Veterinary Medicine (DVM) or equivalent degree; is a current or former employee, member of the governing board, administrator, owner, shareholder of, or consultant to a college of veterinary medicine; is a member of any trade association or membership organization affiliated or associated with the Council; or a parent, spouse, child or sibling of these individuals. Current public members include a faculty member at the University of Mississippi Medical Center, an Assistant Dean of Medical Education and Faculty Development at the Sophie Davis School of Biomedical Engineering, and a retired social worker. Public members of the Council are accorded the same rights and privileges as veterinary members.

Each Council member brings expertise in veterinary education, public/private practice, or a public perspective to their role in the accreditation process.

Training is provided for all COE members (Exhibit 58-P&P Sections 16-3 and Exhibit 59-P&P Section 19) using a DVD; training guide (Exhibit 26-P&P Section 20); a copy of The Future of Accreditation in the US, Peter Ewell, CHEA; annual member training program at the fall COE meeting, (Exhibit 60-COE Minutes_Sept 2014 [showing training]); web-based resources provided by the Association of Professional and Specialized Accreditors (www.aspa-usa.org); training before each site visit (Exhibit 61-P&P Section 19-2 and Exhibit 26-P&P Section 20); and new members are assigned a COE mentor and oriented at a dinner meeting the evening before their first COE meeting. New members also attend the COE site visitor training which is held at AVMA headquarters and attend a site visit as an observer during their first year on the Council for orientation and training purposes. Individual advice and training are offered by COE staff for any member seeking to improve his/her knowledge and skills in accreditation and pre-accreditation duties.
 
Analyst Remarks to Narrative
The agency has procedures for the selection and training of site visitors and Council member which are clearly stipulated in the agency's by-laws and handbook. The agency has also provided sample training materials, nomination solicitation for council members, and a list of site team members and their institutional affiliations.
 
Accreditation Process and Procedures, Question 2
 
Agency Narrative
The COE has in place controls to prevent conflict of interest or the perception of conflict of interest (Exhibit 62-P&P Section 5-4, Exhibit 63-P&P Section 15-7, Exhibit 64-P&P Section 18-1 & 18-2, Exhibit 26-P&P Section 20, Exhibit 65-P&P Section 21-1, and Exhibit 66-P&P Section 21-10). Confidentiality requirements are reviewed before every COE meeting and before every site visit (Exhibit 67-COE Agenda_Sept 2014; Exhibit 14-Conflict Form). All participants sign a confidentiality agreement in order to participate (Exhibit 14-Conflict Form). Appeal panel members are held to the same confidentiality requirements and must sign a conflict of interest agreement (Exhibit 68-P&P Section 10-12)

All members of the COE are volunteers. Each person is trained regarding conflict of interest and personal agendas. During decision making meetings, a COE member identified with a conflict of interest for a given college must recuse herself/ himself from discussions and the decision making process. These members return to the meeting only when a final decision has been made for the college with which they have a conflict (Exhibit 63-Section 15-7 and Exhibit 69-P&P Section 10-7).

Site team members must identify site visits where they wish to participate and through that process indicate that no conflict of interest exists (Exhibit 64-P&P Sect 18-1 & 8-2). Further, each member of the evaluation site team (including the CVMA NEB site team members, the two regional representatives on non-US or Canadian site visits, non-voting AVMA staff and COE Observers and other non-voting observers) must sign a conflict of interest statement for each site visit (Exhibit 62-P&P Section 5-4; Exhibit 14-Conflict Form). The signed document is filed in the COE office. Conflict of interest and personal agendas are addressed again at the on-site training session and a member would be dismissed if an unreported conflict is discovered.

The administrative staff must follow the policy on conflict of interest. The supporting staff member must sign a conflict of interest statement prior to supporting a site visit (Exhibit 62-P&P Section 5-4 and Exhibit 65-P&P Section 21-1). Staff members have no vote in the decision making process but are given an opportunity to provide specific factual information regarding a site visit and serve as one of the measures to ensure consistency in application of the standards.

Any person participating in a COE site visit in any capacity must meet the criteria outlined in section 5.4 of the P&P and must sign a confidentiality agreement (Exhibit 65-P&P Section 21-1).
 
Analyst Remarks to Narrative
The agency has conflict of interest guidelines and requires their council members, site team visitors, and agency staff to sign a conflict of interest statement attesting to their adherence to the conflict of interest guidelines. The agency has also provided sample minutes that demonstrate the agency's application of its conflict of interest guidelines.
 
Accreditation Process and Procedures, Question 3
 
Agency Narrative
The Council uses a variety of methods to ensure consistency in application of the standards. Training site visitors and site team chairs is important in controlling the application of the standards in a consistent manner (Exhibit 26-P&P Section 20). Each site visitor receives intensive initial training and annual retraining where team members are trained in the interpretation of and compliance with the standards (Exhibit 51-Site Visitor Training). The evaluation rubric used by the site team provides guidance to the team when assessing compliance with the standards (Exhibit 52-P&P Section 21-9). Site visitors are evaluated by site team members, site team chairs, and the college following each visit. If needed, remedial training is provided site visitors. The COE produces a video (DVD) that provides general information on the standards and their application. For international visits, the regional representatives receive a copy of the video prior to the site visit. In addition, the site team is provided with (at minimum two hours) training prior to the start of the visit (Exhibit 61-P&P Section 19.2). These sessions discuss the need to focus on the standards and the colleges’ compliance, difficulties created by personal agendas, and the need to be consistent. A staff member travels with each site team and provides continuity and consistency of application of the standards (Exhibit 64-P&P Section 18-1 & 18-2).

Each new member of the COE also participates in the site visitor training, is assigned a mentor, and receives an orientation before their first meeting, and attends a site visit as an observer. In addition, at each COE fall meeting, the COE is provided with training (Exhibit 26-P&P Section 20: Exhibit58-P&P Section 16-3). COE staff will also provide training as requested. Staff also provides a database of past decisions of the Council as a guide if needed (Exhibit 70-P&P Section 17-11).

A detailed self-study template explaining the evidence required to demonstrate compliance with the standards is provided to each college (Exhibit 12-Section 12; Exhibit 36-P&P Section 11-4 [11.4.1]). The completed draft report of evaluation is sent to the dean for comment on factual errors (Exhibit 72-P&P Section 18-8; Exhibit 73-email Requesting Fact Check; Exhibit 18-Deans Comments of Report of Evaluation).
 
Analyst Remarks to Narrative
The agency has described several mechanisms built into its accreditation process to control for the inconsistent application of its standards. For example, the agency provides training to site visit teams, and employs the use of a site visit evaluation rubric to ensure that site visitors consistently assess each criterion under each standard. The agency also provides a self-study template to its programs so that programs are responsive to each of the agency's standards.