Friday, September 9, 2011

Sample CCE Letters

MAKE YOUR LETTERS PERSONAL AND UNIQUE. This all has to be completed by Sept 15

Email your complaint to aslrecordsmanager@ed.gov with the subject line:

Written Comments RE: Council on Chiropractic Education

blind cc steve_tullius@yahoo.com to ensure we have records of your complaint.

Snail Mail your letter to:

National Advisory Committee on Institutional Quality & Integrity
Office of Postsecondary Education
United States Department of Education
1990 K Street, NW
Room 8060
Washington, DC 20006

__________________________________________________________________

A FEW SAMPLE LETTERS ARE BELOW FOR YOUR REVIEW.


Three main issues need to be addressed: 1. The CCE is not representative of the profession., 2. CCE is attempting to move the practice of chiropractic into the practice of medicine., 3. CCE has attempted to mandate a medical education, which leads chiropractors to fail in practice.

*IMPORTANT* Do not copy and paste. Take the 10 minutes to make it unique. Does not have to be long. Just unique and personal. PLEASE REMAIN PROFESSIONAL IN ALL COMMUNICATIONS.

*IMPORTANT* blind cc steve_tullius@yahoo.com
to ensure that we have records of all communications

"In all instances, your comments about an agency's initial recognition or the renewal of recognition must relate to whether the agency meets the Criteria for Recognition."


The following letters contain example of violations of the "Criteria for Recognition" taken directly from the US Dept of Education website. (http://www2.ed.gov/admins/finaid/accred/accreditation_pg13.html)

It is essential to include these points in the letter:
The CCE is in direct violation of the USDOE Criteria for Recognition

Section 602.13 - Acceptance of the agency by others

Recent changes to standards for the accreditation of chiropractic institutions will further reduce chiropractic towards a subset of medicine, having eliminated essential language which defines chiropractic as a separate and distinct philosophy, science, and art. According to institutions, faculty, and the profession at large, the term "subluxation" and the language "without drugs or surgery" are essential elements in defining chiropractic. I also agree that these are core elements to the value and effectiveness of chiropractic.


The CCE is in direct violation of the USDOE Criteria for Recognition

Section 602.14 - Purpose and organization &Section 602.15 - Administrative and fiscal responsibilities

There are direct financial and political conflicts of interest at the CCE which have been evidenced formerly in previous investigations. A very specific philosophical and political agenda is also apparent in the recent changes to the Standards described above.


The CCE is in direct violation of the USDOE Criteria for Recognition

Section 602.16 - Accreditation and preaccreditation standards

The standards and guidelines the CCE sets for the accreditation of institutions is not producing successful doctors of chiropractic, nor is this being monitored. With attrition rates being quite high, and defaults on student loans for chiropractic education even higher, graduates are not well prepared for success. It is no wonder that when taught medicine, graduates fail at chiropractic. The accreditation of institutions which are no longer required to teach the core principles and practice of chiropractic in their curriculum removes the very uniqueness that adds value for the public and makes chiropractic effective and efficient healthcare.


In sum, the CCE is no longer representative of the profession and has been exercising it's control to move the profession away from it's unique and core value as a distinct and effective approach to health and wellness.

*****IMPORTANT***** DO NOT COPY VERBATIM. Make it personal and unique to have the biggest impact. It does not have to be long and technical. You and our profession deserve the 10-15 min it takes to perform this simple yet profound act.

Here is a link to review these issues in detail: http://www.mccoypress.net/subluxation/docs/cce_fvs.pdf
______________________________________________________________________________

Dear Sir/Madame,

There has been trepidation by the United States Department of Education to address the political and inner workings of the chiropractic profession, or any profession. I understand this,however the CCE is no longer representative of the profession and their lack of regard to representing us has led us to the extreme measure of once again seeking your assistance in our internal issues. In my professional and personal opinion, the CCE has repeatedly violated your Criteria for Recognition, and in doing so, has sought to diverge from the core principles that make the chiropractic profession distinct. The violations are:

First, section 602.13 - Acceptance of the agency by others. “Acceptance” is something that requires a group to reflect the interests of the larger public that they intend to represent. In the recent reformation of their standards of accreditation, the CCE (willfully or otherwise) ignored the input of thousands of practicing doctors of chiropractic, the profession that they claim to represent. I personally wrote a letter, faxed a letter and phoned the organization personally, all to receive not even a modicum of response or compromise on the major issues presented. From personal interactions, I know of several hundred other doctors who received the same treatment from the CCE. If no amount of the representing public commenting can alter the opinions of the CCE, then the CCE does NOT have acceptance by others, they only have acceptance by their own set of standards. This is in violation of the principle of the accreditation process as a whole.

Second, Section 602.16 - Accreditation and preaccreditation standards. The CCE was given authority to accredit chiropractic colleges due to their niche within the healthcare world. In their recent reformation of their standards, the CCE has removed two principles that the chiropractic profession has legally defended for decades, namely the correction of subluxation and being a profession that does not use drugs or surgery. As their new standards do not include these defining characteristics of the profession, then the CCE has essentially made themselves a de facto medical board, thereby making them inappropriate to accredit chiropractic institutions. The chiropractic profession has dozens of civic and criminal legal cases in favor of being a separate and distinct profession based upon these two principles. By their own hand, they have removed their authority to accredit chiropractic institutions.

Thirdly, and this case is somewhat harder to make, these changes as I am describing above only have come as the result of repeated violations of Section 602.15 - Administrative and fiscal responsibilities. The CCE nomination and selection process has repeatedly demonstrated that it is subject to philosophical bias, financial influence, and nepotism. They have broken their fiduciary responsibility to represent the profession as a whole. This is best summarized by Dr Gerry Clum, DC, a former member of the CCE. He wrote:

"Think about the appointment process to the Council - people get nominated, they are vetted by a committee of the Council on ambiguous criteria, they are put on a ballot that allows preferences to come into play, then a decision is made by the people who already sit on the Council. The opportunity for in-breeding, and election of people who represent a given orientation in the profession versus another, is obvious." http://www.chiro.org/docs/cce_revision_clum.pdf

Without the administrative process to be open in selection and representative of the profession as a whole instead of those chosen according to ideological positions, the CCE has not standardized process to ensure that it can meet the criteria as outlined by the USDOE.

In closing, it is imperative that this cycle of infighting be stopped, but it appears the profession as a whole cannot do so. We have petitioned the CCE with our opinions, and they have ignored us. Many have vied for positions on the board, only to be denied due to ambiguous decisions processes. It appears that your committee and the governmental sponsorship of this group seem to be the only remaining source of true balance for this issue. I strongly urge to reprimand the CCE or revoke their right to ability to accredit chiropractic institutions if they are unable to reform their repeated violations of the Criteria for Recognition.

With Respect,

To Whom it May Concern:
Please accept my complaint to the US Department of Education (USDOE) against the Council on Chiropractic Education (CCE). It is my opinion and the opinion of many of my colleagues that The CCE is not representative of the chiropractic profession. In particular the CCE is attempting to change the practice of chiropractic into the practice of medicine.

Even as far back as 1986 when I graduated from chiropractic college, the schools, under the accreditation of CCE were severely lacking in a true chiropractic education, and favored a medical curriculum. If it were not for my being the son of a chiropractor, I am not sure that I would have acquired the knowledge and skills necessary to provide my community a competent chiropractic service. Many gaps in what I believe I should have learned in chiropractic college were filled in by my dad and other older chiropractors who were willing to take the time to teach those of us who sought it out.

Unfortunately, not every student had the background that I had. This is evident in the high default rate among chiropractic college graduates. It is clear that the CCE did not ensure that our schools were providing an adequate education in order for the students to come out and succeed in practice.

It is important that any agency that wishes to accredit the schools of a profession do so in a manner that is consistent with the practice of that profession. CCE is trying to move chiropractic away from the detection and correction of subluxation, which is the primary function of the chiropractor. The CCE is trying to change chiropractic into the practice of medicine by removing wording that states that chiropractic is a profession that works "without drugs or surgery". This is unacceptable, as it was never the intention of the chiropractic profession, and it will not adequately take the place of practicing medical doctors whose job does involve the use of drugs and surgery.

The public and future generations deserve to benefit from the chiropractic profession and its unique service of detecting and correcting subluxations. If the CCE would like to represent this great profession then it should share that objective, not one of changing chiropractic into a duplication of medical practice with no more chiropractic available to the people of this world.

Thank you for considering my comments, and for dealing with the CCE in a manner that is proper,


_________________________________________


To Whom it May Concern:

Please accept my complaint to the US Department of Education (USDOE) against the Council on Chiropractic Education (CCE). It is my opinion and the opinion of many of my colleagues that The CCE is not representative of the chiropractic profession. In particular the CCE is attempting to change the practice of chiropractic into the practice of medicine.

When I graduated from chiropractic college, the schools, under the accreditation of CCE were severely lacking in a true chiropractic education, and favored a medical curriculum. This is evident in the high default rate among chiropractic college graduates. It is clear that the CCE did not ensure that our schools were providing an adequate education in order for the students to come out and succeed in practice.

It is important that any agency that wishes to accredit the schools of a profession do so in a manner that is consistent with the practice of that profession. CCE is trying to move chiropractic away from the detection and correction of subluxation, which is the primary function of the chiropractor. The CCE is trying to change chiropractic into the practice of medicine by removing wording that states that chiropractic is a profession that works "without drugs or surgery". This is unacceptable, as it was never the intention of the chiropractic profession, and it will not adequately take the place of practicing medical doctors whose job does involve the use of drugs and surgery.

The public and future generations deserve to benefit from the chiropractic profession and its unique service of detecting and correcting subluxations. If the CCE would like to represent this great profession then it should share that objective, not one of changing chiropractic into a duplication of medical practice with no more chiropractic available to the people of this world.
Thank you for considering my comments. I am certain you have received many letters that describe the many infractions and violations of the USDOE "Criteria for Recognition"


____________________________________________


To Whom it may concern:

I am a doctor of Chiropractic writing to file a complaint with the US Department of Education against the Council of Chiropractic Education (CCE).

The CCE has a troublesome stranglehold over the direction of modern Chiropractic education which is lowering the quality of practitioners that are being graduated by the Chiropractic schools. The educational standards that it promotes and enforces are not in line with the actual practice of Chiropractic in the United States and represent only a minority view of the profession at large.

I serve on the Board of Trustees for a Chiropractic college and I am appalled by the lack of focus on Chiropractic education by the CCE with instead an almost total focus on a medical education. Many of the things we are mandated to teach at our school have nothing to do with the practice of Chiropractic and instead create confusion in the mind of the student as to what the true role of a Chiropractor is.

Being that Chiropractors are obviously not qualified medical doctors the CCE medical education leads to failure in practice and a resulting high rate of default on student loans.

There are MANY medical courses that could be easily cut from the chiropractic curriculum. This would lower the cost of a chiropractic education and thus lower the default rate on student loans. This would be an enormous savings to the federal government in these tough economic times.

In addition a new focus on teaching an actual Chiropractic education would produce highly qualified Chiropractors. This would increase their success rates, lower the student loan default rates, and better serve Americans who choose Chiropractic care for their families.

I would be willing to form a knowledgeable group of educators and leaders in the Chiropractic profession whom could testify to the sad state of affairs and very poor Chiropractic educational programs that are currently being encouraged by the Council of Chiropractic Education. We could also offer effective solutions to this crisis in Chiropractic education.

Chiropractors are responsible for detecting, analyzing, and adjusting vertebral subluxations. Please work with us to provide an accrediting agency that ensures this rather then the current system which ensures costly failures to the government by training doctors of Chiropractic to be 3rd rate medical practitioners.

Thank you for your time and consideration in this manner.
___________________________________________________

To Whom It May Concern,

Please accept my comments to the US Department of Education (USDOE) concerning the Council on Chiropractic Education (CCE). I am a Chiropractor in Atlanta Georgia and have been for 6 years.
I am aware that you have received many complaints and letters, so mine will be brief, I will not speak to doctrinal issues, or political differences. I will simply ask that you hold the CCE accountable to USDOE requirements.

There are many requirements that I believe the CCE is not meeting, but I will focus on only one here.

To my understanding, it is a requirement for the CCE to take into account comments made during the period PRIOR to their adoption of new educational standards.
In their recent changes, they did not take into account comments from the profession, and if they did, we were completely disregarded. It amazes me that so many voices were ignored!

They made changes against the will of not only thousands of practitioners, but also the International Chiropractors Association, The American Chiropractic Association, 7 to 9 schools of chiropractic, And also my state association the Georgia Council of Chiropractic. Is this acceptable by your standards?

Thank you,

___________________________________________________

To Whom it May Concern:
I am doctor of chiropractic writing today to file a complaint with the US Department of Education (USDOE) against the Council on Chiropractic Education (CCE) for the following infractions and violations of the USDOE "Criteria for Recognition" 1:

* Lack of consideration of the opinions of the profession at large and students in particular as witnessed with the recent adoption of new CCE Standards. 2-6 This is particularly disconcerting as the new Standards have essential language such as subluxation, nearly removed, as well as any reference to chiropractic being "without the use of drugs or surgery." The Association of Chiropractic Colleges considers both to be essential elements of their paradigm statement. 7 How can a graduate expect to succeed in clinical practice when the detection and correction of subluxation is not considered a meta-compentency yet considered essential to the colleges and profession at large? Removing the language "without drugs or surgery" serves to move the profession closer to the inclusion of drugs, which has become an increasing political and philosophical battle this past year. As a doctor of chiropractic, I wish for chiropractic to remain drugless. The failure of the CCE to recognize and respond appropriately to the wishes of the institutions, faculty and practitioners is a direct violation of section 602.13 Acceptance of the agency by others.

* Failure to adequately assess the competency of chiropractic colleges in producing graduates who will succeed in clinical practice. With chiropractic student loans at 53.8% of all the Health Education Assistance Loan (HEAL) loans that are in default according to Health Resources and Services Administration (HRSA), it is clear that the CCE is not ensuring that the colleges are producing a curriculum that gives students a realistic chance at success post graduation. 8 According to a study conducted in the state of California, attrition rates for chiropractors are as high as 25%. 9 Others remark on the same theme. 10, 11, 12 The failure of the CCE to accredit institutions and mold their curriculums that produce graduates that will succeed in practice is a direct violation of section 602.16 Accreditation and preaccreditation standards.

* While the CCE has developed a "Guideline for DCP Assessment of Learning of Meta-Competencies," 13 those guidelines are predominantly based on passing of exams by the National Board of Chiropractic Examiners. This is a cyclical problem as the CCE dictates the curriculum, the NBCE writes the test and the colleges most then teach to the test. In this way, chiropractic curriculums and resultantly the profession, are being diverted towards a particular political and philosophical agenda. As cited above, the CCE is not "promoting academic excellence and not ensuring the quality of chiropractic education" in a meaningful way as per the CCE's purpose stated in section 2 of the CCE Standards. Dr. Bruce Lipton, Ph.D., has referred to the increasing medical curriculum in chiropractic education which is being mandated by the CCE as "an academic impediment that unknowingly destabilizes their students and hobbles their graduates' effectiveness." 14 As a former student and now doctor of chiropractic, I can attest to that curriculum being insufficient in teaching the core principles and practice of chiropractic, as can the many graduates referenced above who were unable to succeed in practice. This is another example of a violation of 602.16 Accreditation and preaccreditation standards.
* CCE Policy 18 in the CCE Manual refers to Conflicts of Interest stating, "Councilors, Academy of Site Team Visitors, Member Representatives, CCE Administrative Office staff; other CCE representatives; and consultants retained by CCE; shall not engage in activities that would result in a conflict of interest, or the appearance of a conflict of interest that would affect their ability to be impartial and objective with their CCE-related duties or that would result in personal gain to themselves." This has long been a complaint against the CCE for violating this standard. As was seen with the Life University situation in 2002, councilors were making decisions with direct financial conflicts of interest and most recently, changes to the Standards reflect a particular philosophical and political agenda. The rampant conflicts of interest in the CCE is a violation of sections 602.14 Purpose and organization and 602.15 Administrative and fiscal responsibilities.

* From the CCE Manual of Policies 15 comes the following statement: "If the Council determines that a CCE-accredited DCP is making incorrect, misleading or misrepresentation of public statements about its accreditation status, the contents of site visit reports, DCP effectiveness, success of graduates and/or Council accrediting actions, the Council will act to have the DCP publicly correct the statements within a specified time frame." This is of particular concern as National University of Health Sciences has publicly advertised their program as a Doctor of Chiropractic Medicine Program and sought the approval of various state boards to allow this distinction. No such program has ever been accredited by the CCE, yet a CCE announcement dated March 3, 2010 reflects a "Reaffirmation of Accreditation" of National's "Doctor of Chiropractic Medicine Program." 16 This is a clear violation by of the CCE's Standards by National University as well as by the CCE of section 602.18 Ensuring consistency in decision-making.

In addition to the above, CCE is in violation of the "Member Code of Good Practice" document found within the CCE Council Manual. 17 Specifically the CCE has:


* Failed to demonstrate "respect for the complex interrelationships involved in the pursuit of excellence by individual institutions or programs." This is witnessed by the lack of proper representation of various segments of the profession as well as the requiring of a curriculum reflective of narrow interests and political action. Violation of sections 602.14 Purpose and organization and 602.15 Administrative and fiscal responsibilities.

* Violated, and not exhibited a "system of checks and balances in its standards development and accreditation procedures." The recent disregard of the unprecedented feedback from the profession regarding the CCE proposed Standards clearly demonstrates that no checks and balances is in place. Violation of section 602.16 Accreditation and preaccreditation standards.

* Failed to "serve as a unifying body for the chiropractic profession" as per CCE mission statement. There is as much, if not more division within our profession today as ever. This after 50 years of CCE operation, since its incorporation in 1971.

The CCE is not representative of the profession. It has a long history of conflicts of interest and advancement of philosophical and political agendas. A simple search of the names of the councilors of the CCE in the two national, and ideological opposed chiropractic associations (ACA and ICA) reveals that out of the 18 doctors of chiropractic that are councilors, 9 are members of the ACA while there are zero from the ICA. The election process of the CCE is riddled with conflicts of interest and outright attempts to keep the profession under the control of the reigning body and their political agenda.

Past-president and former member of the CCE, Gerry Clum recently had this to say regarding the election process, "Think about the appointment process to the Council - people get nominated, they are vetted by a committee of the Council on ambiguous criteria, they are put on a ballot that allows preferences to come into play, then a decision is made by the people who already sit on the Council. The opportunity for in-breeding, and election of people who represent a given orientation in the profession versus another, is obvious." 18

James Edwards, past ACA chairman, also commented in regards to this saying, "This incestuous selection process has failed to produce CCE board and council members who are willing and able to represent the mainstream positions of the majority of doctors of chiropractic, the majority of chiropractic colleges, and both national chiropractic membership organizations. And until CCE changes its electoral process, it will remain an organization without any moral authority to speak for the chiropractic profession." 19

Clearly, the CCE is operating as the "cartel" and "monopoly" as Dr. Denardis, one of the individuals hearing the case for the National Advisory Committee on Institutional Quality and Integrity at the last reaccreditation hearing stated, "Battles over turf, battles over philosophy, maybe battles over personal ambition, but divisions of every kind. And some of this, maybe most of it, is a consequence of, at least as I see it, a monopoly control of a profession which has led to the establishment of a virtual cartel..." 20

The CCE is advancing a curriculum that is not consistent or congruent with the practice of chiropractic and is actually antagonistic to chiropractic principles. It leads the public to believe that we are treating their "diagnosed condition" with chiropractic care. This becomes a liability and can become a danger to the public. This approach encroaches into other therapeutic fields that are outside the scope of practice of chiropractic. Christopher Kent has given an excellent example of a curriculum that reflects the practice of chiropractic and would help ensure the success of our graduates. 21

I feel that as a doctor of chiropractic, I do not need and it does not serve me, or the public, to duplicate what already exists. The education and service the CCE is advancing through their mandatory curriculum is nearly identical to one received in physical therapy and physiatry.

I feel that the CCE has not giving educational freedom and institutional autonomy to the chiropractic institutions and is supporting or accommodating a specific philosophical or political position by seeking to transform chiropractic into or towards a medical discipline.

I am requesting that the CCE cease and desist its "redefining of chiropractic" as recently proposed. It is beyond the CCE mandate to do so.

I am requesting a proper resolution to the above complaints, as to date, no actions have been taken to ensure that these sorts of abuses do not continue. I am asking for a reformation of the CCE governing body or the dissolution of the CCE with the formation of a new accrediting body with a grace period to establish such a body. This is the only way to ensure proper representation of the profession as the CCE has clearly shown they are not capable of following the Criteria of Recognition that the USDOE has establish.

Thank you in advance for your consideration in this matter.

References:

1. "Criteria for Recognition" taken directly from the US Dept of Education website:http://www2.ed.gov/admins/finaid/accred/accreditation_pg13.html
2. Edwards, J. The Profession Has Spoken ... But Will the CCE Listen? Dynamic Chiropractic - December 2, 2010, Vol. 28, Issue 25
3. Outpouring of Comments to CCE Marks Deep Profession-Wide Concern Over Future of Chiropractic Education, ICA http://members.chiropractic.org/asset/docs/OutpouringofCommentstoCCEFeature.pdf
4. Clum, G. Open letter to the profession regarding proposed changes to the CCE Standards http://www.chiro.org/docs/cce_revision_clum.pdf
5. Edwards, J. The Profession Has Spoken ... But Will the CCE Listen? Dynamic Chiropractic - December 2, 2010, Vol. 28, Issue 25 http://www.jamesedwards.com/CCE2.pdf
6. CCE Accreditation Standards - Principles, Processes & Requirements for Accreditation January 2012 http://www.cce-usa.org/uploads/2012-01_CCE_STANDARDS.pdf
7. Association of Chiropractic Colleges Paradigm Statement http://www.chirocolleges.org/paradigm_scope_practice.html
8. Health Education Assistance Loan (HEAL) - Defaulted Borrowers http://defaulteddocs.dhhs.gov/discipline.asp
9. Foreman SM, Stahl MJ. The attrition rate of licensed chiropractors in California: an exploratory ecological investigation of time-trend data.Chiropractic & Osteopathy, 2010;18:24.
10. McDonald, W., K. Durkin, S. Iseman, et al. 2003. How Chiropractors Think and Practice. Ada, Ohio: Ohio Northern University.
11. Mirtz T, Hebert J, Wyatt L. Attitudes of non-practicing chiropractors: a pilot survey concerning factors related to attrition, Chiropractic and Osteopathy, 2010,18:29, www.chiroandosteo.com/content/18/1/29.
12. Kent, C. Is There an Oversupply of DCs? Dynamic Chiropractic - October 7, 2010, Vol. 28, Issue 21
13. Manual of Policies of The Council on Chiropractic Education January 2011 http://www.cce-usa.org/uploads/2011-01_Manual_of_Policies.pdf
14. Lipton, B. The Science of Innate Intelligence, 2002. http://w3.palmer.edu/strang/Philosophy112/Documents/Dr.%20Lipton%20Article.doc
15. CCE Manual of Policies - http://www.cce-usa.org/uploads/2011-01_Manual_of_Policies.pdf
16. CCE ANNOUNCEMENT -ACCREDITATION ACTIONS Annual Council Meeting January 15-17, 2010http://www.mccoypress.net/mccoy/docs/national_dcm_program.pdf
17. CCE Council Manual January 2010 - http://www.cce-usa.org/uploads/2010-01_Council_MANUAL.pdf
18. Clum G. "The Latest Stuff From Gerry." Jan. 31, 2011, Vol. 11, No. 14.
19. Edwards, J. Exposing the CCE Charade, Dynamic Chiropractic - April 9, 2011, Vol. 29, Issue 08http://www.dynamicchiropractic.com/mpacms/dc/article.php?id=55252
20. Betz, J. CCE "Cartel" is at it Again , AJCC 9/15/2010 http://www.chiropractic-biophysics.com/clinical_chiropractic/2010/9/15/cce-cartel-is-at-it-again.html
21. Kent, C. A New Direction for the CCE?, Dynamic Chiropractic - November 18, 2010, Vol. 28, Issue 24 http://www.dynamicchiropractic.com/mpacms/dc/article.php?id=55021

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