Response to CCAOM from the Accreditation Commission for Acupuncture and Oriental Medicine
January 14, 2003
Based on the Commission's review of the CCAOM executive committee's response to ACAOM's doctoral survey, it is clear that there are a number of inaccuracies contained in that response.
The Commission does not have a current position on the issues raised in its statement and survey. ACAOM's sole intent is to seek feedback and data on the doctoral questions -- questions which have been raised in many venues which are directly relevant to the Commission's functions and responsibilities as an accrediting agency.
The ACAOM survey is an initial first step in what will be a lengthy and thoughtful process in evaluating the future role of doctoral education for the profession, and this process will necessarily include the educational, practitioner and other relevant communities of interest. As part of the process, the Commission will be considering followup surveys, focus groups, public hearings, and other means to ensure that the views of all relevant stakeholders in the profession are fully and fairly considered, and will be making public the data from these efforts to ensure that the process is fully transparent. ACAOM is fully committed to the "careful reflection" and "collective planning" urged in the CCAOM executive committee's response to ACAOM's survey. No conclusions will be reached on these issues until all pertinent information has been fully considered, and collaboration with other relevant stakeholders takes place.
The survey is not "premature." The issue of the doctorate as the entry-level standard for practice has come to a head nationally, with a number of states that have been considering regulatory and legislative proposals to increase curriculum requirements for licensure to justify the doctor licensing title. The debate has also been consistently reflected in the newsletters, web sites, and other public statements of national and state associations, as well as in other venues. These developments, along with the U.S. Department of Education requirements that accrediting agencies must be responsive to, and seek feedback from, all of its communities of interest (including educators and practitioners), led the Commission to the conclusion that the time was right for ACAOM to seek preliminary feedback on the future role of doctoral education for the profession. The Commission believes that the timing of this survey is appropriate and justified given the current nature and tenor of the national debates over doctoral training. If any of the stakeholders in the profession need additional time to respond to the survey, that time will be given.
The Visioning Search Task Force (VSTF) process may not prohibit ACAOM from surveying or seeking feedback from the profession. The U.S. Department of Education requires that accrediting agencies be solely responsible for policy decisions that might impact accreditation standards or processes, and may not, consistent with those requirements, abdicate or delegate those responsibilities to other organizations or groups, such as a Visioning Search Task Force. Although ACAOM can and will participate in the Visioning Search Task Force deliberations, as a USDE-recognized accrediting agency, ACAOM cannot be subject to direct or indirect control relative to its policy making decisions by related professional/educational organizations/groups, or even Task Forces. The work of the VSTF and ACAOM must thus remain as entirely separate endeavors, although there can be parallel processes.
The survey is not "misleading or biased." The quotations in CCAOM's response that were excerpted from ACAOM's survey cover letter and doctoral statement were clearly taken out of context. The Commission's statement on ACAOM's willingness to "embrace" a transition to doctoral training was clearly and unambiguously stated in terms of embracing a transition to doctoral education only if there is sufficient support/consensus. Secondly, the Commission's statement clearly indicated that the Commission has not taken a position on the issue of an entry-level doctorate, but rather is merely seeking feedback from the profession on this issue. Thirdly, the survey cover letter which referenced ACAOM's "taking the initiative" and playing a "leadership role" was clearly stated in terms of the Commission's intent to explore (without taking a position) the issue of the future role of doctoral education for the profession. Finally, the CCAOM comment that ACAOM's failure to frame the issue in terms of whether the "masters or the doctorate should be the entry-level standard" constitutes bias is also in error. Educators, practitioners, licensure boards, students, professional organizations, and all other stakeholders in the profession fully understand that Master's-level education is the current entry level standard for practice and licensure. If they didn't understand this prior to reading the ACAOM statement, they would have after reading the statement, which clearly makes this point. Thus, the conclusion in the CCAOM executive committee's response that these comments reflect bias, is clearly in error.
Although the CCAOM executive committee's response asserts that the ACAOM's "proposed 10-year transitional period" for colleges to offer doctoral training is unrealistic, the Commission has not, in fact, proposed a 10-year transition period. The reference to 10 years in the Commission statement was prefaced by "e.g." ("for example") and thus the length of an actual transition period has not been articulated or proposed by the Commission. The Commission is proposing that a reasonable transition period be established, whether that be 10 years, 15 years, or some other period to allow colleges to restructure their programs without undue disruption.
Contrary to the CCAOM executive committee's response, the Commission fully intends to review the issue with "calm reflection" and "careful collective planning," and there will be no "rush to judgment." As previously noted, the Commission will be conducting a full deliberative process on this issue, will be seeking other data and information, and will take a collaborative approach with other relevant stakeholders in the field in assessing the issues.
Finally, in the absence of any evidence that there are design flaws in the survey, the Commission sees no compelling reasons to withdraw its survey as is urged by the CCAOM's executive committee, and is not inclined to do so. Such action would be inconsistent with U.S. Department of Education requirements that specify that recognized accrediting agencies must not be subject to control or undue influence by other organizations or groups. If the Commission felt that there were serious design flaws that compromised data collection, then the appropriate steps would be taken in terms of survey retrieval.
The Commission believes that rather than challenging ACAOM's right to seek feedback from the profession on questions that have been repeatedly asked relative to the future role of doctoral education for the profession, CCAOM, state and national organizations, and all other stakeholders in the field should join ACAOM in helping to review and assess these critical issues.
ACAOM Executive Committee