Letter to COCA

[DO Anes]

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July 22, 2007

Konrad Miskowicz-Retz, PhD,
Secretary, Commission on Osteopathic College Accreditation
142 E. Ontario Street
Chicago, IL 60611

Dear Dr. Miskowicz-Retz:

The following are comments that I wish to be considered at the next COCA meeting, August 25/26, 2007.

Recently, the application of the Rocky Vista University, College of Osteopathic Medicine (RVUCOM) has brought to light a disturbing aspect of COCA’s accreditation standards that I believe, if not addressed, may threaten COCA’s long-term legitimacy and approval by the US Government as the accreditation agency for all colleges of osteopathic medicine. In COCA’s procedures for pre-accreditation, section 2 under “feasibility study” stipulates that the applicant for pre-accreditation must be either a non-profit or for-profit corporation (1). This is at odds with LCME standards for accreditation of allopathic medical schools, which stipulate that allopathic medical colleges should be non-profit (2). I strongly feel that COCA’s permitting for-profit medical education is an inferior difference from LCME standards that I urge you to correct with all deliberate speed.

In 1908 the AMA commissioned the Flexner Report, of which I am sure you are familiar. Abraham Flexner’s report has served as the basis for standardization and structure in American medical education, both osteopathic and allopathic, and has resulted in the high standard of training in today’s United States. Flexner was extremely critical of for-profit medical education, stating, “Such exploitation of medical education, is strangely inconsistent with the social aspects of medical practice. In modern life the medical profession is an organ differentiated by society for its highest purposes, not a business to be exploited.” (3) Because of concerns regarding the overall quality of education, all for-profit medical schools in the United States were intentionally closed by 1935. Since then, medical education has remained a non-profit enterprise, dedicated not only to the production of physicians, but also to research and expansion of the body of knowledge. Arguably, this has resulted in the remarkable standard of medical care and technology Americans enjoy today. For-profit education has remained an anathema to the medical community and has been vigorously resisted when attempted here. In 1999, Ross University, a for-profit Caribbean medical school attempted to open a branch campus in Wyoming, using the argument of Wyoming being a medically underserved state. At that time, the accreditation was to be based at the parent campus, rather than through the LCME. Despite the enthusiasm of some in Wyoming’s political and business community for this enterprise, the AMA, LCME and Wyoming Medical Society fought it as inimical to patient health and safety and below the accepted standard of the LCME (4). The venture was soundly defeated and Ross has not since ventured to the mainland US. Unfortunately, the organizers of RVUCOM learned from this experience and have come to COCA for accreditation, again using the argument of physician undersupply. My concern is this: clearly the allopathic community views for-profit education as inferior. It follows that they will view COCA’s standards as inferior. In the future, as competition for federal resources intensifies, it is not difficult to imagine a lobbying effort being made to CMS, HHS and even Homeland Security to invalidate COCA standards as inferior and rely instead on LCME for accreditation of all US medical schools, including osteopathic. This would be a devastating loss of our autonomy and would signal the ultimate demise of osteopathic medicine in the United States. Continuing in this vein, it is not difficult to foresee a time when osteopathic medicine is relegated to manipulation only, with osteopathic physicians denied reimbursement by third-party payers.

COCA must meet this potential threat and correct this flaw in our standards. Again, I urge you in the strongest possible terms to reconcile this aspect of COCA’s standards with the LCME.

I also urge COCA to withhold accreditation from RVUCOM, as I do not believe it meets even COCA’s current standards. COCA’s Standard 1.2 states, “Each COM must maintain in effect any charter, licenses or approvals required for it to function as a college of osteopathic medicine in the jurisdiction in which it operates.” (5) The Rocky Vista University College of Osteopathic Medicine, LLC, is currently listed by the Colorado Secretary of State as noncompliant of Colorado statutes regarding corporations because of failure to file its required annual report by 6/30/2007. On 7/1/2007 the Colorado Secretary of State changed RVUCOM’s status to “noncompliant” (6) Granting accreditation status to a corporation currently in violation of Colorado requirements would be, I believe, contrary to COCA standard 1.2 and, therefore, should be denied. RVUCOM also appears to be in violation of COCA standards governing schools in pre-accreditation status, as it has established a website and appears to be recruiting students. (7) The website lists details of the application process, including an e-mail address for admissions and claims accreditation from the AOA and COCA.

Thank you for your time and consideration in review of this lengthy letter. My experience in nearly 20 years of practice has repeatedly demonstrated the current high standard of osteopathic medical training and practice. This is due, in no small part, to COCA’s rigorous enforcement of educational quality. I urge you to maintain our standards, correct the issues I have addressed and protect your autonomous position as the sole accreditation body for colleges of osteopathic medicine.

Sincerely yours,


George Mychaskiw II, DO, FAAP

References:
1. COCA, COM Accreditation Standards and Procedures. Available at: https://www.do-online.org/pdf/acc_predoccom2007.pdf
2. LCME Accreditation Standards. Available at: http://www.lcme.org/functions2007jun.pdf
3. Beck AH. The Flexner report and the standardization of American medical education. JAMA 2004; 291: 2139-40.
4. Stewart A. The Regulated Doctor Shortage. Consumer Health Journal, February 2004. Available at: http://www.consumerhealthjournal.com/articles/regulated-doctor-shortage.html
5. COCA, COM Accreditation Standards and Procedures. Available at: https://www.do-online.org/pdf/acc_predoccom2007.pdf
6. Colorado Secretary of State, Business Center. Available at: http://www.sos.state.co.us/biz/BusinessEntityHistory.do;jsessionid=0000md68upMnP7PM4hY2sLCrrbk:11nm0gcsc?quitButtonDestination=BusinessEntityDetail&pi1=1&nameTyp=ENT&entityId2=20061157060&masterFileId=20061157060&srchTyp=ENTITY
7. Welcome to Rocky Vista University. Available at: http://www.rockyvistauniversity.com/index.asp

 

[drusso]

I sincerely hope that his provokes thoughtful discussion at the highest levels in our profession. BTW, you should forward this to AACOM: Stephen C. Shannon, DO, MPH, President; Michael J. Dyer, JD, Vice President for the Office of Government Relations; Sandra K. Willsie, D.O. Chair of AACOM's Board of Deans.

 

[Oasis105112]

https://www.do-online.org/index.cfm?au=D&PageId=edu_main&SubPageId=acc_main&SubSubPageId=acc_predoc

This is from the website:

"
Third Party Comments
The AOA COCA will receive, review, and consider any written or oral third-party comment in regard to an initial or continued request for accreditation, pre-accreditation, provisional accreditation, requests for substantive change, requests to establish a branch campus, or requests to enter into a teach-out agreement. Written notice must indicate to which COM the comment is addressed, and a general overview of the comments to be made. Persons wishing to present third party testimony at either meeting must provide written notice thirty (30) days prior to the meeting they wish to attend. Although, persons wishing to present third-party commentary are not required to present oral testimony; it is expected that all third-party testimony will include a written portion. The COM will be notified of the third party presentation, and receive a copy of the written comments, so that they can have an opportunity to comment. Notice of opportunity to comment will be provided with announcements of the meeting as issued in the publications of the Division of Predoctoral Education, the AOA Web site, press releases from the AOA Department of Communications, and other vehicles as may be developed."

Will you be attending?

 

[JayneCobb]

Well worded, I've sent a few emails. It will be interesting to see if our concerns are actually addressed.

 

[spicedmanna]

Kudos. This is a very well thought out and written letter. I also hope it receives good consideration. 👍

 

[toothless rufus]

It really says a lot about the powers that be in the profession that this endeavor is even being considered in the first place. This should have never even came up. If RV is successfully prevented from going forward (which I would find amazing) I doubt very much it will be because they saw the light and want to do the right thing. Which says a lot about the powers that be in the profession.

 

[group_theory]

Another suggestion that COCA can take up ...

along with closing the loop hole that allows for-profit schools to get accreditation, why not require all NEW (aka those seeking accreditation for the first time) to be accredited by a regional accreditation body prior to
application. This is the gold standard in terms of accreditation and the vast majorities of colleges are accredited by one of these regional accreditation (including all the Ivies, big research universities, small liberal arts schools, well-known liberal arts school, etc)

The Pharmacy School accrediting body (ACPE) went this route a few years back after an explosion of pharmacy schools, including some that were started from the ground up without any association with universities

The Regional Accreditation Bodies are:

• Middle States Association of Colleges and Schools
• New England Association of Schools and Colleges
• North Central Association of Colleges and Schools
• Northwest Commission on Colleges and Universities
• Western Association of Schools and Colleges
• Southern Association of Colleges and Schools

 

[DrWBD]

Excellently written letter. 👍

 

[DO Anes]

Good afternoon:
Could you please add to my previous comments:
After release of my letter to COCA regarding Rocky Vista, I noted that Rocky Vista University, LLC filed the required annual report with the State of Colorado on 7/24/07 and is now listed as in compliance. Their website has also removed information regarding academic requirements for admission and replaced it with a disclaimer clarifying their pre-accreditation status and informing interested parties that they are unable to accept applications until after accreditation, anticipated in September. I, therefore, modify my previous comments as accurate as of the date of writing, but subsequently corrected by Rocky Vista. I would still ask that COCA delay accreditation of this institution, as the website is still active as a, de facto, recruiting tool and they have complied with statutory requirements only when public commentary was made. Given the negative publicity their accreditation will bring to the profession, I think it prudent to at least look at their behavior, structure and compliance more thoroughly as they have already demonstrated a willingness to ignore established requirements.
Sincerely,
George Mychaskiw II, DO, FAAP

 

[Taus]

Check out the latest entry in the Presidents Blog:

http://blogs.do-online.org/aoapresident.php

It looks like this school will be moving ahead as planned

 

[DO Anes]

Shame on us.
Shame on this profession.
Shame on the mercenaries who have brought this dishonor upon us.
Fit for life?
How about:
Open for business.

 

[PlasticMan]

Check out the latest entry in the Presidents Blog:

http://blogs.do-online.org/aoapresident.php

It looks like this school will be moving ahead as planned

Looks like somebody's got him in their pocket...

 

[MacGyver]

Somebody explain to me why non-DOs are allowed on COCA? Thats a shame and outrage. You guys would be pissed if they had a bunch of MDs on that panel.

 

[toothless rufus]

Check out the latest entry in the Presidents Blog:

http://blogs.do-online.org/aoapresident.php

It looks like this school will be moving ahead as planned

Why am I not surprised? Yep, this puts a little (more?) tarnish on the profession. Wow, osteopathic medicine opens the first for-profit! medical school in what, 80 years? Disregards the reasons why this was curtailed in the first place, and just barrels through without giving any heed to anyone else's opinion. Are they going to change all existing schools to a for-profit status also? Seems like its all just for the $$$$. I personally am disgusted. And geez, should I be worried?

Why didn't the US gov. just make for profit schools illegal? They should not even have to do that in the first place.

 

[Doc2007]

So what will the ADCOM at Rocky Vista look at to select their students? Will it be their MCAT score and GPA or their credit history?

 

[PlasticMan]

So what will the ADCOM at Rocky Vista look at to select their students? Will it be their MCAT score and GPA or their credit history?

I think they will be given a number labeled as "ROI".

 

[Vizsla]

Check out the latest entry in the Presidents Blog:

http://blogs.do-online.org/aoapresident.php

It looks like this school will be moving ahead as planned

👎 thats very unfortunate ...i would say that I hope this will be the only DO school of its kind but i try never to underestimate the power of greed

 

[toothless rufus]

So what will the ADCOM at Rocky Vista look at to select their students? Will it be their MCAT score and GPA or their credit history?

Yeah, no doubt! I would like to think that everyone will shy away from this school, but if your choice is a for-profit school or not being a doctor at all...and it rankles because they know it!

DO Anes: Do you know what any of the other schools think about this, or how many practicing DOs are against it? Another thing that annoys me is that they apparently never even tried to address anyones concern, or give a reason as to why they decided on this embarrasing atrocity.

Also, what might the impact on the profession really be? I have to admit, this new addition to the already not insubstantial "DO Woes" has me wondering if I should be worried for my future and if I might have been better off trying to do things differently.

 

[DO Anes]

The vast majority of practicing DO's with whom I have discussed this are opposed and embarassed. When I spoke at AACOM, nearly everyone in the room said something like "thank God someone is saying the things we can't." Our leadership tried to sneak this in covertly, hoping no one would notice. Now, people are afraid to speak out because they rely on the AOA for certification, licensure, etc. Professors at other schools have been warned by their deans not to say anything because of fear of retaliation from the AOA/COCA. As an outsider who does not need the AOA for anything tangible, I am free to say what most are thinking. I am thankful that a few very brave individuals at the AOA and AACOM subtly pushed this out into the open so people like me could comment. Our leadership seems to want to go along to get along, but after all, members of the leadership of the Colorado Society and AOA Board of Trustees sit on the board of Rocky Vista. What could ultimately happen? How about the AMA and LCME pushing for the US Dept of Education to invalidate COCA as inferior? Do you think this will stop with Rocky Vista? There are a lot of Caribbean shcools out there and investors looking for opportunities.

Shame on us.
Shame on this profession.
Shame on the mercenaries who have brought dishonor upon us.
Fit for life?
How about:
Open for business.

I have advocated for osteopathic medicine my entire career of >20 years. This breaks my heart.

 

[toothless rufus]

The vast majority of practicing DO's with whom I have discussed this are opposed and embarassed. When I spoke at AACOM, nearly everyone in the room said something like "thank God someone is saying the things we can't." Our leadership tried to sneak this in covertly, hoping no one would notice. Now, people are afraid to speak out because they rely on the AOA for certification, licensure, etc. Professors at other schools have been warned by their deans not to say anything because of fear of retaliation from the AOA/COCA. As an outsider who does not need the AOA for anything tangible, I am free to say what most are thinking. I am thankful that a few very brave individuals at the AOA and AACOM subtly pushed this out into the open so people like me could comment. Our leadership seems to want to go along to get along, but after all, members of the leadership of the Colorado Society and AOA Board of Trustees sit on the board of Rocky Vista. What could ultimately happen? How about the AMA and LCME pushing for the US Dept of Education to invalidate COCA as inferior? Do you think this will stop with Rocky Vista? There are a lot of Caribbean shcools out there and investors looking for opportunities.

Shame on us.
Shame on this profession.
Shame on the mercenaries who have brought dishonor upon us.
Fit for life?
How about:
Open for business.

I have advocated for osteopathic medicine my entire career of >20 years. This breaks my heart.

Seriously, it is disheartening. So, we can expect this to be the first of many for-profit schools, probably. I am stunned that anyone would be hiding in fear of retaliation. You should never have to be afraid to speak your mind. So basically, everyone is "officially" on board. Lame.