CCE Is Leaving Federal Recognition. Now We Need to Read the Fine Print.

The Council on Chiropractic Education is preparing to withdraw from recognition by the U.S. Department of Education. That sentence sounds bigger, and probably more ominous, than the facts underneath it. CCE is not disappearing. It is not giving up accreditation of chiropractic programs. It was not stripped of federal recognition. Its board voted unanimously on July 10 to begin a voluntary withdrawal, and as of Craig Little’s recent explanation in Dynamic Chiropractic, CCE had not yet submitted formal notice to the Secretary of Education. CCE plans to continue accrediting Doctor of Chiropractic programs and remain recognized by the Council on Higher Education Accreditation.

There is another piece that matters just as much. Chiropractic students do not gain access to Title IV federal financial aid because their programs are accredited by CCE. That eligibility comes through the institutional accreditation of their colleges and universities. CCE says none of its accredited programs currently depends on CCE accreditation to access Title IV or other federal funding. That distinction makes its decision considerably easier to understand. The Department of Education is proposing additional requirements for recognized accreditors involving governance, conflicts of interest, monitoring, student outcomes and other areas. CCE’s conclusion is that complying with those requirements would add substantial burden without producing much additional benefit for the programs it accredits, their students or the public.

There is a reasonable case for that decision. If CCE’s federal recognition is not providing the pathway to federal student aid, and CCE can continue its programmatic accreditation while maintaining CHEA recognition, then it makes sense to ask what value the additional federal layer is providing to CCE. The opportunity is in what that freedom allows CCE to do: concentrate more directly on the quality of chiropractic education, the competence of graduates and how doctors should be trained. That could be a real benefit to the schools and the profession.

That is the education piece. I don’t think that is where the work ends.

Little notes that CCE has already identified four states with statutory or regulatory language that refers, in different ways, to recognition of the accreditor by the Department of Education. CCE says it is working with accredited programs, licensing authorities and other stakeholders to address those provisions. That should get the attention of every state board and every state association, including those that are not among the four.

Go read the language.

Not what we think the law says. Not what someone remembers from the last time the practice act was opened. Pull the statute. Pull the rules. Look at exactly how the educational requirement for licensure is written. If it says graduation from a CCE-accredited program and nothing about Department of Education recognition, perhaps there is nothing to do. If it ties an acceptable program to an accreditor recognized by USDE, there may be work ahead. If some other provision refers back to federal recognition in a way nobody has thought about for years, now would be a useful time to find it.

This is not particularly dramatic work. It is also much easier to do before there is a graduate sitting in front of a licensing board with an application that does not fit the words in an old statute.

The same exercise should move beyond licensing. I would want to know what the NBCE has written into its requirements. I would want specialty boards and postgraduate programs looking at theirs. What do interstate licensure arrangements say? What appears in credentialing standards? Payer manuals? Hospital bylaws? Malpractice requirements? Federal programs that recognize chiropractors? International agreements that use American chiropractic accreditation as part of their own standards?

Maybe almost all of those reviews come back clean.

Good.

The point is to know that, rather than assume it.

Over decades, references to CCE and federal recognition can find their way into documents written for entirely different purposes. Someone drafting a credentialing rule twenty years ago may have used “recognized by the U.S. Department of Education” because it was an easy way to describe an acceptable accreditor. Another organization may have copied the same language. A legislature may have written it into a practice act. Nobody did anything wrong. The language worked because CCE was federally recognized and there was never much reason to consider what would happen if it chose not to be.

Now there is.

This is where the response has to spread across the profession without turning into a free-for-all. CCE has its job. It has to manage the withdrawal, continue its accreditation work and help its programs through whatever changes are required. The schools need to make sure their students, graduates and institutional accreditation are protected. Licensing boards need to review their laws and rules. State associations should be ready to make legislative corrections where the wording no longer fits. National organizations should be looking at federal policy and the places where chiropractic credentials appear outside of education. People who work in reimbursement and credentialing should be reading the requirements used by payers and other health systems.

And then somebody has to compare notes.

Otherwise, we get fifty states and a collection of national organizations each looking at one small part of the same issue, with no clear picture of what has actually been checked. One state fixes a statute. Another discovers similar language a year later. A payer issue surfaces somewhere else. A federal reference turns up after that. We learn the structure one problem at a time.

There is no reason to do it that way.

There is also a public-facing part of this that needs attention. “CCE is withdrawing from federal recognition” can easily become “chiropractic education is no longer federally recognized.” Those statements are not the same, but the difference requires more than a sentence to explain. Most people outside higher education do not spend much time distinguishing institutional accreditation from programmatic accreditation, or USDE recognition from CHEA recognition. Little’s explanation is clear: CCE is voluntarily leaving the USDE recognition process, CCE accreditation is not what gives chiropractic institutions access to Title IV student aid, and CCE intends to continue its accreditation role.

That explanation needs to be understood well beyond CCE.

A licensing board member should be able to explain it. So should the leadership of a state association. The people representing chiropractic in a legislature should understand it before a legislator asks. If the subject comes up in a payer conversation or is raised by another healthcare organization, we should not be trying to work through the distinctions for the first time in the room.

None of that requires us to defend CCE’s decision reflexively. Over the next several years, the profession should judge the decision by what follows from it. Does CCE actually use the additional flexibility to improve accreditation? Do schools gain room to experiment with educational models while maintaining standards? Are graduates prepared as well or better? Does CHEA recognition provide sufficient outside accountability? Those are fair questions, and they should remain fair questions.

But they are different from the work directly in front of us.

CCE has changed one part of an arrangement that has existed long enough for other parts of the profession to have been built around it. Some of those connections are obvious. The four states CCE has already identified are an example. Others may be buried in a statute, a credentialing document or a policy nobody has had a reason to examine in years.

We have been given the reason.

Now we need to go read them.

Dr. Glenn Jaffe is a practicing chiropractor with more than twenty years in the profession. He served as president of the North Carolina Chiropractic Association and has worked at the national and legislative level on the profession's governance priorities. He is the founder of BoldAzure, a leadership platform for chiropractors. He writes about where the profession is, how it got there, and what maturation actually requires.

Learn more at boldazure.com