Advisory Committee Recommends Denial of SCASA Re-Recognition By Secretary of Education

On November 13, 1990, in Arlington, Virginia, the National Advisory Committee of the U.S. Department of Education, Office of Postsecondary Education, Accrediting Agency Evaluation Branch (AAEB) held Full Committee Hearings to determine whether to recommend the Straight Chiropractic Academic Standards Association, Inc. (SCASA) for renewal of listing as a nationally recognized accrediting agency. This would be SCASA's first renewal hearing since their initial recognition in 1988. The outcome of this hearing (and subsequent action by the U.S. Secretary of Education) would probably determine SCASA's position in accreditation for many years to come.

The hearing began as part of a very full agenda for the committee that day. The Advisory Committee did not actually address the SCASA issue until almost 5 p.m. The hearing did not end until almost 8:30 p.m.

The Advisory Committee consists of various individuals from diverse backgrounds in the field of education. They are served by a staff that conducts actual on-site observations and analysis as part of their preparation for hearings.

In this case, different members of the Committee's staff had been present for three SCASA site inspections, one at each of the three SCASA colleges: Sherman College of Straight Chiropractic (SCSC), Pennsylvania College of Straight Chiropractic (PCSC), and Southern California College of Chiropractic (SCCC). In addition, different members of the Advisory Committee staff had been observers at three of SCASA's decision-making meetings. These observation visits were conducted from August 1989 to October 1990. It was from these observed events and the documentation submitted from SCASA and other parties (both within and without the chiropractic profession) upon which the recommendation of the Advisory Committee was based.

In its written report, the Advisory staff listed one area of non-compliance:

602.14(c) -- demonstrates acceptance throughout the United States by recognized agencies.

The Advisory staff report stated that "The agency (SCASA) has not demonstrated compliance with this requirement."

The staff report also listed two areas of partial compliance, nine areas that need strengthening, and three areas which required further discussion. Two of the areas needing further discussion would ultimately prove critical in this hearing:

602.14(b) -- demonstrates its acceptance throughout the United States by licensing bodies ...

Staff reported that "SCASA has submitted evidence of acceptance of graduates of its schools by 12 state licensing bodies. However, members of two boards which SCASA claims recognizes its schools have disputed this 'acceptance'."

602.19(b) -- takes into account actions by other recognized agencies in granting initial accreditation or pre-accreditation.

Staff stated "SCASA is developing a policy pertinent to this criterion. There is a question about the extent to which the commission considered the action of another recognized agency (CCE) in its review of the Southern California College of Chiropractic."

Ultimately, the Accrediting Agency Evaluation Branch (AAEB) staff's recommendation was: "AAEB is withholding a recommendation pending receipt and review of all pertinent third-party testimony."

An oral report was given by staff analyst Joan Givens. In her report, Ms. Givens stated that "Overall, SCASA has made substantial progress since their last review." Ms. Givens report went on to review the areas of non-compliance, partial compliance, areas that needed strengthening, and areas needing further discussion.

The final portion of Ms. Givens report gave a comprehensive list of the "third party" communications and documentation that had been received and whether it was for or against SCASA's re-recognition:

Eight chiropractic colleges chose to submit written comment -- all eight stated they were against SCASA's re-recognition.

Three non-chiropractic colleges commented -- one against re-recognition, two questioned the need for two agencies.

Three educational associations commented -- one opposed SCASA's re-recognition, two requested only one agency in the chiropractic profession (please see the letter from the American Council on Education on page XXXX).

A number of letters from U.S. senators and members of congress were received; almost all asked the question, "Why does the chiropractic profession need more than one accrediting agency?" Some supported the Council on Chiropractic Education (CCE) as that one agency.

Three chiropractic state associations wrote letters -- one for SCASA's re-recognition, two opposed.

A number of individual chiropractors also wrote letters to the Advisory Committee, all of those letters opposed the re-recognition of SCASA.

Six chiropractic state licensing boards wrote letters; two opposed SCASA's re-recognition, one wanted only one accrediting agency, and three corrected SCASA's claim that SCASA graduates could be licensed in that state. SCASA initially claimed that 17 states accepted SCASA graduated for licensure. Ultimately, through four letters citing "inaccurate claims" and one testimony, the number was found to be only 13.

Additionally, the Federation of Chiropractic Licensing Boards and four national accrediting agencies opposed more than one agency for accreditation (please see page XXX for the letter from the Council on Postsecondary Accreditation).

SCASA was first to speak on its behalf. Leroy Moore, D.C., executive director; James Healey, D.C., president; Myron Brown, D.C., executive secretary of the Commission on Accreditation and Jerry Hardy, D.C. chairman of the Commission on Accreditation represented SCASA.

The SCASA panel attempted to address all of the issues raised in the staff report. Unfortunately, SCASA did not appear to have satisfied the committee on two issues:

The ability to demonstrate acceptance throughout the United States by licensing bodies and recognized agencies (602.14).

Taking into account actions by other recognized agencies in granting accreditation (602.19b). This applied specifically to SCASA's accreditation of Southern California College of Chiropractic _before_ CCE had stopped accrediting SCCC.

In addition, Dr. Healey attempted to demonstrate the need for two accrediting agencies within the chiropractic profession. In support of this position, Dr. Healey stated, "They (SCASA and CCE) are serving separate regions of the profession. They represent two portions of a profession in which two agencies are necessary."

After SCASA spoke, there was an opportunity for "third party presentations." There were five individuals speaking for SCASA's re-recognition and five speaking against.

This is who spoke for re-recognition and a short quote representing the thesis of their presentations:

William A. Volk, Ph.D., president, Pennsylvania College of Straight Chiropractic -- "Approval of SCASA is critical to maintaining the integrity of our college."

J. Scott Wilson, student at PCSC -- "Because SCASA exists, and because 'straight' exists and is growing, I chose to go there (PCSC)."

Thomas A. Gelardi, D.C., president, Sherman College of Straight Chiropractic -- "If SCASA is not re-recognized, we will lose the entire straight chiropractic profession... I'm really appreciative that the secretary of education did recognize SCASA or our college wouldn't be there."

Terry A. Rondberg, D.C., president, World Chiropractic Alliance -- "I literally beg you to consider this matter very seriously."

Douglas Gates, D.C., executive director, Federation of Straight Chiropractic Organizations (FSCO) -- "SCASA's continued recognition is vitally important to straight chiropractic colleges."

This is who spoke against re-recognition and a short quote representing the thesis of their presentations:

John L. Miller, D.C., president, Council on Chiropractic Education (CCE) -- "The issues of accreditation are educational standards."

Bruce Reyes, D.C., chairman of the Board of Chiropractic Examiners, state of California -- "SCASA policies, actions, and decisions are causing problems for the chiropractic profession in California."

D. Brent Owens, D.C., vice president, Federation of Chiropractic Licensing Boards -- "Based on the statistical information provided to us by licensing boards, it appears that only three or four states would accept SCASA graduates as candidates for licensure if USDE had not granted it initial status in 1988."

James F. Winterstein, D.C., secretary/treasurer, Association of Chiropractic Colleges -- "This non-diagnostic or ommissive position (of SCASA) relegates a person trained under these circumstances to a tertiary care level."

Louis Sportelli, D.C., immediate past chairman of the board, American Chiropractic Association -- "The best thing that ever happened to this profession is when the educational requirements of this profession were mandated by the Council on Chiropractic Education."

It should be noted, that while a representative of the International Chiropractors Association did not speak against the re-recognition of SCASA, the ICA did submit written testimony against re-recognition, and Ronald M. Hendrickson, executive vice president was present at the hearing.

After all had spoken, the Advisory Committee asked their staff for their recommendation. The staff recommendation was:

"We do not believe that they (SCASA) have met the requirements of 602.14. Based on that, we recommend that SCASA not be re-recognized."

At this point, the committee member made comments that not only concurred with the staff's view that SCASA had failed to demonstrate acceptance throughout the United States (602.14), but had also failed to take into account the actions of other recognized agencies (CCE) in their actions of accreditation (602.19b).

The committee pointed out that it was not the job of the U.S. Department of Education to recognize SCASA so that it could be accepted nationally. It is the job of SCASA to demonstrate national acceptance in order to be recognized.

The question was called, and the Advisory Committee "moved that the staff recommendation (for SCASA to NOT be rerecognized) be accepted based on violation of 602.14 and 602.19b."

The Advisory Committee voted 10 to 1 in favor of withholding re-recognition from SCASA.

What Does The Future Hold?

The Advisory Committee's recommendation will be made to Assistant Secretary for Postsecondary Education Dr. Leonard L. Haines, III. Dr. Haines will review the recommendation, and then make a recommendation to Secretary of Education Lauro F. Cavazos. If Secretary Cavazos signs this into effect, it probably won't be until sometime after the first of the year.

There is always the possibility that Dr. Haines or Secretary Cavazos will overturn the recommendation. But it is, however, unlikely.

For The Students of SCASA Colleges

Assuming that SCASA is not re-recognized, students of SCASA colleges have two options. Without being accredited by a recognized agency, students of a college cannot receive federal student loans.

In the case of Southern California, this may be academic. A new federal regulation that will go into effect in January of 1991 will make students of a college that is in bankruptcy ineligible for federal loans. In the case of Pennsylvania College, this would force the college to either seek another accrediting agency or its students would not qualify for federal loans. In the case of Sherman College, the students could only apply for certain types of loans. This is because Sherman is accredited regionally by the Southern Association.

In addition, graduates of SCASA colleges would probably only be able to be licensed in three to five states. Again, Sherman College graduates would be able to seek licensure in eight states due to regional accreditation.

Students could either:

a.) Apply to CCE colleges for transfer, or

b.) continue at SCASA colleges with restrictions on finances and licensure.

There is of course one other option. The loss of federal student loan funding will not take place (due to the presumed loss of recognition by SCASA) until the end of the term that the secretary of education actually signs the decision.

The Future of "SCASA" Straight Chiropractic

The three SCASA colleges could apply to CCE in an effort to re-unite the profession academically. In order for this to be functional, the CCE would have to keep the accreditation process focused strictly on standards, and not on philosophy.

During the questioning by the committee, CCE president, John Miller, D.C. (who is also the president of Palmer College of Chiropractic-West) made it clear that in his opinion, CCE was ready to do just that. Dr. Miller stated that "CCE will accredit Sherman (or any other SCASA college) provided they meet CCE criteria.

It is not unusual for unity to only occur when mandated by an outside agency. This is a golden opportunity for the chiropractic profession to unite academically. But, this will require both "sides" to do their part:

The SCASA colleges must meet the CCE standards for academic quality. This may take time, hopefully CCE will be in a position to grant them as much time as they need.

CCE must be prepared to consider only academic standards and not philosophy. This will require both parties to communicate well and often so that each clearly understands this difference.

The chiropractic profession IS big enough for the full spectrum of chiropractic philosophies. Now appears to be the time to bring that full philosophical spectrum under one academic umbrella.