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The CCE and Section 602.13

 As has been (not so) widely reported, the National Advisory Committee on Institutional Quality and Integrity (NACIQI) of the US Department of Education met on December 14, 2011 to consider the Council on Chiropractic Education’s petition for renewal of recognition. The process of continuing the recognition of an existing agency is generally unremarkable, often requiring only 15 minutes or so of discussion.

This proceeding involving CCE was anything but routine, with four hours of public comments, agency responses, and deliberations. In the end the Department of Education staff identified over 40 compliance issues that the CCE needs to address within the next year. These areas of deficiency exceeded the norm for re-accreditation violations. Chairman Wickes referred to the quantity of citations as “an embarrassing number.” The CCE expects an official letter from NACIQI approximately 90 days from the hearing date and they expect to be granted a maximum of 12 months from the date of this document to address the identified deficiencies. The Council predicts a deadline of March 2013 to complete a compliance report to NACIQI’s committee liaison.

Following overwhelming written and oral testimony to the committee expressing concerns about the CCE from the profession at large, the NACIQI added the following statement: “In addition to the numerous issues identified in the staff report, NACIQI asks the agency to demonstrate compliance with Section 602.13 dealing with the wide acceptance of its standards, policies, procedures, and decisions; and to address how its standards advance quality in chiropractic education.”

The “wide acceptance” issue is, of course, scope and definition of chiropractic practice and whether or not to marginalize the subluxation model.

The CCE’s own Accreditation Standards as of January 2012 define chiropractic primary health care as, “care that is provided by a health care professional in the patient’s first contact within a health care system that includes an examination and evaluation, diagnosis and health management. A Doctor of Chiropractic practicing primary health care is competent and qualified to provide independent, quality, patient-focused care to individuals of all ages and genders by: 1) providing direct access, portal of entry care that does not require a referral from another source; 2) establishing a partnership relationship with continuity of care for each individual patient; 3) evaluating a patient and independently establishing a diagnosis or diagnoses; and 4) managing the patient’s health care and integrating health care services including treatment, recommendations for self-care, referral, and/or co-management.”

The IFCA website claims that “the CCE’s definition of chiropractic is clearly in violation of 602.13 as it is not widely accepted. A review of chiropractic state practice acts as listed by the Federation of Chiropractic Licensing Boards, which has been previously provided to this committee, revealed that the majority of states (41 to be exact) do not allow for chiropractors to serve the public in the broadly defined role of primary care physician. The remaining states that DO ALLOW for a broader scope of practice do not define chiropractors as being the coordinators in the public’s use of the health care system in the way the CCE standards do.”

They argue that this will make it increasingly more difficult for chiropractors to earn a living.

Naturally, there are two sides to the argument.  Some groups, like the West Hartford Group, Inc. represent what might be called the progressive side of the argument and would like to leave subluxation behind. The conservative side is represented by a coalition  which includes the Foundation for Vertebral Subluxation (FVS), the International Federation of Chiropractors and Organizations (IFCO) and the Movement for Chiropractic Quality & Integrity (MCQI). This coalition argues that the CCE misrepresents the bulk of the chiropractic profession when it marginalizes subluxation, that the CCE is attempting to turn chiropractic into medicine, and that this is in violation of Section 602.13. In other words the CCE’s position does not have the support of the majority of the profession.

And so the saga continues.

The Council on Chiropractic Education Accreditation Standards Draft for 2012

15 comments to The CCE and Section 602.13

  • dr r cohen

    “the more things change the more they stay the same” chiropractic does not need any enimies along their are chiropractors
    this never endeing battle between limited scope and broad scope dc’s I know of no other health care field whose’s practitioners try to limit the scope of practice

    as far as I am concerened if all you want to do is adjust great
    if you are trained to do more great as long as you don’t forget you are first a DC
    it”s time to stop this bs
    do unto others what they would do unto you

  • Albin

    This issue is new to me. I have been to several different chiroprators. Each has his own methods and style. I do not think limitations should be put on them. Leave them free do do what they do best.

  • Chiropractic is a science an art of correcting vertebral misalignment that causes neurological disturbance. The correction of this complex process, aka subluxation, is at the core of 70+ percent of the chiropractic practices in the US. Hopefully the USDOE will be successful in righting the educational branch of chiropractic and the CCE. As a third generation principled chiropractor, I’d like democracy (votes based on student enrollment per institution) to prevail in this inquiry.

    Yours in health,
    Trace Palmer, DC

  • Dave Cenci

    The scope of chiropractic is too limited in the majority of the states compared to the college education. For those chiropractors who wish to keep a limited scope, just continue what you have done. As a third year chiropractic student, I am for a broader scope, we are being trained to be PCP. I can also say I am not one for the term “chiropractic subluxation” and I know that many of my colleagues at my university agree.

    • Hi Dave,

      First off, congrats for making it to Year 3.

      Although there are some States that restrict Chiropractic to spinal adjusting (Michigan prevented DCs from using physiological therapeutics for eons), I’m not sure what you mean by saying that “The scope of chiropractic is too limited in the majority of the states compared to the college education.” Perhaps you could tell me what you believe being a PCP means?

      To me, it is the same as saying I am a “portal of entry” — that is, that any patient can come to me directly, without a referral from any other provider. And that IS the case in every State.

      DCs are NOT licensed to prescribe drugs (or to do surgery) anywhere, to the best of my knowledge. So, if your school is training you to prescribe, then your argument is not with our profession…it’s with the Department that regulates and writes the Scope of Practice laws for the State you want to practice in. The simple truth is that for each State, chiropractic is what the law says it is….no more, and no less.

      Tell me…what’s wrong with the term “subluxation”? Have you read the Medicare definition for what they are willing to pay us for? If you refuse to adjust to correct a subluxation, then you will not be able to bill Medicare for your patients when you adjust them.

      In reality, whether you call it joint fixation, or somatic dysfunction, or any of the dozens of terms that describe what the adjustment is meant to correct, you will soon learn from experience that there is “something” wrong with those joints, and that adjusting them helps our patients. If you choose to call it something else, it really doesn’t matter. I prefer to stick by all the DCs that came before me, and to support chiropractic research, so that eventually science will better describe whatever it is we are adjusting.

  • Hey John

    Getting fancy with Blockquotes and justification! Woo-Wooh! Way to go, my friend!

  • And so we are stuck. We will never achieve an ounce of cultural authority if we insist upon adhering to subluxation and therefore can continue to expect these kinds of outcomes. And if we abandon subluxation arguably we lose what makes us unique.
    Unfortunately, we are no closer to a solution now than we were 30 years ago.

    • Hi John

      I seriously doubt that Organized Medicine’s long term plan to crush chiropractic was based on semantics (subluxation). The anti-trust suit found them guilty solely for opposing competition, hiding behind the ruse of protecting the public.

      They could care less what we call whatever-it-is that we adjust.

      They denied us access to Federal research funds for decades, and access to MDs to design research projects. That’s we have a paltry collection of research to support what we do.

      Even so, percentage-wise, spinal manipulation has more research supporting its use than almost any other allopathic treatment.

      Cultural authority? The AMA (here in Chicago) releases 5,000 press releases per WEEK. How can a few positive studies a year stand up against that?

  • When it comes to forming a cohesive profession I don’t think we should look at it as a competition. Cultural authority, unity, respect, whatever you want to call it; eventually we will have to stop blaming external sources and admit that we need to change from within if we want to move forward.

  • Chris

    If all you do is adjust subluxations then you are a technician and not a doctor at all. It does not take 4 years to learn how to find a subluxation (or what ever you choose to call it) and then adjust it. If that’s all that you do then you practice a modality. You truely are not a Doctor of Chiropractic. The practice and therefore the education of a Doctor of Chiropractic requires more. Our patients need more.

    It does not take any training in medicine to practice wellness, but it does take more than spinal manipulation. The Doctor of Chiropractic should be a PCP who can manage a patient’s health without medicines, and can refer a patient when surgery or medicine is required.

  • Allen Margolis

    I keep reading this endless fight between straights and mixers and it’s all baloney. Chiropractors are doctors, darn-it. Start acting like one! Do whatever you think is the best and most expedient for the patient that is relying on you to solve their health issue. If you employ a limited treatment protocol that falls short for the patient you will loose that patient. If you have the ability to supply more for your patient to solve his issue he will stay with you till resolution. Patient’s do not care what your philosophical point of view is. And they do not care for an expensive “natural approach” which falls short of resolution. They just want to get well quickly and with the least amount of cost. This bickering, which is endless is ridiculous!

  • Nick Karapasas

    Upon review by the U.S. Department of Education, the concerns regarding 34 CFR 602.13 were dismissed.

    In a letter from the USDE dated 3/15/12 to the CCE regarding re-accreditation, investigation revealed that a “small minority within the profession” were presenting themselves as a majority, which led to the enhanced review by NACIQI leading up to the re-accreditation hearing.

    All of the other administrative points mentioned were listed and had to be corrected within 12 months of the date of the letter.

    As was suspected by many… the accusations against the CCE are a tempest in a teapot. The same partisan battles over semantics and power struggles within the profession by one group to eliminate the other.

    Language changes in the CCE document were, and are, supportive of ALL the mission statements of the colleges… without being partisan. As they should be…

  • steven schargel

    Dr r cohen,
    You said you know of no other health care field whose practitioners try to limit the scope of practice! I KNOW OF NO DENTIST WANTING TO INCLUDE OTHER SPECIALTIES. let the pts do pt, the acupuncturists do their thing and lets work together for the best care of the patients. WHAT IS BEST FOR THE PATIENT. NOT WHAT IS BEST FOR OUR INCOME!!! IT TAKES A LIFETIME OF STUDY TO MASTER ANY ONE HEALING ART. if you were in real need, wouldn’t you find the best practitioners in their speciality?

    • Steven,

      Nicely stated!

      You don’t see Orthopedists running vaccination clinics in malls.

      You don’t hear of IENT doctors setting fractures.

      My biggest concern is WHO is teaching these DCs about drugs. Is it an MD who teaches at a medical school, and granting them credit from that med school?

      If you believe it’s important to prescribe, then convince medical schools to provide your training and degree. That will prevent a lot of blowback in the future.

  • Nick Karapasas

    Actually, the Dentist analogy doesn’t fit. (outside of a number of DDS’s I know that practice nutrition in the functional model)

    Dentistry has multiple specialties and sub specialties… including oral pathology (mostly a “behind the microscope” field), and oral surgery (which requires an extensive training period… including a period of training in general surgery where these dentists are repairing hernias and taking out gall bladders.)

    The mistake many of us seem to make is that anyone who would do this would be doing something radically different from what *they do* in their practice.

    Either way, it has nothing to do with what the CCE is doing. If you look at what is actually written, and what they have actually done, at worst they have created an environment that allows for the individual colleges (and practitioners) to choose a model and mission statement that reflects how they choose to train and be trained as a chiropractic physician… and that is across the entire spectrum of practitioners that exists.

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