Accreditation of Colleges of Osteopathic Medicine: COM New ... · 1. Provide a copy of the Dean’s diploma from a COCA accredited college of osteopathic medicine. 2. Provide a copy

COCA COM New & Developing Accreditation Standards 2019

Page 1 of 55 COCA COM New and Developing Standards

Accreditation of Colleges of Osteopathic

Medicine:

COM New & Developing Accreditation

Standards

(Effective July 1, 2019)

Third Party Comments



Candidate Element 2.1



Candidate Element 2.1: Dean Qualifications

A proposed COM must have a dean who is qualified by education, training, and experience to

provide effective leadership in education, scholarly activity, and patient care. The dean shall have an

earned DO degree from a COCA accredited COM, medical license, board certification (at some

time in his/her career), and at least five years’ experience in academic leadership roles that include

budget management authority.

Proposed Revision:

A COM must have a dean who is qualified for the position by education, training, and experience to

provide effective leadership in education, scholarly activity, and patient care. The dean shall have:

1. An earned DO degree from a COCA accredited COM;

2. An unrestricted medical license at some time in his/her career, free of disciplinary actions or sanctions;

3. Board certification at some time in his/her career; and

4. At least five years of proven experience within the last ten years in academic leadership roles that includes budget management authority.

Candidate Submission 2.1: Dean Qualifications

1. Provide the current job description for the Dean.

2. Provide a full CV for the Dean.

3. Provide a copy of the Dean’s diploma from a COCA accredited college of osteopathic medicine.

4. Provide a copy of the Dean’s medical license.

5. Provide a copy of the Dean’s board certification documents.

Proposed Revision:


2. Provide a copy of the Dean’s most recent medical license.


4. Provide a current and complete curriculum vitae for the Dean


6. Provide the dean/physician’s most current report from the National Practitioners Data Bank



Comment

Candidate Element 2.1: Dean Qualifications, COCA proposes the following qualifications for Deans. 3. Board certification at some time in his/her career; and COUME proposes: 3. AOA/ABMS Board certification at some time in his/her career; and

Candidate Submission 2.1: Dean Qualifications, COCA proposes the following qualifications for Deans. 5. Provide a copy of the Dean’s board certification documents. COUME proposes: 5. Provide a copy of the Dean’s AOA/ABMS board certification documents.






Candidate Element 2.3: Academic and Administrative Leadership

A proposed COM must have academic and administrative leadership to accomplish the mission of

the medical school. Assistant/Associate Deans (at least one of which must be a board-certified DO)

must have proven experience in teaching, educational design and evaluation, scholarly activity, and

academic leadership in a medical education setting appropriate for the position.

Candidate Submission 2.3: Academic and Administrative Leadership

1. Provide an organization chart that shows the leadership positions and reporting relationships.

2. Provide the current job description for each member of the administrative leadership team (Associate Deans, Assistant Deans, senior level administrators).

3. Provide a full CV for each member of the administrative leadership team who has been hired (Associate Deans, Assistant Deans, senior level administrators).

4. Provide a copy of the employee’s medical license (if a DO or MD).

5. Provide a copy of the employee’s board certification documents (if a DO or MD).



Comment Candidate Element 2.3: Academic & Administrative Leadership, COCA proposes no revisions proposed to the qualifications for Academic & Administration Leadership. COUME proposes: A proposed COM must have academic and administrative leadership to accomplish the mission of the medical school. Assistant/Associate Deans (at least one of which must be an AOA/ABMS board-certified DO) must have proven experience in teaching, educational design and evaluation, scholarly activity, and academic leadership in a medical education setting appropriate for the position.

Candidate Submission 2.3: Academic and Administrative Leadership, COCA proposes no revisions to the qualifications for Academic & Administrative Leadership. COUME proposes: 5 Provide a copy of the employee’s AOA/ABMS board certification documents (if a DO or MD).






Candidate Element 3.3: Escrowed Reserve Funds

A proposed COM must demonstrate the existence of a minimum segregated, unencumbered reserve

fund escrowed until one year after graduation of the first class of students and equal to the greater

cash value of 1) $30,000,000; or 2) tuition multiplied by the approved number of students for the

COM multiplied by four years. An increase in tuition will require recalculation of the escrow

amount and an increase in the amount of the escrowed funds. The escrowed reserve fund must not

be borrowed or pledged funds and must be 100% wholly owned assets of the COM or its parent

institution.

Proposed Revision:

A proposed COM must demonstrate the existence of a minimum segregated, unencumbered reserve

fund escrowed until one year after graduation of the first class of students and equal to the greater

cash value of 1) $30,000,000; or 2) tuition multiplied by the approved number of students for the

COM multiplied by four years. An increase in tuition will require recalculation of the escrow

amount and an increase in the amount of the escrowed funds. The escrowed reserve fund must: 1)

not be borrowed or pledged funds; and 2) be funded by immediately available liquid assets that are

wholly owned assets of the COM or its parent institution. The proposed COM may not withdraw

any interest that accrues in the escrowed funds. A proposed COM must replenish the escrow fund

account in the event the value of the account decreases below the required minimum amounts stated

above.

Candidate Submission 3.3: Escrowed Reserve Funds

1. Provide a copy of the proposed Escrow Contract

2. Provide evidence of availability of unencumbered funds equal to the escrow amount.

3. Standard Element for escrow agreement



Comment Comment/ Concern: Restriction of access to interest from accrual of escrowed funds will result in unintended consequences of limitation of resources that could be applied towards the educational program for the osteopathic medical students in the new and developing Colleges of Osteopathic Medicine For example, if $50,000,000 in reserve funds are required, the potential interest until one year after graduation of the first class of students can result in approximately $1,000,000 in interest, per year ( In excess of $7x,000,000 while as the reserve funds are required to be in held two years prior to the start of the first class) that could be applied to COM operations. Access to those funds can positively impact student through facilities, faculty or equipment advancing the education of those osteopathic students.. The inability to apply these funds will unintentionally result in either decreased resources or increased tuition to cover the operations impacting student indebtedness that would otherwise have been accomplished through the interest that would accrue from the escrowed funds being applied to operations., Both of these outcomes result would negatively impact affect the ing students. It is therefore requested that the commissioners consider striking theis sentence “The proposed COM may not withdraw any interest that accrues in the escrowed funds” from the proposed revisions avoiding the impact on the osteopathic medical student in the new and developing COM.






Candidate Element 7.1: Faculty and Staff Resources and Qualifications

A proposed COM must have sufficient faculty and staff resources to achieve the program mission.

Proposed Revision:

At all educational teaching sites, including affiliated sites, a proposed COM must demonstrate that it will have sufficient faculty and clinical staff resources to achieve the proposed program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a proposed COM is unable to fill physician faculty positions with board certified or board eligible physicians, the proposed COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.

Candidate Submission 7.1: Faculty and Staff Resources and Qualifications

1. Provide the organizational chart demonstrating how the faculty will be organized.

2. Complete and submit the Faculty and Staff hiring Tables.

Proposed Revision:

1. Complete Tables 7.1a, 7.1b, and 7.1c.

2. Submit a comprehensive statement providing the justification for the proposed COM’s anticipated employment of physician faculty (both FTE and adjunct) in the patient care environment who are not board certificed or board eligible.

3. Submit the most recent and complete curricula vitae of all faculty, including adjunct faculty, if currently employed by the proposed COM.



Comment Candidate Element 7.1: Faculty and Staff Resources and Qualifications and Pre-Accreditation Element 7.1: Faculty and Staff Resources and Qualifications (CORE) I disagree with the following change “In the event a proposed COM is unable to fill physician faculty positions with board certified or board eligible physicians, the proposed COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience.” Many schools have trouble filling vacancies for faculty physicians due to a variety of factors including non-competitive salaries. By including this statement as an accreditation standard, proposed COMs can lower salaries such that physicians with board certification would be less likely to accept a position. After a period of open recruitment, proposed COMs with noncompetitive salaries can simply declare that no boarded individuals were available and can employ physicians with subjective credentials rather than objective credentials. This is a bad precedent to set, if the goal is to ensure quality education at our COMs.

Submission 7.1: Faculty and Staff Resources and Qualifications Submission 7.2: Faculty Approvals at All Teaching Sites Candidate Submission 7.1: Faculty and Staff Resources and Qualifications Candidate Submission 7.2: Faculty Appointment and Advancement I disagree that non-boarded or non-board eligible physician should be permitted to hold significant faculty positions in an academic or patient care setting. These individuals would not provide a specialty-level educational experience for the students. It is especially worrisome, that COMs can plan on employing non-board physicians for these roles even before the COM enrolls its first class.

Candidate Element 7.1: Faculty & Staff Resources & Qualifications, COCA proposes the following qualifications for Faculty & Staff. At all educational teaching sites, including affiliated sites, a proposed COM must demonstrate that it will have sufficient faculty and clinical staff resources to achieve the proposed program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a proposed COM is unable to fill physician faculty positions with board certified or board eligible physicians, the proposed COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field. COUME proposes: At all educational teaching sites, including affiliated sites, a proposed COM must demonstrate that it will have sufficient faculty and clinical staff resources to achieve the proposed program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and AOA/ABMS board certification/board eligibility. In the event a proposed COM is unable to fill physician faculty positions with an AOA/ABMS board certified or board eligible physicians, the proposed COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not AOA/ABMS board certified or board eligible based on that



physician’s demonstrated educational and clinical practice experience. All nonphysician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.

Candidate Submission 7.1: Faculty and Staff Resources and Qualifications, COCA proposes the following revisions to the qualifications for Faculty & Staff Resources and Qualifications. 2. Submit a comprehensive statement providing the justification for the proposed COM’s anticipated employment of physician faculty (both FTE and adjunct) in the patient care environment who are not board certified or board eligible. COUME proposes: 2. Submit a comprehensive statement providing the justification for the proposed COM’s anticipated employment of physician faculty (both FTE and adjunct) in the patient care environment who are not AOA/ABMS board certified or board eligible.






Candidate Element 7.2: Faculty Appointment and Advancement

A proposed COM must have clear policies and procedures in place for faculty appointment, renewal

of appointment, promotion, granting of tenure (if a tenure program exists), and remediation. The

policies and procedures must provide each faculty member with written information about his or

her term of appointment, responsibilities, lines of communication, privileges and benefits,

performance evaluation and remediation, terms of dismissal, due process, and, if relevant, the policy

on practice earnings.

Proposed Revision:

A proposed COM must have policies and procedures in place for faculty appointment, renewal of

appointment, promotion, granting of tenure (if a tenure program exists), and remediation. The

policies and procedures must provide each faculty member with written information about his or

her term of appointment, responsibilities, lines of communication, privileges and benefits,

performance evaluation and remediation, terms of dismissal, due process, and, if relevant, the policy

on practice earnings.

Candidate Submission 7.2: Faculty Appointment and Advancement

1. Provide the policies and procedures for faculty appointment and advancement.

Proposed Revision:

1. Provide a copy of the policies and procedures for credentialing and appointment, or approval of all COM faculty.

2. Submit a comprehensive and detailed statement explaining the circumstances why the COM employed any physician faculty in the patient care environment who are not board certified or board eligible.

3. Complete Table 7.2. (in summary of tables)

Table includes:

Preceptor Name

Clinical Site

Proposed # of students per rotation supervised by the preceptor

Preceptor’s status - Board cert? Board eligible

Preceptor’s discipline

Preceptor appointed or approved as faculty?

(must define appointment vs. approval)



Comment Candidate Submission 7.2: Faculty Appointment and Advancement, COCA proposes the following revisions to the qualifications for Faculty Appointment & Advancement 2. Submit a comprehensive and detailed statement explaining the circumstances why the COM employed any physician faculty in the patient care environment who are not board certified or board eligible. 3. Complete Table 7.2. (in summary of tables) Table includes: Preceptor Name Clinical Site # of Students per rotation supervised by the preceptor Preceptor’s status - Board cert? Board eligible Preceptor’s discipline Preceptor appointed or approved as faculty? (must define appointment vs. approval) COUME proposes: * Submit a comprehensive and detailed statement explaining the circumstances why the COM employed any physician faculty in the patient care environment who are not AOA/ABMS board certified or board eligible. * Complete Table 7.2. (in summary of tables) Table includes: Preceptor Name Clinical Site # of Students per rotation supervised by the preceptor Preceptor’s status - AOA/ABMS Board cert? Board eligible Preceptor’s discipline Preceptor appointed or approved as faculty? (must define appointment vs. approval)



Pre-Accreditation Element 1.1



Pre-Accreditation Element 1.1: Program Mission (CORE)

A College of Osteopathic Medicine (COM) must produce and publish a written mission statement

for the program that explains the overall purpose of the program and serves as guide for program

planning and assessment. If the COM is part of a larger educational institution or parent institution,

the COM’s mission shall be consistent with the institution’s mission. The COM must review the

program mission periodically and revise it as appropriate, including faculty and students, at a

minimum, in the process.

Proposed Revision:

A COM must have a mission statement that: 1) explains the overall purpose of the COM’s program;

and 2) serves as guide for program planning and assessment. Where the COM is part of a larger

educational institution or parent institution, the COM’s mission must be consistent with the

institution’s mission. The COM must review its program mission periodically and upon review, if

the COM deems it to be appropriate to do so, the COM should revise its mission to meet the

COM’s growth and continued development. The COM must consider the input of its faculty, staff,

and students when reviewing and revising its mission.

Pre-Accreditation Submission 1.1: Program Mission

1. Provide the public link where the COM'copies of the COM’s program mission, vision (optional), goals or objectives (optional) and a public link to where the documents are published.

2. If the COM is part of a larger educational institution (parent institution), provide a copy of the parent institution’s mission statement. The documents should show last updated date (or effective date) and revision history.

3. Provide documentation of the revision process for the COM’s mission.

Proposed Revision:

1. Provide the public link where the COM’s mission is published. This link may also include the COM’s vision, goals, or objectives.

2. If the COM is part of a larger educational parent institution, provide a copy of the most recently updated parent institution’s mission statement. The documents should reflect the date(s) of each prior revision to the institution’s mission statement.

3. Describe the COM’s process of revising its mission statement and submit the documentation that supports the description.



Comment Pre-Accreditation Submission 1.1: Program Mission The proposed change in the language used for the document - Accreditation of Colleges of Osteopathic Medicine: COM Continuing Accreditation Standards (Effective July 1, 2019) – should be reflected in this document. I recommend the following revision: 3. Provide documentation of review of the COM mission along with the revision process (if applicable), participants, and meeting minutes documenting the most recent governing board approval of the COM’s mission.






Pre-Accreditation Element 2.1: Dean Qualifications (CORE)

A COM must have a dean who is qualified by education, training, and experience to provide

effective leadership in education, scholarly activity, and patient care. The Dean shall have an earned

DO degree from a COCA accredited College of Osteopathic Medicine, medical license, board

certification (at some time in his/her career), and at least five years’ experience in academic

leadership roles that include budget management authority.

Proposed Revision:

A COM must have a Dean who is qualified for the position by education, training, and experience to

provide effective leadership in education, scholarly activity, and patient care. The Dean shall have:

1. An earned DO degree from a COCA accredited COM;

2. An unrestricted medical license at some time in his/her career, and free of disciplinary actions or sanctions while licensed;

3. Board certification at some time in his/her career; and

4. At least five years of proven experience within the last ten years in academic leadership roles that includes budget management authority.

Pre-Accreditation Submission 2.1: Dean Qualifications


2. Provide a full CV for the Dean.


4. Provide a copy of the Dean’s medical license.


Proposed Revision:


2. Provide a copy of the Dean’s most recent medical license.


4. Provide a full curriculum vitae for the Dean


6. Provide the dean/physician’s most current report from the National Practitioners Data Bank



Comment Pre-Accreditation Element 2.1: Dean Qualifications (CORE), COCA proposes the following revisions to Dean Qualifications. 3. Board certification at some time in his/her career; and COUME proposes: 3. AOA/ABMS Board certification at some time in his/her career; and

Pre-Accreditation Submission 2.1: Dean Qualifications, COCA proposes the following qualifications for Deans. 3. Provide a copy of the Dean’s board certification documents. COUME proposes: 3. Provide a copy of the Dean’s AOA/ABMS board certification document






Pre-Accreditation Element 5.1: Professionalism (CORE)

A COM must ensure that the learning environment of its osteopathic medical education program is

conducive to the ongoing development of professional behaviors in its osteopathic medical students,

faculty, and staff at all locations and is one in which all individuals are treated with respect. This

should also include exposure to aspects of patient safety, cultural competence, and interprofessional

collaborative practice.

Proposed Revision:

A COM must ensure that the learning environment of its osteopathic medical education program is

conducive to the ongoing development of professional behaviors in its osteopathic medical students,

faculty, and staff at all locations and is one in which all individuals are treated with respect.

Pre-Accreditation Submission 5.1: Professionalism

1. Provide a copy of all professionalism policies. The professionalism policies should extend to items including, but not limited to, patient safety, cultural competence, and interprofessional collaborative practice.

2. Provide a link to where the documents are published.

3. Provide a copy of the membership of any professionalism committee and a copy of the charge or purpose of the committee.

Proposed Revision:

1. Provide a public link to where the professionalism documents are published.

2. Include the membership of the committee that addresses issues of professionalism and ethics.

3. Provide a published description and charge of the committee that addresses issues of professionalism and ethics.



Comment Pre-Accreditation Submission 5.1: Professionalism Please clarify the proposed revision below. Does this mean that the membership of the committee should be posted publically or just provided to COCA? If the membership needs to be posted publically then consider the following revision: 2. Provide a public link to Include the membership of the committee that addresses issues of professionalism and ethics.






Pre-Accreditation Element 6.6: Principles of Osteopathic Medicine (CORE)

A COM must provide each student, in each year of the curriculum, with opportunities for learning

Osteopathic Principles and Practice (OPP), including both observation and hands-on application of

osteopathic manipulative medicine (OMM) supervised by COM credentialed physicians (DO or

MD).

Pre-Accreditation Submission 6.6: Principles of Osteopathic Medicine

1. Complete the curricular elements table demonstrating where this element will be introduced, continue to be taught, and assessed throughout the osteopathic medical education curriculum.

Proposed Revision:

1. Provide a description of the COM’s delivery of its curriculum including opportunities for learning osteopathic

principles and practice (OPP), including both observational and hands-on application of osteopathic

manipulative medicine (OMM). Not to exceed a maximum of 250 words.

2. A curriculum map demonstrating how the content of these courses is delivered must be made available during

any site visit.



Comment Pre-Accreditation Submission 6.6: Principles of Osteopathic Medicine Recommend revision to reflect the policy: 1. Provide a description of the COM’s delivery of its curriculum including opportunities for learning osteopathic principles and practice (OPP) in each year of the curriculum, including both observational and hands-on application of osteopathic manipulative medicine (OMM). Not to exceed 250 words.






Pre-Accreditation Element 6.10: Clinical Experience

A COM must ensure that each student participates in one or more required third year clinical

clerkship experiences conducted in a health care setting in which the student works with resident

physicians currently enrolled in an accredited program of graduate medical education. In addition to

the above expectation, a minimum of one required third year clinical clerkship must be completed

under the supervision of an osteopathic physician and a minimum of one required third year clinical

clerkship must be completed in an inpatient facility.

Pre-Accreditation Submission 6.10: Clinical Experience

1. Complete and submit the Clinical Affiliation Agreement Table.

2. Provide a copy of all signed clinical affiliation agreements.

3. Provide a copy of all signed preceptor applications/ agreements.

Proposed Revision:

1. Complete and submit Table 6.9



Comment Pre-Accreditation Element 6.10: Clinical Experience I recently completed a retrospective study investigating the OMM practice patterns of 3rd and 4th year students as documented by the ATSU-KCOM required OMM Practice Logs. These practice logs documented 30 supervised OMT treatments that each student completed during their 3rd and 4th years. Over 10,000 practice treatments were reviewed. Data included whether the OMT involved a clinical or volunteer patient and whether it was supervised by an MD or DO. Third years students performed OMT on clinical patients significantly more often than fourth year students and MDs supervised the OMT significantly more often for fourth year students than for third year students. This data is currently in final review for publication in JAOA. I believe this data is a direct reflection of the following COCA requirement: “a minimum of one required third year clinical clerkship must be completed under the supervision of an osteopathic physician”. Given the marked increase in the number osteopathic physicians in practice over the past decade, I recommend the following revision: “a minimum of one required third year and one fourth year clinical clerkship must be completed under the supervision of an osteopathic physician”






Pre-Accreditation Element 7.1: Faculty and Staff Resources and Qualifications (CORE)

At all educational teaching sites, including affiliated sites, a COM must have sufficient faculty and staff resources to achieve the program mission, including part time and adjunct faculty, who are appropriately trained and degreed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/ board eligibility. The non-physician faculty must have appropriate qualifications in their fields.

Proposed Revision:

At all educational teaching sites, including affiliated sites, a pre-accredited COM must have sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.

A candidate COM applying for pre-accreditation must have a pro forma plan for sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.

Pre-Accreditation Submission 7.1: Faculty and Staff Resources and Qualifications

1. Provide the organizational chart demonstrating how the faculty will be organized. Indicate (highlight) any

changes or updates since the initial submission.

2. Complete and submit the Faculty and Staff Hiring Tables. (Tables 7a and 7b)

Proposed Revision:

1. Provide the organizational chart demonstrating how the faculty will be organized. Indicate (highlight) any changes or updates since the initial submission.

2. Complete the Faculty and Staff Hiring Tables. (Tables 7a and 7b)

3. Submit a comprehensive statement providing the justification for the COM’s employment of physician faculty (both FTE and adjunct) in the patient care environment who are not board certified or board eligible.



4. Submit the most recent and complete curricula vitae of all faculty, including adjunct faculty.

Comment Pre-Accreditation Submission 7.1: Faculty and Staff Resources and Qualifications and Pre-Accreditation Submission 7.2: Faculty Approvals at All Teaching Sites I disagree that non-boarded or non-board eligible physician should be permitted to hold significant faculty positions in an academic or patient care setting. These individuals would not provide a specialty-level educational experience for the students. If COCA allows non-boarded general practitioners to be required core rotation preceptors, then general practitioners would be acceptable as faculty in this role.

Pre-Accreditation Element 7.1: Faculty & Staff Resources & Qualifications, COCA proposes a and the following qualifications for Faculty & Staff Resources & Qualifications. At all educational teaching sites, including affiliated sites, a pre-accredited COM must have sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field. A candidate COM applying for pre-accreditation must have a pro forma plan for sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field. COUME proposed: At all educational teaching sites, including affiliated sites, a pre-accredited COM must have sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and AOA/ABMS board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with AOA/ABMS board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not AOA/ABMS board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.



(Continuation of comment above) A candidate COM applying for pre-accreditation must have a pro forma plan for sufficient faculty and clinical staff resources to achieve the program mission, including part time and adjunct faculty, and preceptors who are appropriately trained and credentialed. The physician faculty, in the patient care environment, must hold current medical licensure and AOA/ABMS board certification/board eligibility. In the event a COM is unable to fill physician faculty positions with AOA/ABMS board certified or board eligible physicians, the COM may, under exceptional circumstances and upon good cause, employ physician faculty who are not AOA/ABMS board certified or board eligible based on that physician’s demonstrated educational and clinical practice experience. All non-physician faculty must have demonstrated, appropriate qualifications in his/her disciplinary field.

Pre-Accreditation Submission 7.1: Faculty and Staff Resources and Qualifications, COCA proposes the following qualifications for Faculty and Staff. 3. Submit a comprehensive statement providing the justification for the COM’s employment of physician faculty (both FTE and adjunct) in the patient care environment who are not board certified or board eligible. COUME proposes: 3. Submit a comprehensive statement providing the justification for the COM’s employment of physician faculty (both FTE and adjunct) in the patient care environment who are not AOA/ABMS board certified or board eligible.



Pre-Accreditation Submission 7.2: Faculty Approvals at All Teaching Sites, COCA proposes the following qualifications for Faculty Approvals at Teaching Sites. 2. Submit a comprehensive and detailed statement explaining the circumstances why the COM employed any physician faculty in the patient care environment who are not board certified or board eligible. 3. Complete Table 7.2. Table includes: Preceptor Name Clinical Site # of Students per rotation supervised by the preceptor Preceptor’s status - Board cert? Board eligible Preceptor’s discipline Preceptor appointed or approved as faculty? (must define appointment vs. approval) COUME proposes: 2. Submit a comprehensive and detailed statement explaining the circumstances why the COM employed any physician faculty in the patient care environment who are not AOA/ABMS board certified or board eligible. 3. Complete Table 7.2. Table includes: Preceptor Name Clinical Site # of Students per rotation supervised by the preceptor Preceptor’s status - AOA/ABMS Board cert? Board eligible Preceptor’s discipline Preceptor appointed or approved as faculty? (must define appointment vs. approval)






Pre-Accreditation Element 7.3: Department Chair Qualifications

A COM must employ (have under contract prior to the granting of Pre-accreditation Status)

Department Chairs, or their equivalent, with proven experience in teaching and academic leadership

in a medical education setting. For clinical department chairs, the chair must have an active medical

license and active board certification in the discipline in which they serve as chair.

Pre-Accreditation Submission 7.3: Department Chair Qualifications

1. Provide the organizational chart demonstrating the reporting hierarchy for each department.

2. Provide the current job description and complete CV for each Department Chair or its equivalent.

3. Provide a complete CV for each Department Chair or its equivalent.

4. For each clinical department chair, provide a copy of the Chair’s medical license.

5. For each clinical department chair, provide a copy of the Chair’s board certification documents.



Comment Pre-Accreditation Submission 7.3: Department Chair Qualifications, COCA no revisions: COUME proposes: 2. For each clinical department chair, provide a copy of the Chair’s AOA/ABMS board certification documents.






Pre-Accreditation Element 7.4: Primary Care Leadership

A COM must employ a Doctor of Osteopathic Medicine with an active medical license and active

board certification from a primary care discipline to serve as the Department Chair of Primary Care

(or equivalent). If the COM does not have an organized Department of Primary Care, the

Department Chair of either Family Medicine or Internal Medicine or Pediatrics must be a Doctor of

Osteopathic Medicine with active board certification.

Pre-Accreditation Submission 7.4: Primary Care Leadership

1. Provide a copy of the job description for the Chair of Primary Care (or equivalent).

2. Provide a complete CV for the Chair of Primary Care (or equivalent).

3. Provide a copy of the Chair’s medical license.

4. Provide a copy of the Chair’s board certification documents.



Comment Pre-Accreditation Element 7.4: Primary Care Leadership, COCA proposes no revisions to the qualifications for Primary Care Leadership. COUME proposes: A COM must employ a Doctor of Osteopathic Medicine with an active medical license and active AOA/ABMS board certification from a primary care discipline to serve as the Department Chair of Primary Care (or equivalent). If the COM does not have an organized Department of Primary Care, the Department Chair of either Family Medicine or Internal Medicine or Pediatrics must be a Doctor of Osteopathic Medicine with active board certification.

Pre-Accreditation Submission 7.4: Primary Care Leadership, COCA proposes no revisions COUME proposes: 4. Provide a copy of the Chair’s AOA/ABMS board certification documents.






Pre-Accreditation Element 7.5: OMM/OPP Leadership (CORE)

A COM must employ a Doctor of Osteopathic Medicine with an active medical license and active

board certification from the American Osteopathic Board of Neuromusculoskeletal Medicine

(AOBNMM) or a Certificate of Special Proficiency in OMM (C-SPOMM) to serve as the

Department Chair of OMM/OPP, or equivalent.

Note:

The COCA has received a request from the American College of Osteopathic Family Physicians

(ACOFP) to revise this element to permit physicians other than those listed in this element to be

eligible for chair leadership positions. At the December, 2018, meeting, the COCA received oral

comments from the ACOFP, the Educational Council on Osteopathic Principles, the American

Academy of Osteopathy, and the American Osteopathic Association Bureau of Osteopathic

Specialties. The COCA will take those comments into consideration, along with any other public

comments that may be received to fashion a proposed revision, if any is to be made.

Pre-Accreditation Submission 7.5: OMM/OPP Leadership

1. Provide a copy of the job description for the Chair of OMM/OPP (or equivalent).

2. Provide a complete CV for the Chair of OMM/OPP (or equivalent).

3. Provide a copy of the Chair’s medical license.

4. Provide a copy of the Chair’s board certification documents.



Comment "Pre-Accreditation Element 7.5: OMM/OPP Leadership (CORE) A COM must employ a Doctor of Osteopathic Medicine with an active medical license and active board certification from the American Osteopathic Board of Neuromusculoskeletal Medicine (AOBNMM) or a Certificate of Special Proficiency in OMM (C-SPOMM) to serve as the Department Chair of OMM/OPP, or equivalent. Note: The COCA has received a request from the American College of Osteopathic Family Physicians (ACOFP) to revise this element to permit physicians other than those listed in this element to be eligible for chair leadership positions. At the December, 2018, meeting, the COCA received oral comments from the ACOFP, the Educational Council on Osteopathic Principles, the American Academy of Osteopathy, and the American Osteopathic Association Bureau of Osteopathic Specialties. The COCA will take those comments into consideration, along with any other public comments that may be received to fashion a proposed revision, if any is to be made." I do have some significant concerns in allowing those without NMM board certification to be chairs at osteopathic medical schools. While I agree, that there is a need for further OMM education and that those boarded by ACOFP, specifically, can fill in nicely as faculty in an OMM department, I do not believe they should have the ability to chair those departments. I feel I am uniquely qualified to speak to this topic, as I was a family practitioner who used OMM quite frequently, who went back to do an NMM/OMM fellowship after being in practice for some time. As a family practitioner, only educated by my medical school and using OMM in the clinics in which I worked, I was definitely adequate but without the formal training offered by an NMM/OMM fellowship, my skills absolutely needed improvement to be at a level where the boards of the AOBNMM require them to be. As a professor at a new COM in the OMM department we see a wide range of level of skills in our own students. Extrapolate that out for many more years of training and with the proposed changes, anyone boarded by ACOFP, however inadequate in their own skills, could be the OMM department chair. I do realize that the argument is that both bodies, those boarded by AOBNMM and ACOFP/AOBFP both have “practicals” in which they demonstrate their OMM skills. Having just taken my NMM boards, I can definitely say that the skill level required to be boarded by the AOBNMM compared to the AOBFP is significantly higher. As I am a firm proponent of quality education, I do not want future osteopathic physicians, who represent me to have a poorer education than what I had because we allowed someone without as much training to be chair of the OMM department. The board exam the members of ACOFP endure are nothing compared to the boards required by the AOBNMM. I specifically remember my own OMT portion of my family practice boards where we were encouraged NOT to actually treat our partners. How can we allow someone who potentially has never performed cervical HVLA to be in charge of teaching it to students? How can be allow someone who knows the theory but doesn’t have the hands on skills to actually be effective in OMM treatment. While I certainly believe that there are many out there who do have the skills to be successful in treating their own patients in their own clinics, under their own AOBFP board certification, I do not believe that translates to the ability to effectively lead and guide students in a leadership manner of an OMM department. Quite frankly, the skills set will definitely be inadequate compared to the members boarded by the AOBNMM. This is like saying that because I have read many EKGs in my own practice, and made decisions on how



(Continuation of comment above) to treat based on what I find that I am qualified to be the chair of cardiology in either a hospital setting or an academic setting. I certainly can teach those students, how to interpret EKGs but do not consider myself competent to to take them to the Cath lab for definitive treatment. Please give significant thought to these proposed changes as I can only see detrimental costs to our own medical students and colleges of osteopathic medicine in the future, if this is allowed to occur. Thank you for your time.



In response to the proposed revision, specifically in address to that listed below: "Pre-Accreditation Element 7.5: OMM/OPP Leadership (CORE) A COM must employ a Doctor of Osteopathic Medicine with an active medical license and active board certification from the American Osteopathic Board of Neuromusculoskeletal Medicine (AOBNMM) or a Certificate of Special Proficiency in OMM (C-SPOMM) to serve as the Department Chair of OMM/OPP, or equivalent. Note: The COCA has received a request from the American College of Osteopathic Family Physicians (ACOFP) to revise this element to permit physicians other than those listed in this element to be eligible for chair leadership positions. At the December, 2018, meeting, the COCA received oral comments from the ACOFP, the Educational Council on Osteopathic Principles, the American Academy of Osteopathy, and the American Osteopathic Association Bureau of Osteopathic Specialties. The COCA will take those comments into consideration, along with any other public comments that may be received to fashion a proposed revision, if any is to be made." While I agree, that those boarded by ACOFP can perform the role of faculty in an OMM department, I have significant concerns in allowing those without NMM board certification to be chairs at osteopathic medical schools. At this point in my career my definition of OMM is hands-on treatment of the bones, joints, muscles, fascia, nerves, blood vessels, lymphatics and viscera in order to improve physiologic function. This is a much more expansive and comprehensive definition than I had ten or even five years ago. This definition of osteopathy has evolved through countless hours of practice in OMM residency, OMM clinics and dozens of OMM continuing medical education courses. The average ACOFP certified physician may not fully comprehend my definition of OMM, much less have the ability to demonstrate and teach it, as their resume would pale in comparison to the type of manipulation experience that NMM board certified physicians possess. Only after this depth and breadth of experience can one begin to employ the degree of analysis, organization, and attention to detail that must be afforded when developing and implementing an OMM curriculum. These attributes are directly proportional to the department chair's ability to convey complex and often enigmatic concepts and skills to medical students and faculty alike. As the leader of an OMM department that employs a number of talented ACOFP boarded family physicians I can tell you that none of them feels ready to lead the OMM department. This is the case despite the fact that each of them has practiced for a number of years and incorporates manipulation into their practice. This is a precarious time for the osteopathic profession and diluting OPP departments at the chair level will significantly depreciate the value of NMM board certification, decrease the quality of osteopathic medical education for our students and have deleterious effects on our profession as a whole. As we hit the mid-way point of the merger and are surrounded by changes in osteopathic residency accreditation, board certification and continuing medical education, it is important to showcase our osteopathic distinctiveness and maintain the highest quality of OMM training in our COMs. To allow lesser trained physicians to direct the OMM curriculums at COMs would be the fastest way to have our uniqueness snuffed out by the much larger, and more powerful LCME, and USMLE. This scenario should not seem far-fetched as all post graduate training will be controlled by the ACGME within the next two years giving the allopathic training model a great degree of leverage and influence over medical education in general. Furthermore, if we truly cannot find adequate numbers of qualified NMM faculty for the chair positions at COMs, then maybe it is time to consider slowing the growth of osteopathic schools, and curbing the expansion of osteopathic education. What is the difference between the MD and DO education anyway? Is it really a good history, or "patient-centered care," or lifestyle changes or preventative care? I would argue that the osteopathic profession does not have a monopoly on any of these, and that the real tangible difference in our education is manipulative care. Without this element osteopathic and allopathic education is essentially just the same and we as a profession are caught hiding behind carefully crafted slogans, catch phrases and advertising campaigns. As a profession it is time to stand up and demonstrate, celebrate, and cultivate OMM as a distinctive difference in our osteopathic education. We need the experts in OMM as department chairs- leading and teaching in the COMs-in order to accomplish this goal. Certainly, this is not the time to replace the New York Philharmonic with the high school band.



Pre-Accreditation Element 7.5: OMM/OPP Leadership (CORE) The inclusion of the “Note” following the criteria for OMM leadership serves no purpose within the accreditation document and should be removed from the final document. As far as changing the language of Element 7.5, any proposed revisions need to be put forth for public comment. While many physicians have been trained in osteopathic manipulative medicine throughout their training and careers, only specialists in osteopathic neuromusculoskeletal medicine/osteopathic manipulative medicine (NMM/OMM) received the required training as defined by post-graduate specialty training requirements, specialty board assessment, and recertification that included the full range of osteopathic manipulative techniques covered in the AACOM and NBOME osteopathic core competency documents. I recommend continued requirement of the OMM Leadership to have active board certification from the American Osteopathic Board of Neuromusculoskeletal Medicine (AOBNMM) or have received a Certificate of Special Proficiency in Osteopathic Manipulative Medicine (C-SPOMM) to serve as the Department Chair of OMM (or equivalent). The changes now occurring at AOA regarding the removal of OPP/OMM from all board certification exams except NMM/OMM further illustrates the importance of AOBNMM certification as the necessary prerequisite for this leadership position.






Proposed New Text:

Element 12.7: Campus Security (CORE)

A COM must provide comprehensive information through a public link about its campus security to

its students, faculty, staff, and to the public at large.

Proposed New Text:

Pre-accreditation Submission 12.7: Campus Security (CORE)

1. Provide the public link where the COM’s annual security report will be published.

2. Provide the public link where the COM’s campus security policies are published



Comment Element 12.7: Academic Freedom Pre-Accreditation Element 12.10: Academic Freedom I recommend the following revision in order to provide consistency with the required evidence submission: A proposed COM must develop policies regarding academic freedom evidencing a commitment to academic freedom, intellectual freedom, freedom of expression, and respect for intellectual property rights the proposed COM intends make publicly available. All such policies must be approved by the proposed COM’s governing board.



Other



Comment Since the beginning of the ACGME merger, I have feared the loss of residency opportunity for future Osteopathic physicians in convenient locations near their homes and loss of exposure to Osteopathic Family Medicine (my specialty of choice which I fell in love from my role models prior to even applying to medical school). Our largest hospital dissolved it’s family medicine residency and after many years, I no longer teach. Few students in my area have opportunities to be mentored by Family Physicians or even be exposed to my specialty as a career choice since their training is becoming more and more overrun by internal medicine specialists. Furthermore, with the rising practice of midlevel extenders I am fearing that perception of the specialty of Osteopathic Family Medicine will loose credibility as the differences get blurred since more and more Family Physicians are being discouraged from hospital medicine as our training programs and hospital practice patterns continue to shift away from hospital medicine. My other fear is for the survival of our Osteopathic organizations noting that as the future physicians graduate from ACGME programs and are mentored by allopathic physicians, many will not maintain certification and licensure from Osteopathic organizations, and our conference attendance will drop. After many years of disheartening national meetings watching my fears become reality, I am attending fewer national meetings and even reducing my local conference activities since in the past I earn many more CME credits than I needed and my usefulness on committees is reduced since I no longer have teaching opportunities as Osteopathic Family Medicine seems to be discouraged from our hospital residency programs. As my wife reminded me over the last few years, if I walk out of the meetings upset and frustrated, why am I putting myself through this? I hope one day our Osteopathic leadership will begin to understand effects of what has happened and will take an active role in returning our profession to promote our unique capabilities as Osteopathic Physicians to serve our patients rather than blur our differences between allopathic physicians, physician assistants, and nurse practitioners.

Where is “Candidate Submission 6.6: Principles of Osteopathic Medicine”? Proposed COMs should be required to submit a plan for its curriculum to include opportunities for learning osteopathic principles and practice (OPP) in each year of the curriculum.

Please ask for evidence of the dean and associate deans are actually living in the town they propose to Start a school.



I was looking through this briefly and first of all, would like to thank you for all the time you must spend trying to read this all line by line. Thank you for the time and efforts you all are giving for our profession. On a separate note, does any of this involve re-accredation? I looked through the highlighted documents and didn't see any of that - I'm not sure if I missed it or if these changes are just for initial accreditation. I would like to state that I think the reaccreditation process should be extended to 10 years. I feel that OCC is just a money maker on your part, not any benefit to physicians or ongoing learning. It takes a great deal of time to thumb through charts and pull out the best data to prove we are doing a good job - which may or may not be the case. I believe that intermittent patient surveys and a 10 year test are adequate. Or even better, after 2 rounds of re-accreditation, eliminate the test and Grandfather in the physicians so no re-test would be necessary. I do agree that CME requirements are helpful to get updates.

Documents

Accreditation of Colleges of Osteopathic Medicine: COM New ... · 1. Provide a copy of the Dean’s diploma from a COCA accredited college of osteopathic medicine. 2. Provide a copy