The Society for Veterinary Medical Ethics

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Message from the President-Elect for Fall 2014 Newsletter                                

From the Constitution and By-Laws of the Society For Veterinary Medical Ethics:

Article II, Sec 2(A): To encourage ethical practices and professional behavior of veterinarians and others in all aspects of the veterinary medical profession.

I received Dr. Mary Beth Leininger’s written comments to the National Advisory Committee on Institutional Quality and Integrity (NACIQI) (see her letter below). The comments reflected her direct knowledge of the inner workings of the AVMA Council on Education and are an effort to expose the deception, generation of falsified documents, the silencing of dissent among our colleagues to the United States Department of Education. The allegations are made more disturbing by a laundry list of documentation reflecting the AVMA Executive Board’s direct intrusion into the operation of Council on Education, the open hostility shown to deans of veterinary schools and other critics by the AVMA staff and the COE Executive committee.

Dr. Mary Beth Leininger, President of the AVMA 1996-1997, tireless volunteer to our national professional organization for 27 years, now joins the ranks of Dr. Bill Kay, who lead the Animal Medical Center for decades, as two veterinarians to be removed from the Council on Education for speaking out against the policies and politics of the AVMA interference with the Council on Education. Why has such democratic and civil dissent been met with ridicule by the AVMA Executive Board, Executive Director, and the administrative staff?

Dr. Al Dorn, one of the original founders of the SVME, was my surgery professor and eventually introduced me to the Society. Our profession seemed more civil then. It seems that our national association is presenting a poor example of professional and ethical behavior in this agenda.

So how did we get from there to here?  Let us know your opinion.

William Ray Folger DVM,MS,ABVP(Feline)
Memorial Cat Hospital
ABVP Feline Regent
President, Society For Veterinary Medical Ethics 2015-2017

As an elected member-at-large of the AVMA Council on Education (term 2012-2018), I am writing to comment on the Compliance Report submitted by the agency for review in December 2014. I will address my comments in the chronological order of regulations (some of which are not mentioned in the Compliance Report) and will provide as much documentary evidence as is currently available to me.

Because I am unable to access all required COE background material, I respectfully request to be permitted to submit a supplementary packet of background documentation within the next 30 days. 602.13 Acceptance of the agency by others.

This paragraph expands on my written request to make oral comments at the 11 December 2014 NACIQI meeting which dispute the agency’s claim of wide acceptance by others. At no time during the meetings of the CoE that I attended beginning in the Fall 2012, was there any agenda item, discussion or decision to reach out to the thirteen 2012 commentators and resolve the concerns that were enunciated. Both the COE chair and AVMA senior staff repeatedly and disparagingly stated that the detractors didn’t know what they were talking about and were just trying to make trouble. Attachments to come: COE Agendas October 2012, March 2013, September 2013, and March 2014.

Related to the agency’s claim that the new selection process for AVMA representatives on the COE mirrors the model of the Liaison Committee on Medical Education (LCME), the AVMA Selection Committee that was initiated, is – instead - made up of MORE insular and “insider” persons. Four of the five members of this new Committee are either members of or chosen by the AVMA Executive Board/Board of Directors, not people chosen because they are education experts. 

Attachment to come: AVMA Selection Committee document.

602.15(a)(1) Administrative and fiscal responsibilities
I understand that, because the COE is a programmatic accreditor, regulation 602.14’s requirement of “separate and independent” does not apply to the agency. However, regulation 602.15(a)(1) does require “adequate administrative staff and financial resources to carry out its accrediting responsibilities.” There are multiple examples of the agency’s failure to meet the requirements of this regulation:

1) At no time during my time on the COE has the agency discussed, reviewed, or set a budget. Instead, COE expenses and income are buried in the AVMA budget for the Education and Research Division, and the members of the agency do not have access to this information. Attachments to come: COE Minutes October 2012, March 2013, September 2013

2) The agency does not have its own dedicated legal counsel. Instead, AVMA staff counsel is called in to advise the agency on matters under discussion. However, the March 2014 minutes of the COE (provided as Exhibit 5a by the agency) do not reflect the participation of AVMA General Counsel Isham Jones.

3) Agency has no control over the number of meetings it can schedule to complete its work. (Telephone communication with COE Executive Committee member Dr John Pascoe on March 1, 2014)

4) Agency’s administrative staff is small and overburdened with responsibilities far beyond the work of the agency.

5) The agency’s lack of control over its budget, and the lack of participation of agency members in the budget process threatens the ability of the agency to prioritize its resources to fulfill its obligation under USDE regulations because volunteer and staff resources have been diverted to the inspection and accreditation of foreign schools, thereby leaving inadequate resources to review the standards and address needed improvements in the quality of veterinary education.

602.15 (a)(6) Conflict of interest
Within the agency’s response (page 4 and 5) is a detailed description of the extensive training provided to site visitors. This is in striking conflict with the perfunctory orientation that I, as a newly elected member of the COE, received in 2012: 1) I was requested to view a 40 minute video by COE members providing brief, very top-line information about new COE members’ responsibility; 2) the planned ½ day training I was to receive in advance of my first COE meeting was truncated to less than an hour; 3) repeatedly, I was told by AVMA senior staff and the COE chair that “once you go on a site visit, you’ll understand how this works.”
In addition, at no time during my orientation was there any mention that the agency was required to follow specific USDE regulations, nor were the regulations provided, explained or discussed.

602.16(a)(1)(i) Student achievement (Standard 11, Outcomes Assessment)
As mentioned on page 6 of the agency’s response, the NAVLE pass rate threshold was placed in the standard as requested by the Department. However, the Council recently altered the threshold and started to apply a complicated statistical methodology that allowed international CVMs (whose students are not required to take the NAVLE) to meet the standard. This method was widely disputed by many deans of accredited CVMs.
Attachment: While almost two dozen deans submitted letters disagreeing with the change, these letters are kept confidential by the COE and cannot be provided. Attachment to come: COE Minutes September 2013

602.16 (a)(2)Preaccreditation standards
One the first page of the December 2012 USDE Staff Report, item No. 3 indicates that the current scope of the agency’s recognitions for preaccreditation is entitled “Reasonable Assurance” and item No.4 indicates that the Department staff has made a technical change that directs the agency to title its preaccreditation status as “Provisional Accreditation.”
Regulation 602.16(a)(2) Directs the agency to permit a program receiving preaccreditation (now termed “Provisional Accreditation”) to remain in this category for no more than 5 years. However, page 593 of the document submitted by the agency (P&P section 10.1 and section 10.2) describes these two terms (Reasonable Assurance – maximum of 3 years, and Provisional Accreditation – maximum of 5 years) as different, even though page 1 of the December 2012 Staff Report indicates they are the same. These two P&P sections, taken together, demonstrate that the agency can grant preaccreditation for up to 8 years, not the 5 years stipulated in regulation 602.16(a)(2).
On May 31, 2013 and July 2, 2013, the agency granted preaccreditation via a letter of “Reasonable Assurance” (not “Provisional Accreditation” as required by the Department) to two new programs in the US, thereby failing to follow this regulation.

602.21(a)(b)(c) Review of standards
In the 2014 Compliance Report submitted by the agency, there is a scrupulous description of how standards of accreditation are reviewed in a segmented, annual process. What the agency does not describe is the disinclination, nay the impossibility, of any time being allotted during meetings of the agency for it to be self-reflective and do the very hard work of discussing and identifying changes/enhancements in the standards that may be needed for the agency to truly (as described in P&P section 4.2, Scope and Purpose: “consider[s] the interests of the veterinary profession and society at large in the review of programs.” With the amount of material agency members are expected to consider and thoughtfully review, and with the limitations of time and the agency’s inward-looking and defensive culture, it is impossible to raise questions about the overarching needs of the veterinary profession as it serves society, or even to consider how the agency could serve as a catalyst to truly improve educational outcomes.
In my experience as an insider on the COE, I have reached the disappointing conclusion that the agency is not currently capable of reviewing its standards to ensure that they are relevant to the educational needs of students. To conduct an adequate program of review, the agency must welcome the constructive criticisms of its constituencies, but COE Executive Committee and AVMA staff are openly hostile to the views of the deans, educators, schools and third parties who participated in commenting to NACIQI in 2012. Not once during my time on the COE was there an honest discussion about the criticisms that had been raised. Instead, senior AVMA staff claimed that the agency’s critics knew nothing and created a repressive atmosphere in which attempts to discuss issues raised by the critics were stifled. The agency is insular and operates with the wagons circled, thus making it institutionally incompetent to conduct a review of the standards as a whole against the backdrop of seeing how those standards truly meet the educational needs of students.

There is no open discussion of broad policy issues within the agency because the agenda is so full that there is no time to get to them. The meetings are few and far between. The meeting agendas are often sent out late and the supporting documentation may run over 1000 pages. Volumes of documents are on a back table in the meeting room, but COE members do not have the time to review them during the meetings. Nor is there time set aside when policy issues and standards can be addressed with the attention they deserve. The effect is that self-reflective analysis is lacking.

For nearly a decade, the agency has made its confidentiality rules more and more restrictive, so that not only are the accreditation actions kept confidential – as they certainly should be, but now anything and everything else related to the COE, unless it’s published, is considered “confidential.” In this manner, members of the COE supposedly are prevented from raising policy issues in front of the AVMA policy makers, including the House of Delegates, or before other constituency groups. In 2006, Dr. William Kay, one of the most highly respected leaders in our profession, was removed from the COE after he raised concerns that the agency was being pressured to grant accreditation to Western University despite the fact that its distributive model of education was not consistent with the standards. Dr. Kay had led the Animal Medical Center in New York City for decades and was intimately familiar with the weaknesses of approving a training program at Western that was not grounded in research and not subject to close monitoring by a parent institution of higher learning. His voice within the agency was silenced while Western was granted a form of provisional accreditation in violation of the agency’s procedures at the time.

I have personally experienced retaliation by the AVMA for my efforts to ensure that the agency has adequate resources to carry on its business. As the agency now devotes almost half of its volunteer resources to the inspection of foreign programs, I have raised concerns that there was not enough money, not enough volunteer time, not enough staff resources and not enough agency meeting time to address whether domestic programs met the current standards or whether those standards needed to raised in light of what today’s students need to know. This has been a hot topic within the AVMA House of Delegates, and numerous relevant constituencies have been outspoken critics. AVMA Executive Vice President Dr Ron DeHaven, who is not a member of the COE and who should not be privy to its confidential information, has been a stalwart defender of the status quo, given interviews on this subject and debated it publicly. When I raised my concerns on this issue at a Reference Committee meeting of the AVMA House of Delegates in January, 2014, I was suspended from the COE. When I refused to sign a gag order on this issue silencing me within the COE, I was expelled from the agency. My appeal to the AVMA Board of Governors is pending, but I hold little hope that I will be reinstated, even though the COE Policy and Procedure Manual contains no provision that authorizes an elected member of the COE to be removed in the middle of her term. My public comments no more violated the confidentiality of the COE’s deliberations than those of Dr. DeHaven. The difference is that I dared to question the decisions and priorities of the agency. The people who are in the best position to expose the problems of the agency’s process are those members of the COE who have witnessed it first-hand. But the overextended confidentiality rule is used to silence them.

In closing, I believe the COE and the AVMA cannot be trusted to conduct an open, fair and comprehensive program of education review, which leaves the larger issue unanswered: why isn’t the agency using the skills, knowledge, and incredible talent of its members to upgrade the competencies of veterinary graduates in our country? As the agency continues to accredit programs that are focused on entry-level clinical competence with limited exposure to a substantially science based curriculum, it degrades the important role that veterinarians play in protecting our nation from the risks of bioterrorism, many sources of which are animal based (i.e., foot and mouth disease, anthrax, Ebola). It may not be stretching the point to say that AVMA COE accreditation actions may be damaging our country’s national security interests.

Mary Beth Leininger, DVM
Executive Board, AVMA, 1995-1998
President, AVMA, 1996-1997
Council on Education, AVMA, 2012 – current ?

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