Craig S. Little Ed.D
President
Council on Chiropractic Education
8049 North 85th Way
Scottsdale, AZ 85258-4321
Dear Dr. Little and Members of the Council,
We are writing on behalf of a coalition of chiropractic organizations to express our concerns regarding the format and to provide specific commentary for the annual business meeting scheduled for January 10, 2025.
Inclusivity and Accessibility of Meeting Format
Firstly, we wish to address the Council’s decision to accept only oral comments during the meeting and the absence of a virtual participation option. The chiropractic community, including our coalition members, has adapted to virtual environments extensively over the past several years, especially noted during the COVID-19 pandemic when the CCE allowed many chiropractic students to complete their education online.
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Additionally, the decision to disallow written comments, as we are providing here, further limits meaningful participation and input from stakeholders. This approach seems contradictory to the assurances the CCE made to the U.S. Department of Education and the profession when it was struggling to maintain its federal recognition. The decision to allow only in-person oral comments without the flexibility of virtual or written options seems a step back from the inclusive and accessible practices that we have come to expect in modern governance and engagement.
We urge the CCE to reconsider this approach now and in the future and provide a hybrid model that accommodates both in-person, virtual, and written inputs, ensuring broader participation from stakeholders who may not be able to travel to the meeting location. These options are also crucial to ensuring all stakeholders’ concerns are expressed and documented.
Concerns Regarding Monopoly Practices and Relationships
More critically and to the main point of this letter, we are concerned about the CCE’s ongoing relationship with the National Board of Chiropractic Examiners (NBCE) and the implications this has on chiropractic education and licensure. The CCE uses NBCE exam scores as a proxy for licensure success rates in its Standards which leads to significant repercussions for chiropractic schools whose students fail to meet these benchmarks. We contest the appropriateness of this measure, given that the NBCE, like the CCE, functions as a private company and enjoys a monopoly sanctioned by state statutes and regulations.
If the Council intends to use licensure rates as a benchmark for program success, it should directly evaluate the licensure rates themselves rather than relying on scores from a private testing company that enjoys a much-contested monopoly. This is particularly pressing considering the "cozy" relationship between CCE and NBCE, which could potentially cloud objective assessment and transparency in chiropractic educational standards. The argument that NBCE Part IV is necessary because the schools can’t be trusted to evaluate competency is really an indictment against the CCE and its practices. If we need the CCE to keep the schools in check and we need the NBCE to keep the CCE and the schools in check then who keeps the NBCE in check?
Part IV Exam and Travel Requirements
We object to the NBCE's new requirement, and the CCE's support for, chiropractic students worldwide to travel to its headquarters in Greeley, Colorado to take the Part IV exam necessary for licensure in the United States. This policy not only imposes undue financial and logistical burdens on students but also seems disconnected from the practical and educational realities of modern chiropractic training. Feedback from numerous chiropractic schools indicates a clear rejection of this plan; however, the NBCE and CCE have disregarded such significant stakeholder input. We object to the CCE's support of this decision and its lack of response to the NBCE regarding schools that opposed the move during the NBCE's decision-making process. This further highlights a disconnect between these organizations and the stakeholders they claim to serve.
Notably, the medical (MD) and osteopathic (DO) professions have eliminated their Part IV examinations, relying instead on the expertise of their schools to assess clinical competency. Chiropractic schools are more than capable of performing this role, standards the CCE already evaluates during its program accreditation process. The redundancy of an external examination undermines trust in the educational institutions and imposes unnecessary burdens on students and schools alike.
Request for Reevaluation of Policies
Given these concerns, our coalition urges the CCE to:
Cease its reliance on NBCE exam scores as a proxy for licensure success in assessing educational programs and drop the Part IV requirement immediately.
Address the monopolistic dynamics between the CCE and NBCE, ensuring that educational and licensure evaluations are fair, transparent, and truly reflective of a school’s performance.
Publicly support the effort to remove “CCE Only” language from state statutes, rules and regulations.
Implement a more accessible format for its meetings that allows for both in-person, written and virtual comments.
We hope that the CCE will consider these points seriously and initiate an action plan aimed at reforming current practices that are detrimental to the chiropractic profession.
Thank you for your attention to these critical issues.
Sincerely,
Foundation for Vertebral Subluxation
International Federation of Chiropractors & Organizations
Palmetto State Chiropractic Association
Chiropractic Society of Texas
Florida Chiropractic Society
Alliance of New Mexico Chiropractors
New York Chiropractic Council
Georgia Council on Chiropractic
Sustainability Committee
MLS Seminars
On Purpose
Mile High Foundation
Mile High Seminars
Chiropractic Trust
ChiroWay
ChiroFutures Malpractice Program
McCoy Press
Waitlist Workshops
Holder Research Institute
Torque Release Technique
Dynamic Essentials
DE Lasting Purpose Foundation
Pure Chiropractic Notes
Titronics
The Institute Chiropractic - TIC
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