This is a special 2 part post that includes the webinar delivered to the profession in May 2018 as well as an unabridged version of the article that appeared in the June edition of TAC.
PART 1: WEBINAR
In May 2018, ACC asked its critics to send in their questions and concerns. On the 18th May 2018, ACC held a webinar responding to these concerns. This is an edited recording of that webinar. It features Professor Hamish Coates, ACC’s Academic Board Chair; Dr Patrick Sim, interim CEO; Dr Amanda Frache, project officer (curriculum development); and is facilitated by Dr Mark Postles of the ACC’s board of directors.
PART 2: CAA LETTER TO THE EDITOR UNEDITED VERSION
As is often the case when something new or different is proposed or established there is opposition. It is also common that the opposition is lacking on facts and unfortunately suspicion and rumour can morph into ‘facts’. The ACC is very aware of a section of the profession who choose to wilfully act in ignorance of the ACC’s intent, promoting toxic views and opinions about the ACC and the people involved with its establishment. This has not made the journey any easier, however it has reinforced our resolve to pursue our cause.
The purpose of this communication is to update everyone and hopefully put to bed some of this misinformation. I would like to take this opportunity to inform you on the status of the ACC and the efforts to create the greatest possible quality in the higher education of chiropractors available in Australia. It is my hope that this letter provides clarity and information in the creation of Australia’s only private Chiropractic program.
The mission of the ACC is to create an exceptional environment for outstanding chiropractic education. In order to do this there are two critical areas to address. They are: one, satisfying Australia’s high standards for quality in higher education, and two, having enough money to begin operations. It is the former point, aka Accreditation, that is the bulk of this letter as it is a highly complex and involved process that is poorly understood by our profession.
The process of accreditation is the way in which a program is assessed for things like academic quality, student welfare, financial sustainability, and governance. It’s a complex, time consuming, and costly process, which has taken the lion’s share of ACC’s resources in achieving. Accreditation is also a very necessary process if an institution wants to ensure it is meeting the standards of higher education. Because of this, the ACC welcomes the challenge the accreditation process provides.
The Role of CBA, CCEA, and Staging
In Australia, there are two levels of accreditation: professional accreditation and government accreditation. There are 2 bodies involved in professional accreditation: the Chiropractic Board of Australia (CBA), and the Council for Chiropractic Education Australasia (CCEA). I am sure you are all familiar with the CBA as all Australian chiropractors must register with this body. It’s also the body which issues complaint notifications, write practice guidelines, and administer the Act to chiropractors. The CBA has a legislative requirement to advocate for, and protect, the public. It’s for this reason that the CBA has the final say in the approval (from a professional standpoint) of any Australian chiropractic course. According to its website, “National Boards regulating health practitioners in Australia must decide whether their accreditation function is to be exercised by an external accreditation entity or a committee established by the national board”. CBA have delegated its accreditation function to an external entity, the Council of Chiropractic Education Australasia (CCEA), which accredits all programs in the Australasian region. CCEA is well accomplished and exhibits the relevant skills and qualities necessary for its purpose.
CCEA assess programs against CBA approved standards and competencies. It then reports to both CBA and the program and supplies a list of areas for the program to improve on, as well as a time frame in which to make the improvements, and when the program’s next accreditation is due (its accreditation cycle). Programs then submit annual reports to CCEA outlining how it is improving in these areas.
You can take this loosely to mean that a program on a short cycle has much to improve on, and CCEA feels that it requires close monitoring. On the other hand, a program on a longer cycle is considered a high-quality program. For example, NZCC was awarded a five-year cycle in 2016, the greatest possible cycle. Thus, CCEA has a high degree of confidence that the program will maintain the standards for the duration of the cycle.
It’s worth mentioning that NZCC has gifted its course in entirety to the ACC. This means that the ACC will build on a foundation that already has the highest level of professional accreditation. However, accreditation does not come complimentary with the program. ACC still needs to achieve professional accreditation in its own right – a process we are undergoing as you read this.
The process of ACC to become accredited with CCEA is staged. This means that after achieving CCEA accreditation, as the ACC teaches its first group of students, CCEA will monitor and assess its progress and its ability to produce competent and safe chiropractors. The CCEA accreditation for new programs is for a period of up to three years, during which time they will monitor the development of the program and the establishment of clinical education resources. If the program meets these requirements, CCEA may extend accreditation up to the full five year phase. After which the program will be eligible to apply for re-accreditation for the normal five year cycle. Once a program is granted accreditation, the CCEA accreditation decision is reported to the CBA for their determination regarding the approval of the program as leading to registration.
The National Regulator, TEQSA
Professional accreditation, then, is a vital component in producing chiropractors. However, as important as professional accreditation is, there’s an even more important body that ACC needs to satisfy first, that is, the national regulator: The Tertiary Education Standards and Quality Agency, TEQSA.
I say it’s more important than professional accreditation because without approval from TEQSA, ACC cannot teach. In reality, both CCEA and TEQSA are vital, however, to achieve CCEA approval without TEQSA approval would not allow the ACC to take on students – the fundamental ingredient of a functioning college.
All higher education providers in Australia must be registered with TEQSA, including all Australian Universities. No Australian chiropractic program has ever been directly assessed and accredited by TEQSA. The four universities currently delivering chiropractic courses have ‘self-accrediting’ status, granted when TEQSA was established in 2011. This renders them exempt from needing to have each of their courses accredited by TEQSA, instead the university in which the program is housed is delegated the role.
The ACC does not have this luxury. ACC will need to be accredited on two levels with TEQSA: once to be registered as a Higher Education Provider, and once to have its bachelor’s course in chiropractic accredited. Once achieved, ACC will be the first chiropractic course to have physically passed over the desks of both TEQSA and CCEA ensuring the highest level of scrutiny, something we embrace and welcome.
One of the key areas that TEQSA focuses on is the personnel involved with the ACC. In this area ACC has the highest quality people from a range of backgrounds but all with outstanding higher education experience. This includes academics such as:
- Professor Hamish Coates, Tenured Professor, Tsinghua University; Deputy Director, Global Research Centre for the Assessment of College and Student Development, Tsinghua University, University of Melbourne, Melbourne Business School;
- Associate Professor Dianne Chamberlain, College of Nursing and Health Sciences, Flinders University;
- Mr Jerry Adams, Harvard Business School graduate and former interim Dean of the University of Adelaide Business School; and
- Dr Gerry Clum, former President of Life Chiropractic College West (1981-2011).
The Process Thus Far
ACC submitted its initial documentation to TEQSA in December 2016. Once TEQSA had approved the initial application, ACC moved to the substantive application process in March 2017. This process has a legislative time frame of 9 months in which TEQSA must notify the applicant of its decision. As mentioned previously, ACC has submitted two applications, one for registration as a higher education provider (HEP), and one for the accreditation of an AQF level 7 bachelor award. ACC submitted its first Self Evaluation Report to CCEA in June 2017.
In September 2017, ACC became aware of an internal issue with the regulator. This issue, which was in effect out of TEQSA’s control, resulted in TEQSA having to extended its legislated timeframe from December 31st, 2017, to June 29th, 2018. In addition, this issue also gave ACC further opportunity to expand on and clarify its initial application. In January 2018 ACC submitted a further 174 documents (close to 2000 pages) to TEQSA.
Part of TEQSA’s time extension has involved the regulator having appointed 4 new external experts to review the registration and accreditation applications. Reports from these experts will inform TEQSA as to how ACC’s applications are viewed against the national higher education standards. A case team at TEQSA will then collate these reports and make a recommendation to the TEQSA Commission about the ACC. The Commission will then make a final decision. ACC will be informed of the case teams recommendation prior to the Commission receiving the recommendation. This will give ACC an opportunity to make any final statements prior to the Commission meeting.
Given the legislative timeframe of 29th June, it is expected that this process is to be completed within the next 8 weeks.
There are two key outcomes that ACC is preparing for. The first is TEQSA approval with conditions. This would mean that ACC can begin scaling up and preparing for operations on the condition that certain milestones are met along the way. This is common for start-up HEPs.
The second outcome is the rejection of ACC’s application for registration and accreditation. In this instance, the normal course of action is to appeal the decision through the Administrate Appeals Tribunal. If this outcome should eventuate, ACC will follow this path.
In the meantime, the ACC is still heavily engaged in fund raising and reviewing and improving its documentation. Last month, ACC’s board was informed that ACC had met its second self-imposed financial target, that is to have $850,000 in reserve prior to enrolling students. The next target is a further $400,000 to ensure the college can operate through its start-up phase.
The journey to establish the ACC has been a gruelling one interposed with moments of true joy and accomplishment. In hindsight, we were very green and naïve when we set out on this process, however, even had we known what was required we still would’ve gone ahead, such is the importance of the project. No doubt the project will encounter challenges ahead but this will not deter our commitment to seeing the ACC become a reality.
Finally, The Board of Directors and I thank all the chiropractors and supportive stakeholders who have selflessly contributed to the raising of some $1.5million to date. It is a staggering accomplishment, and indicates that the NZCC/ACC brand is needed and wanted in Australia. It is a very fascinating time and I look forward updating you as soon as we hear from TEQSA.