Mark Cushing
JD
Politics & Policy columnist Mark Cushing is a political strategist, lawyer, founding partner of the Animal Policy Group and founding member of the Veterinary Virtual Care Association. Since 2004, he has specialized in animal health, animal welfare, and veterinary educational issues and accreditation. He is the author of “Pet Nation: The Inside Story of How Companion Animals Are Transforming Our Homes, Culture and Economy.”
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The American Veterinary Medical Association Council on Education is the accreditor of veterinary colleges in the United States and Canada. Until 2023, the COE’s paramount controversy involved its refusal in the early 1990s to recognize academic models utilizing distributive clinical rotations. These models rely upon practices, shelters, and the like rather than teaching hospitals traditionally associated with land-grant institutions. Distributive models were officially awarded equal status with teaching hospitals after Western University in Pomona, California, sued the AVMA. In 2013, a second distributive program appeared with Lincoln Memorial University in Tennessee, followed by the University of Arizona, Long Island University, and a hybrid program at Texas Tech.
The Controversy Surrounding the COE
Since 2023, the following seven “disruptions” have appeared on the COE’s agenda.
1. The COE Centralized Power Over Veterinary Schools
The Council on Education rolled out a series of highly prescriptive rules and rule modifications, centralizing powers over veterinary schools. Accreditation staff appeared to play an outsized role in imposing these rules.
2. Distributive-Model Approvements Became More Difficult
Responding to data showing the United States and Canada faced veterinarian shortages, many new schools launched efforts to gain accreditation. The number of aspirants did not threaten established schools, but the COE raised the bar, adopting new rules and interpreting existing rules so it was more difficult and expensive for distributive-model schools to be approved.
3. Distributive Models Persisted
Many new programs persevered, continuing to propose distributive models.
4. Online Learning Was Restricted
In March 2025, the COE announced rules restricting the ability of schools to utilize online learning technologies. Schools did not see this as a proper accreditation function, but the council fought back and gave schools four months to demonstrate compliance. These anti-online rules raise costs, attack common higher-education practices, increase the need for more faculty at schools, and are inconsistent with how new generations of students learn. They also place the COE in a role of “curriculum czar” for DVM programs.
5. LMU Filed an Antitrust Lawsuit Against the AVMA
The Council on Education declared that it intended to deny Lincoln Memorial University the opportunity to open a second campus in Florida. LMU filed an antitrust lawsuit against the AVMA, raising a fundamental question: Should a trade association charged with protecting its members’ economic interests be the accreditor of new and existing programs, and arbiter of the number of graduates?
In light of the lawsuit, the COE approved LMU’s Florida program. LMU maintained its antitrust case to resolve the question of whether the AVMA should be the profession’s accreditor. Of note, the U.S. Department of Justice Antitrust Division filed an 18-page statement of interest in the lawsuit with a rebuttal of the AVMA’s motion to dismiss LMU’s complaint.
6. Tuskegee’s Accreditation Was Challenged
We recently learned that the COE is attempting to terminate the accreditation of Tuskegee University’s School of Veterinary Medicine, and plans to severely limit Tuskegee’s ability to put on a defense in the administrative appeal. Many observers were shocked by the AVMA’s restrictions of Tuskegee’s rights. After a hearing before a federal judge in Alabama, the AVMA decided to allow Tuskegee to call its witnesses and use more than the 2½ hours originally imposed by the AVMA.
7. A Department of Education Task Force Was Formed
The U.S. Department of Education announced in late January the formation of a task force to reform accreditation practices in higher education. According to the agency’s announcement, the task force will address:
- Deregulation: The department will address regulations that impede the entry of new accreditors, reduce burdensome and duplicative requirements that hinder efficient reviews, and require accrediting agencies to enforce their standards in ways that minimize unnecessary costs and administrative burden on institutions.
- Student outcomes: The department
will establish expectations that accrediting agencies assess quality using data-driven student outcomes. - Merit: The department will revise regulations to ensure that accreditors’ standards comply with all federal civil rights laws and prohibit policies that require or facilitate discrimination on the basis of immutable characteristics.
- Integrity: The department will ensure that accrediting agencies do not mislead students with misrepresentative labels, strengthen requirements to maintain greater separation between accrediting agencies and related trade associations, and improve college affordability by reforming transfer-of-credit policies.
This initiative is slated to move rapidly. The department welcomes all parties of interest to share information, experiences, and reform ideas without fear of retribution.
The Future of Veterinary School Accreditation
Ultimately, it will be the Department of Education, not the AVMA, that determines what veterinary accreditation should look like. I anticipate that the COE’s imposition of new regulations attacking online learning will be scrutinized under the banner of minimizing “unnecessary costs and administrative burden on institutions.” The challenges raised in LMU’s lawsuit squarely fall under steps the Department of Education can take to “strengthen requirements to maintain greater separation between accrediting agencies and related trade associations.” And the American Association of Veterinary Medical Colleges’ recent highlight in its competencies-based initiatives aligns with the department’s prioritization of “data-driven student outcomes.”
The stakes couldn’t be higher for individual institutions and veterinary medicine as a whole. Some will rue this Department of Education initiative, but it is the department’s mandate to ensure that federal student loans are utilized by institutions — and recognized by accreditors — to promote the right policies and outcomes. While the Council on Education has done its business without much scrutiny in the past, its practices are now out in the open, and the animal health community has a unique opportunity to engage.
