1. International Mobility Recent Events and Actions

2. FCLB Language The FCLB Official Directory includes a section for each state entitled “Special Requirements for Graduates of Foreign Colleges:”. The FCLB Official Directory includes a section for each state entitled “Special Requirements for Graduates of Foreign Colleges:”. Most include a statement similar to: “Schools with CCE Reciprocal Agreements accepted” Most include a statement similar to: “Schools with CCE Reciprocal Agreements accepted”

3. CCE Language CCE Policy: BOD – 52 Cooperative Accreditation of Non U.S. Chiropractic Programs/Institutions CCE Policy: BOD – 52 Cooperative Accreditation of Non U.S. Chiropractic Programs/Institutions CCE Website Heading: “Doctor of Chiropractic Programs … Holding Accredited Status from Accreditation Agencies Having Reciprocal Agreements with CCE” CCE Website Heading: “Doctor of Chiropractic Programs … Holding Accredited Status from Accreditation Agencies Having Reciprocal Agreements with CCE”

4. NBCE Language NBCE Policy includes: “… the chiropractic college shall submit to the NBCE documentary certification that the chiropractic college is accredited by a chiropractic accrediting agency recognized by the United States Office of Education.” NBCE Policy includes: “… the chiropractic college shall submit to the NBCE documentary certification that the chiropractic college is accredited by a chiropractic accrediting agency recognized by the United States Office of Education.”

5. Prior to June 2004 The CCE Reciprocal Agreements seemed to provide a mechanism for recognition of international study by Regulatory Boards The CCE Reciprocal Agreements seemed to provide a mechanism for recognition of international study by Regulatory Boards The FCLB did not know that reciprocal agreements had been rescinded in January 2002 The FCLB did not know that reciprocal agreements had been rescinded in January 2002

6. May 31, 2004 EVENT A US citizen attending a foreign DCP sends an email that reports the reciprocal agreements “were dissolved in 2002” A US citizen attending a foreign DCP sends an email that reports the reciprocal agreements “were dissolved in 2002” FCLB ACTION Researched assertion and found it to be true. Started thinking about ramifications

7. June 10, 2004 Excerpts from letters from FCLB: “It is the understanding of FCLB that CCE-USA currently maintains reciprocal agreements…” “It is the understanding of FCLB that CCE-USA currently maintains reciprocal agreements…” “42 US Boards … have developed regulatory language that relies on these agreements as one criterion for licensure” “42 US Boards … have developed regulatory language that relies on these agreements as one criterion for licensure” …”uniform standards appear to be an excellent step to ensure that new and existing CCEs will have substantially equivalent processes worldwide.” …”uniform standards appear to be an excellent step to ensure that new and existing CCEs will have substantially equivalent processes worldwide.”

8. What Now?

10. June 22, 2004 EVENT CCE Announcement: “CCE-USA will, for the record, keep the agreements in force … providing stakeholders an opportunity to determine their course of action regarding reciprocity.” CCE Announcement: “CCE-USA will, for the record, keep the agreements in force … providing stakeholders an opportunity to determine their course of action regarding reciprocity.” NBCE ACTION Monitor developments and plan to present information at the Fall Board Meeting

11. July 19, 2004 EVENT CCE Announcement: “This will serve as public notice that the CCE-USA Board of Directors plans to reaffirm the decision to rescind BOD Policy – 52 … at its January 2005 meeting.” CCE Announcement: “This will serve as public notice that the CCE-USA Board of Directors plans to reaffirm the decision to rescind BOD Policy – 52 … at its January 2005 meeting.” NBCE ACTION Duly noted Recognized that NBCE policy will need to be modified.

12. October 14, 2004 EVENT WFC/ACC Conference: FCLB facilitates a discussion on chiropractic regulatory reliance on programmatic accreditation WFC/ACC Conference: FCLB facilitates a discussion on chiropractic regulatory reliance on programmatic accreditation CCE-USA reveals that the reciprocal agreements never did confer USDE recognition CCE-USA reveals that the reciprocal agreements never did confer USDE recognition NBCE ACTION Staff attends meeting but did not attempt to direct or affect any solutions.

13. October 18, 2004 EVENT FCLB UPDATE states: “Healthy information exchange and lively brainstorming are leading toward the general concept of agreements facilitated by CCEI, which can assure regulatory agencies of substantial equivalence in educational competence of chiropractic programs and their graduates worldwide.” FCLB UPDATE states: “Healthy information exchange and lively brainstorming are leading toward the general concept of agreements facilitated by CCEI, which can assure regulatory agencies of substantial equivalence in educational competence of chiropractic programs and their graduates worldwide.” NBCE ACTION Duly noted

14. October 18, 2004 EVENT FCLB UPDATE states: “Our members may rest assured that their current board requirements can remain in place in which regulatory agencies generally accept as candidates for licensure those graduates of DCPs with accreditation by the commissions of the CCEs (in addition to other criteria as may be required by law.) FCLB UPDATE states: “Our members may rest assured that their current board requirements can remain in place in which regulatory agencies generally accept as candidates for licensure those graduates of DCPs with accreditation by the commissions of the CCEs (in addition to other criteria as may be required by law.) NBCE ACTION Duly noted, but still believe NBCE policy will need to be modified This information is reported to our full Board at its meeting a few days hence

15. November 2004 – March 2005 NBCE ACTION Staff develops a draft policy revision that incorporates the substantially equivalent terminology and receives legal OK

16. March 10 – 12, 2005 EVENT NBCE EC Meeting: EC discusses options NBCE EC Meeting: EC discusses options NBCE ACTION EC moves to recommend to the full board a policy revision that includes the substantially equivalent terminology.

17. March 11, 2005 EVENT CCE-USA Announcement: Equivalency Based on CCEI Model Standards Replaces Reciprocal Agreements CCE-USA Announcement: Equivalency Based on CCEI Model Standards Replaces Reciprocal Agreements It includes: “It should be noted that … compliance and conformity with CCEI Model Standards does not necessarily express identical equivalence with CCE-US Standards.” It includes: “It should be noted that … compliance and conformity with CCEI Model Standards does not necessarily express identical equivalence with CCE-US Standards.” NBCE ACTION Duly noted; substantial equivalence not identical equivalence is the language everyone has been using.

18. May 2 - 7, 2005 EVENT NBCE Board meeting: Full Board discusses eligibility policy options NBCE Board meeting: Full Board discusses eligibility policy options NBCE ACTION Full Board revises eligibility policy to extend eligibility to those already in the system through 2006 and includes the substantially equivalent terminology Staff directed to document the presumed substantial equivalency

19. June 14 – November 3, 2005 EVENT CCE-USA can not assert that any of the other CCEs Standards are substantially equivalent to their own. CCE-USA can not assert that any of the other CCEs Standards are substantially equivalent to their own. NBCE ACTION Staff concludes that there is evidence to support an assertion that the Standards of all the CCEs are substantially equivalent but that the CCEI Model Standards are not precise enough to be considered substantially equivalent

20. November 3 - 5, 2005 EVENT NBCE Board Meeting: Full Board discusses options that include polling the state boards, specifically “asking if the CCEI endorsement and recognition of equivalency is acceptable to them” NBCE Board Meeting: Full Board discusses options that include polling the state boards, specifically “asking if the CCEI endorsement and recognition of equivalency is acceptable to them” NBCE ACTION Because of the complexity of the issue, it is assigned to the Board’s Exam Development Committee for closer oversight Staff is directed to follow-up on all the options presented

21. November 5 – December 13, 2005 EVENT Committee chair and staff recognize that this situation places foreign educated graduates at risk of not being able to become licensed in their state of choice Committee chair and staff recognize that this situation places foreign educated graduates at risk of not being able to become licensed in their state of choice Committee chair and staff ponder potential solutions. Committee chair and staff ponder potential solutions. New broadcast email software is installed New broadcast email software is installed NBCE ACTION Staff develops survey to provide data to help evaluate several potential solutions

22. Survey Purposes Confirm (or refute) states’ requirement for USDE recognition of DCPs. Confirm (or refute) states’ requirement for USDE recognition of DCPs. Confirm (or refute) states’ reliance on reciprocal agreements to accept foreign educated applicants. Confirm (or refute) states’ reliance on reciprocal agreements to accept foreign educated applicants. Would states accept the mutual endorsement and recognition provisions of CCEI to allow foreign educated applicants for licensure? Would states accept the mutual endorsement and recognition provisions of CCEI to allow foreign educated applicants for licensure? Would states accept evidence of substantial equivalency to CCE-US standards to allow foreign educated applicants for licensure? Would states accept evidence of substantial equivalency to CCE-US standards to allow foreign educated applicants for licensure? Would states require that NBCE annotate score transcripts of foreign educated examinees? Would states require that NBCE annotate score transcripts of foreign educated examinees?

23. December 14, 2005 Survey is broadcast emailed or faxed to all state boards Survey is broadcast emailed or faxed to all state boards

24. Survey Questions and Responses 1. Does your Board require that licensure applicants provide evidence that they attended a DCP that is accredited by an accrediting agency recognized by the USDE? 39 YES or CCECOA accredited 39 YES or CCECOA accredited 2 NO 2 NO 3 No Answer 3 No Answer

25. Survey Questions and Responses 2. Did your board accept CCE-US reciprocal agreements as evidence that foreign DCPs were accredited by an accrediting agency recognized by the USDE? 16 YES 16 YES 24 NO 24 NO 4 No Answer 4 No Answer

26. Survey Questions and Responses 3. Can and will your board accept the mutual endorsement and recognition provisions of CCEI member accrediting agencies as an equivalent substitute for the previous reciprocal agreements? 7 YES 7 YES 25 NO 25 NO 12 Others 12 Others

27. Survey Questions and Responses 4. If no to number 3, would evidence that a foreign CCE’s standards are substantially equivalent to CCE- US standards be satisfactory for your board to accept applications from those who attended a foreign DCP and passed the NBCE examinations? 7 YES 7 YES 13 NO 13 NO 24 Others 24 Others

28. Survey Questions and Responses 5. If no to number 4, and if NBCE continues to grant eligibility to applicants from non-CCE-US accredited programs, would your board require that NBCE annotate its score transcripts with the name of the accrediting agency that accredited the examinee’s DCP? 11 YES 11 YES 11 NO 11 NO 22 Others 22 Others

29. Findings 1. CCE-USA can not state that the other CCE’s requirements, standards and procedures are substantially equivalent to their Council on Accreditation standards.

30. Findings 2. The other CCE’s will not state that their requirements, standards and procedures are substantially equivalent to the CCE-US Council on Accreditation standards.

31. Findings 3. NBCE should not conduct, or hire another organization to conduct, an independent comparison of the various CCE accreditation standards.

32. Findings 4. A number of US state licensing boards will not (or cannot without changing their legislation) accept the mutual endorsement and recognition provisions of CCEI member accrediting agencies as a substitute for the rescinded reciprocity agreements.

33. Findings 5. A CCE’s stated adherence to the CCEI Model Standards does not satisfy our current policy.

34. Conclusion Without the ability to document “substantial equivalency” as required by NBCE’s current policy, foreign educated students and graduates will soon be ineligible to sit our examinations. Without the ability to document “substantial equivalency” as required by NBCE’s current policy, foreign educated students and graduates will soon be ineligible to sit our examinations.

35. May 2, 2006 The current policy has been extended through 2007 and referred for further study The current policy has been extended through 2007 and referred for further study