The FCLB recommended language for law and rule changes is specifically designed to ensure automatic approval for PACE programs, and to continue the existing board approval process for non-PACE programs. Copies of this recommended language are included in the handouts Dr. Cowie distributed.

State associations should ensure that the recommended language is adopted in statute and rule. This would allow the proper use of PACE, and also guarantee that the associations will maintain the same level of control that they currently enjoy.

PACE was designed to be of assistance to CE providers who offer courses for chiropractors in multiple jurisdictions. To that end, it will significantly assist those entities with approval processes and cost. It is not designed to have any effect on local programs, study groups, or state association educational activities.

In accepting PACE approved programs, regulatory boards will not be "ceding their authority."  They will be adopting a process in which they hold confidence that the assessment of programs is equal to, or superior to, their own processes, and therefore will remain convinced that their main goal of patient protection is being fulfilled.

In order to assist with this process in the past, many regulatory boards adopted a policy that stated that "courses taught by CCE accredited colleges would be approved for license renewal CE." Although this was an admirable attempt at a global approval process, it falls short since the CCE does not accredit the post grad departments of the chiropractic colleges.  In effect, no one currently ensures that CCE colleges maintain rigorous standards in the development of CE material.  In fact, some are very vigilant in their CE processes while others are not. The state boards have expressed displeasure with the current system, which has led to the development of PACE. 

Since the state regulatory board will ultimately maintain control and will continue to approve non-PACE programs, there should be no effect on state association programs in the area of 1) course content, 2) philosophic emphasis or 3) financial income.

Obviously, state associations would be welcome to partner with PACE approved providers such as chiropractic colleges (without applying directly to PACE), and feature the PACE logo on any qualifying programs they may offer at their state conventions. Those programs would be automatically approved for CE credit.

To steal and modify a quote from President Lincoln: "The PACE program is of the regulatory boards, by the regulatory boards, and for the regulatory boards."  Born from the frustration of regulators, it was developed to assist in the all-to-often overwhelming task of course approval. It is not designed to affect, nor to integrate specifically with state associations.  It is designed to act as a credentialing mechanism for national programs of the highest caliber, and to allow colleges and other national programs to teach freely without the financial impediment of compliance with varying nuances and requirements of multiple regulatory boards.

I have not used this letter to comment on most of the positive effects of the PACE program to teaching institutions, regulatory boards, field practitioners, and patients. The handout I prepared for the COCSA meeting more aptly addressed those concepts.  This note is to deal more directly with the concerns expressed in the COCSA resolution and questions articulated in your recent meeting.

The PACE program will roll out in May of 2004, and the FCLB will be accepting applications from institutions after that time.  I am personally committed to working with you to allay any fears from the membership of COCSA regarding the PACE program prior to that time.

I'd like to continue the discussion following the review of this letter by your leadership so we can further resolve concerns.  We are also very interested in positive suggestions to enhance the PACE service. As you review the Policies & Procedures and Criteria you may have additional ideas. As you do so, please forward them to me so we can give them our most careful consideration for possible inclusion in the program.

Thanks for your participation with this important project.

Sincerely,

Richard L. Cole, DC, DACNB, FICC
FCLB President