Hi Kathy,
Sorry everyone this is long! This is an important matter though and I feel this needs to be discussed.
I am very well aware of what the intention of that position statement was. As you know but some on this listserv may not, I was on the BOD when it was drafted and passed.
It was to state that the position of the board was in support of a single point of entry at the doctoral level. We did ask for a national dialogue in order for us to work together and move forward. What you are saying now is that the reaffirmation of this
statement by the board in October 2017 was done in order to justify having more dialogue but the first part of that statement and I quote, “It is the position of the American Occupational Therapy Association (AOTA) Board of Directors that the profession
should take action to transition toward a doctoral-level single point of entry for occupational therapists, with a target date of 2025” should be ignored? If that was the intention this was a very poor way of doing it. A position statement is to state
a position. So we look past this as an honest mistake. What is the justification for the statement from August 2017 mentioned below and in the statement from ACOTE? There was nothing in there about wanting more dialog. In fact, it said there
had been extensive dialog and careful consideration!!!! There was nothing in there questioning ACOTE’s authority to make this decision.
There was no statement to the profession ever made that the BOD did not believe that ACOTE had the authority to make this decision until today.
So why did the board direct legal counsel to look into the MOU and the governance documents? What was the justification for this? Also what was the point of the national conversation if all of this was driven by the current board wanting more answers and
directing legal counsel to look into it this past fall?
Our AOTA bylaws state that ACOTE will have complete autonomy in “establishing standards for education programs” So how is it not their decision to decide to no longer establish
standards for a specific degree? Further, where in any of the governance documents does it reserve the right for AOTA to make entry-level degree requirements? Also, if that right is reserved for AOTA, why has AOTA not challenged any of the
decisions ACOTE has made in this regard over the last 20 years? If the legal counsel was charged with reconciling our bylaws, the MOU, our governance documents with the USDE and CHEA requires for recognition, where did they find justification for this
statement from the BOD?
I am very familiar with the language in the bylaws and in the MOU. I am yet to see where it says AOTA retains the right to determine entry-level degrees.
They both however say many times that ACOTE can establish and maintain standards with “complete autonomy”, or other analogous terms to the same effect,. Again, if they choose to no longer develop standards for a degree how is that not within
this function? If they choose not to consider application for accreditation review from OTM programs anymore how is that not in their stated functions? And again, why were no questions asked in the last 20 years?
Just to be clear on this issue, there is nowhere in any governance document for AOTA that explicitly reserves the right for AOTA to make this decision.
The bylaws and SOP for the RA say vaguely that the RA is charged with “professional policy”. The RA can pass whatever they want but it does not mean ACOTE has to respond to their direction. The RA passed a motion a few years back saying ACOTE should accredit
PPOTD programs. They didn’t do it. So if ACOTE is working under the RA direction in this regard where is the protest to this inaction? The statement in the letter from the BOD today saying this is the purview of the RA because they have a history of making
these decisions would be akin to saying that these decisions should rest with the Board because the Board has a history of passing position statements related to entry-level education.
The only explicit mention of who has the authority to mandate entry-level degree requirements is on the AOTA Board of Directors webpage in the OTD FAQs which states:
“Ultimately,
the only body with regulatory authority to mandate the entry-level degree is the Accreditation Council for Occupational Therapy Education (ACOTE®). ACOTE is recognized as the accreditation agency for occupational therapy education in the United
States by both the United States Department of Education (USDE) and the Council on Higher Education Accreditation (CHEA).
USDE and CHEA regulations require that all actions and decisions of the accreditation agency must be made independently from the parent association(s). Historically, ACOTE has been careful to consider the positions and policies of the profession’s
leadership groups when determining entry-level degree requirements.”
Kathy, I have never once made a personal attack toward anyone in a volunteer leadership position, including the BOD, over this issue. I know
everyone is a volunteer and I choose to believe that we all have what we see as the best interest of our profession at heart.
I do question actions though. Please don’t mistake my wanting answers as personal attacks. You all made this decision which is leading our profession down a path of litigation. The long and short it, I want to know why.
Thank you for reading/listening
Best
Tim
Timothy J. Wolf, OTD, PhD, OTR/L, FAOTA
Associate Professor and Chair
Department of Occupational Therapy
University of Missouri
810 Clark Hall
Columbia, MO 65211
573-882-8403
From: ot-pd@aotalists.org [mailto:ot-pd@aotalists.org]
Sent: Friday, August 10, 2018 9:09 PM
To: ot-pd@aotalists.org
Subject: Re: [OT-PD List - AOTA] - A Message from AOTA Board of Directors on the OTD and OTA Mandates
Hi Tim,
Actually, it was October 2017 that a motion to reaffirm the Board position of 2014 was presented. Again, as I mentioned to Barb, that position was to have a professional dialogue. The current Board believes the profession should continue
to explore and discuss the entry-level education points.
Regarding the announcement following the ACOTE announcement of the mandates, there were concerns as to whether the AOTA governance processes had been circumvented and this was being examined.
As you reflected in your email to this list serve, this is a complex issue. The current AOTA Board wanted to be sure to understand the requirements of CHEA and the US Department of Education and how these relate to our governance and bylaws.
So, we sought advice from a legal firm with experience in these matters.
We respect the work of ACOTE and the need for ACOTE to do the work they are charged with in the Bylaws. However, “complete autonomy in establishing standards for educational programs” must be seen in the full context-these are standards
that pertain to assessing accreditation status of education programs. It does not mean total autonomy on any issue related to education. As the mandate circumvented the AOTA governance process, the AOTA Board had an obligation to address the issues and concerns.
As you know, Tim, members of the Board take their positions seriously and understand the importance of every decision. The Board consists of volunteers who are committed to the membership and to the future of the profession.
Have a nice evening. -Kathy Foley
Kathleen T. Foley
Sent from my iPhone
On Aug 10, 2018, at 9:23 PM, AOTA ot-pd List <ot-pd@aotalists.org> wrote:
Kathy,
So please then reconcile with the statement from the board this past August 2017, the same board with the exception of two members who issued this statement today, in which the board applauded the mandate and stated “We believe ACOTE has acted in the best interest of all of these parties with their recent decision.”
Or please reconcile with the action of the board in November 2017 when the position statement mentioned below was again unanimously supported by the current board with the exception of the two members who took office in July. The position statement was to encourage dialog but it was a position statement and the position was that the board supported a single point of entry at the doctoral level.
So what happened between November 2017 and February 2018 to change the position of the board?
Best
Tim
Timothy J. Wolf, OTD, PhD, OTR/L, FAOTA
Associate Professor and Chair
Department of Occupational Therapy
University of Missouri
810 Clark Hall
Columbia, MO 65211
573-882-8403
From: ot-pd@aotalists.org [mailto:ot-pd@aotalists.org]
Sent: Friday, August 10, 2018 8:14 PM
To: ot-pd@aotalists.org
Subject: Re: [OT-PD List - AOTA] - A Message from AOTA Board of Directors on the OTD and OTA Mandates
Good evening,
As indicated in the statement you linked, the intent of the position statement by the AOTA Board in April 2014 was to take the recommendation to the full membership and facilitate a profession-wide dialogue around the issue. The dialogue was facilitated by past President Stoffel and the AOTA Board between 2014 and 2015. -Kathy Foley
Kathleen T. Foley
Sent from my iPhone
On Aug 10, 2018, at 8:59 PM, AOTA ot-pd List <ot-pd@aotalists.org> wrote:Hello all,
I am curious. How does the AOTA Board of Directors reconcile its current position with the position statement they issued in 2014 in which they recommended that the profession move to a single point of entry for the OT at the doctoral level?
https://www.aota.org/aboutaota/get-involved/bod/otd-statement.aspx#sthash.B2g7T9MK.dp
This position statement was one piece of evidence we used to support the transition.
Barb
From: ot-pd@aotalists.org <ot-pd@aotalists.org>
Sent: Friday, August 10, 2018 7:41 PM
To: ot-pd@aotalists.org
Subject: RE: [OT-PD List - AOTA] - A Message from AOTA Board of Directors on the OTD and OTA Mandates
Hello all,
The U.S. Department of Education (DOE), under the Code of Federal Regulations, Title 34, Chapter VI, Part 602, Subpart B, Section 602.14, outlines criteria for purpose and organization for an accrediting body to be recognized by the Department of Education. Paragraph b describes the requirement to be “separate and independent” from the Association. In this section it states that the accrediting body can jointly share personnel, services, etc. as long as joint use “does not compromise the independence and confidentiality of the accreditation process”
Here is a direct excerpt
(1) The members of the agency's decision-making body - who decide the accreditation or pre-accreditation status of institutions or programs, establish the agency's accreditation policies, or both - are not elected or selected by the board or chief executive officer of any related, associated, or affiliated trade association or membership organization;
The federal law explicitly states that an elected board is not to interfere with the accreditation process.
Please understand what just happened. The AOTA BOD, with consultation with their legal counsel, has decided that their authority as a board supersedes this USDE requirement. There is leeway in what is allowed in terms of written agreements between professional associations, but we are required to have written agreements and abide by them. Per our agreements and actions for the last 20 years, the authority to determine entry level degrees has for 20 years been left to ACOTE unchallenged by our profession. There is no language anywhere in any official document of AOTA that says this decision should be AOTA’s and not ACOTE’s.
Your professional accreditation is now at risk. Without professional accreditation we don’t exist.
This folks is a dark day for our profession.
Best wishes to you all
Tim
Timothy J. Wolf, OTD, PhD, OTR/L, FAOTA
Associate Professor and Chair
Department of Occupational Therapy
University of Missouri
810 Clark Hall
Columbia, MO 65211
573-882-8403
From: ot-pd@aotalists.org [mailto:ot-pd@aotalists.org]
Sent: Friday, August 10, 2018 5:33 PM
To: ot-pd@aotalists.org
Subject: [OT-PD List - AOTA] - A Message from AOTA Board of Directors on the OTD and OTA Mandates
---
Amy J. Lamb, OTD, OT/L, FAOTA
President, American Occupational Therapy Association (2016 - 2019)Associate Professor, Eastern Michigan University Occupational Therapy Program
Owner, AJLamb Consulting LLC
Occupational Therapy is a health and wellness profession that assists people in developing the skills they need to participate in everyday life where they live, learn, work and play.
Do not go where the path may lead, go instead where there is no path and leave a trail.
~Ralph Waldo Emerson