The case in one minute
A public standard should measure competence—not preserve one institutional model.
The American Veterinary Medical Association Council on Education is the only federally recognized specialized accreditor for veterinary medical programs. NAVEC’s filing argues that the Council has not shown that its costliest institutional requirements are necessary to produce safer or more capable entry-level veterinarians.
Independence and evidence
A federally recognized accreditor should be structurally independent and should prove that restrictive standards are necessary.
Scarcity by design
Rules governing facilities, staffing and program structure can prevent lower-cost schools from opening before their outcomes can be tested.
Competence, not overhead
Common knowledge, clinical-skill and workplace gates can protect patients across multiple educational models and accreditors.
What the report documents
The accreditation question reaches tuition, supply and access to care.
Accredited Into Scarcity compares accreditation inputs with published outcome evidence and models lower-cost nonprofit routes to the Doctor of Veterinary Medicine degree. The models are transparent policy counterfactuals—not audited school offers—but they show why the cost of the incumbent design deserves evidence rather than deference.
The governing principle
Accreditation is a delegated public trust, not a private entitlement. Professional judgment may inform a standard; it cannot replace evidence of necessity, benefit and proportionality.
The federal request
What NAVEC asked the Department to do
The filing supports the Department’s proposed shift toward accreditor independence, competition, outcome accountability and proof before restriction. It asks for seven concrete actions:
- 01
Open an immediate recognition-compliance review of the AVMA Council on Education without a presumption based on incumbency.
- 02
Terminate, suspend, or decline renewal of the Council on Education’s federal recognition.
- 03
Open recognition to multiple qualified veterinary accreditors without an artificial numerical cap.
- 04
Require a public evidence docket for Council on Education Standards 1, 3, 4, 6, 8, 9, 10 and 11, and for its distance-education policy.
- 05
Permit controlled practitioner-led, distributive, five-year, and provisional-practice pilots with comparable outcomes and student protections.
- 06
Prohibit retaliation, delay, or adverse treatment when a school chooses, changes, or adds another recognized accreditor.
- 07
Refer the Educational Commission for Foreign Veterinary Graduates and Clinical Proficiency Examination double standard—and the Council on Education–International Council for Veterinary Assessment/North American Veterinary Licensing Examination structure—to the Department of Justice and appropriate state authorities.
Transition without abandonment
Reform can protect students and strengthen the safety floor.
NAVEC does not propose pulling recognition without a bridge. The report calls for protection of every currently enrolled student, existing graduate and accredited program; a defined 24-month safe harbor; expedited recognition of qualified successor accreditors; and continuity of aid and loans to the maximum extent permitted by law.
Common public safeguards
One competence floor. More than one educational path.
- An independent knowledge examination
- A national clinical-skills examination
- Observed workplace performance
- A limited permit and paid supervised year
- Public graduate-outcome reporting
- Independent audit and privacy protection
“The public question is not whether a new school looks like the incumbent model. It is whether its graduates can demonstrate the same knowledge, clinical skill, judgment and workplace performance at a lower cost.”
Primary sources
Read the public record
The official comment is recorded on Regulations.gov. NAVEC also hosts a public copy of the report for direct download.
Official comment NAVEC comment in docket ED-2025-OPE-1042 Comment ID ED-2025-OPE-1042-0202 · Regulations.gov Open Report PDF Accredited Into Scarcity 33 pages · Report dated August 28, 2026 · Public NAVEC copy DownloadSuggested citation: NAVEC, Accredited Into Scarcity: The Case for Terminating AVMA COE’s Federal Recognition (Aug. 2026).