The COCA understands it is responsible for providing complainants with a means to express their specific allegations against a COM as well as to provide a way to review and resolve allegations against the COCA or administrative staff. Therefore, the complaint procedures developed by the COCA are in place to ensure the continued compliance of the
Accreditation of Colleges of Osteopathic Medicine: COM Accreditation Standards and Procedures as they are associated with approved COMs. All accrediting agencies recognized by the US Secretary of Education are required to have a complaint resolution process.
10 The complaint procedures may be used by individuals, organizations, or other stakeholders as a means of bringing any areas of noncompliance with COCA accreditation standards to the attention of the accrediting agency. Such noncompliance issues may be evident in COM proceedings or programs. The complaint policies and procedures of the COCA, as outlined in the following paragraphs, are periodically reviewed by the US Department of Education.
Individuals or groups who file a complaint against a COM generally include osteopathic medical students, individuals or institutions affected by COM accreditation on either an academic or professional level, other members of the osteopathic community, and the public. The filing or acceptance of complaints, however, is not limited to any particular group.
A complaint about a COM must be in writing and signed by the complainant (or complainants) before it is submitted to the COCA assistant secretary. Complaints not in writing and not signed by a complainant will not be accepted. The complainant must address the concern regarding a COM's violation (or violations) of an accreditation standard or procedure. The complaint must be in narrative form and must be based on truthful and reliable information. Allegation of a COM standard or procedure violation must be supported with accurate information as well as documentation. In addition, the complainant must provide evidence regarding his or her attempts to resolve the violation through appropriate COM channels and how these attempts failed to resolve the problem.
After the written and signed complaint has been received by the COCA assistant secretary, copies of the complaint will be sent within 10 business days to the COM's chief executive officer (CEO) or chief academic officer (CAO) for the COM's response within 15 business days. The response is sent back to the COCA assistant secretary addressing the allegations made by the complainant. When the COM response is received, both the original complaint and the response from the COM are forwarded to the COCA chair for a decision. The COCA chair determines whether the complaint should be brought before the entire COCA or if an ad hoc subcommittee needs to be appointed to determine the merits of the complaint and whether further investigation is needed.
If the COCA or ad hoc subcommittee finds that the complaint does not have merit, the complainant and the COM will be notified in writing regarding this decision. If, however, it is determined that the complaint has merit, an investigation will be conducted. The timeframe for conclusion of this part of the process is 15 business days with written notification of the investigation to both the complainant and the COM.
A warranted investigation will initiate a formal review by the COCA assistant secretary, in cooperation with the AOA corporate council and the ad hoc subcommittee within 30 business days from the decision that the investigation is warranted. The appropriate method of review and manner of investigation are decided by the ad hoc subcommittee and are dependent on the type of complaint that has been received. Review and investigation could include further requests for information from both parties, interviews of the complainant and specific COM personnel, and an on-site visit to the COM.
Findings from the investigation are forwarded to the COCA for action at the next regularly scheduled meeting. The COCA may decide on either of the following actions as a result of these findings:
There are several methods of review that can be taken if the COM is found to be out of compliance with the accreditation standards as a result of the complaint investigation. The COM may be required to submit a report to the COCA with its plans to address the compliance deficiencies. In addition, a progress report documenting the COM's planning and implementation of the plans to meet the deficient standards may be required. Finally, if believed appropriate, an on-site visit may be recommended to decide whether the COM's accreditation status should be changed.
When a COM is found to be out of compliance with the standards by the COCA as a result of a complaint investigation, the COM must be notified in writing within 15 business days of that decision. As in any accreditation decision issued by the COCA, the COM can ask for a reconsideration of the decision or appeal the decision according to the written appeals procedures of the COCA.
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Complaints may also be submitted by stakeholders, osteopathic medical students, academic professionals, the osteopathic community, and the public against the COCA or COCA administrative staff. These complaints, again, must be in writing and signed by the complainant before they can be received and reviewed. All complaints of this nature should be submitted to the COCA assistant secretary and will be presented by the COCA assistant secretary, in conjunction with the AOA corporate counsel, to the COCA chair, vice-chair, and secretary. When applicable, it will also be presented to the affected staff members. The COCA chair will appoint a subcommittee to initiate a formal review of the complaint and draft a response to the complainant. The reviewing and response process for the subcommittee must be completed and forwarded to the COCA within 30 business days of the date that the subcommittee is convened.
At the next regularly scheduled meeting of the COCA, the complaint and response will be considered. An invitation will be made to the complainant to appear before the COCA to present the complaint and to attempt to reach a resolution. The COCA's final action will be sent to the complainant within 30 days from the date that the complaint was heard by the COCA.
The COCA requires all COMs to keep a record of complaints made by students that relate to accreditation standards and procedures, including information on the investigation and resolution of these complaints. It is recommended by the COCA that a COM should utilize these complaints in their performance improvement process. The COCA standard 5.7 addresses this topic as follows
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All complaints, as mentioned above, should be directed to the Assistant Secretary of the COCA, AOA, 142 E Ontario St, Chicago, IL 60611-2864. Complaints will only be accepted and reviewed if they are in writing and signed by the individual or individuals who are submitting the complaint. Questions about complaints may be directed to
predoc@osteopathic.org. Information about the COCA complaint procedures may also be found on the COCA Web site,
http://www.aoacoca.org.