January 3, 2003
Paul D. Walker, Ph.D.
Executive Vice President
The Council on Chiropractic Education
8049 N. 85th Way
Scottsdale, AZ 85258-4321
Dear Dr. Walker:
As the chief operating officer of a chiropractic risk purchasing group and insurance concern that provides malpractice coverage to thousands of doctors of chiropractic across the United States, I have a unique perspective on several of the proposed standards changes recently published for comment by the Council on Chiropractic Education (CCE). This perspective is based on a detailed knowledge of matters of liability and professional responsibility, plus a real-world experience with the jeopardy the doctor of chiropractic places him or herself in when steps are taken to exceed the established boundaries of chiropractic science and practice.
The clear expansion of liability potential inherent in two of the proposed changes in CCE standards is of special, indeed, urgent concern. I refer to a desire on the part of some within the CCE to substitute the term “primary care physician” for established chiropractic reference terms such as doctor of chiropractic. This step is clearly beyond what state laws and regulations authorize for the doctor of chiropractic and carries with it significant consequences, all dangerous and potentially economically devastating. Likewise, the initiative to “include physiotherapy in doctor of chiropractic degree requirements and in the clinical competencies.” This step is certainly to be interpreted as a signal to the underwriting industry of the need to recalculate risk/premium equations, a step that will cost every doctor of chiropractic additional malpractice premium expenses, regardless of how or where they practice.
It is clear to the objective observer that these proposals represent a political and philosophical orientation that is out of step with the realities of chiropractic practice and inconsistent with legal and regulatory norms. It would seen reasonable to expect an accrediting body to tailor all demands on institutions and students to the strict legal definitions in operation throughout the nation. These proposals seek to drive the educational process and thus the profession in an entirely new direction, not supported by any discernable legal underpinning. Such steps would be a gross disservice to the student, practitioner and educational institution, with equal prejudice. I urge that these items be withdrawn from consideration in recognition of the unnecessary, costly and disruptive impact such expansive initiatives are certain to have on the profession in active practice.
Thank you for your attention to these matters. I would certainly be happy to provide any additional information or answer any questions you might have on any aspect of my comments.
Stuart E. Hoffman, DC, FICA
1-866-802-4476 Ext. 11