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Commission on Osteopathic College Accreditation COCA Seeking Public Comment

COCA Seeking Public Comment

Feedback wanted

COCA Seeks Public Comment on Standards Revision

In light of the recent public forums during which current and potential pending revisions to Accreditation Standards have been discussed, the Commission of Osteopathic College Accreditation (COCA) is now soliciting public comment on three specific issues:

  • Proposed revisions to COCA 2023 Continuing Accreditation Standards, Element 6.9 Clinical Education (CORE);
  • Revisions to the COCA’s Substantive Change Policies and Procedures to include the addition of a required feasibility study outlining GME capacity for any requested new additional location, branch campus, or planned class size increase; the development of 30% of the class size increase as new PGY-1 positions; and
  • COCA’s continued role as an institutional accreditor (Note: This does not impact COCA’s role as a programmatic accreditor).

To provide context for requested public comment, provided below is the background as to why these issues are under reconsideration, the COCA’s rationale associated with each of the proposed revisions and the specific standard, language or item open for public comment.

COCA 2023 Continuing Accreditation Standards, Element 6.9 Clinical Education (CORE)

Element 6.9, provides that a COM must, #3: “Define its core clinical rotations.”

Issue: Definition of Core Rotations

  • Since the revisions to the COM Continuing Accreditation Standards were published on Sept. 26, 2023, the COCA has received feedback that clarity is needed regarding which medical specialty rotations classify as core rotations.
  • The 2023 COCA Glossary currently provides the following definition:
    “At a minimum, core rotations should include, but are not limited to internal medicine, surgery, family medicine, obstetrics and gynecology, pediatrics, psychiatry.”
  • COMs have also expressed confusion regarding the deferential between a “core rotation” and a “required rotation.”

To address the issues and areas of concern, the COCA is proposing the following revisions:

Element 6.9, A COM must, #3:

  • Provide proof that students at a minimum must successfully complete core clinical rotations including family medicine, internal medicine, general surgery, pediatrics, psychiatry and obstetrics and gynecology.
  • Provide proof that students must successfully complete at a minimum a required clinical rotation in emergency medicine.*
  • All core and required rotations listed above must be a minimum of four weeks long and must include in-person patient care.

*The distinction between core rotations and required rotations is that core rotations must be taught in the third year of the curriculum by faculty who hold (or have held) board certification, or be board eligible, in the listed specialty. These stipulations do not apply to required rotations.

COCA’s Substantive Change Policies: Feasibility Study Outlining GME Capacity for a new Additional Location, Branch Campus or Planned Class Size Increase; the Development of 30% of Planned Class Size Increase as New PGY-1 Positions


Unique to the medical profession is the requirement that medical school graduates cannot enter the profession and become licensed physicians without at least one year of residency. Because of this, COCA has long held the position that all COMs share in the responsibility to develop adequate GME positions for osteopathic medical college graduates.

New GME Development Requirement for New and Developing COMs

In the Sept. 26, 2023, published revisions to the 2023 New and Developing Accreditation Standards, Pre-Accreditation Element 10.2: Accredited GME, the COCA ratified its position with the language below:

  • “In order for a COM to be awarded pre-accreditation status, the COM must provide evidence of approval of new PGY-1 positions supported by the COM and equal to 30% of the COMs requested class size. (New PGY-1 positions may not be claimed by other COMs.)”

In line with the new GME development standard for New and Developing COMs, the COCA is now proposing that the following language be added to the application requirements for any request for an additional location, branch campus or planned class size increase:

  • “The proposed COM must submit a feasibility study outlining available GME capacity including development costs and a plan outlining how the proposed COM will ensure sufficient residency positions (PGY-1) to equal the requested class size. Of these residency positions, 30% must be newly created PGY-1 positions.”

COCA’s Continued Role as an Institutional Accreditor


Accreditation is an evaluative process used to ensure that institutions of higher education and their programs meet acceptable educational standards. The U.S. Department of Education (USDE) recognizes the COCA as an accrediting agency.

The COCA currently serves as both a programmatic and institutional accrediting agency. Whereas programmatic accreditation focuses on assessing specific programs at a college, institutional accreditation evaluates the educational institution as a whole. Institutional accreditation is essential for distributing federal aid and efficiently transferring credits.

A COM that is not affiliated with a parent institution must be institutionally accredited in order to qualify for participating in federal programs under Title IV of the Higher Education Act of 1965.

COCA currently serves as the programmatic accreditor for 40 COMs and the institutional accreditor for only six of those 40 COMs. COCA has a single standard, Standard 12, devoted to institutional accreditation.

During a recent analysis of the value of the COCA serving as the COM’s institutional accreditor, COCA staff engaged with the deans of each of the six COMs currently institutionally accredited by the COCA. Staff learned that four of the six are in the process of transitioning from COCA to one of the six other higher education institutional accreditors. Reasons reported included:

  • Consideration of expanding to offer other programs—such as nursing, physician assistant, physical and/or occupational therapy—that COCA does not accredit, and
  • The ability to participate in the National Council for State Authorization Reciprocity Agreements (NC-SARA) which facilitates interstate post-secondary distance education (clinical rotation opportunities).


The COCA is currently evaluating the value to the COMs of continuing to serve as an institutional accreditor. In addition, COCA staff are analyzing the internal commitment of resources and investment in infrastructure needed to continue to effectively serve as an institutional accreditor.

If the COCA were to discontinue institutional accreditation services, it would no longer provide this accreditation service to new and developing COMs. For those COMs for whom COCA currently serves as their institutional accreditor, COCA would define a generous time period for COMs to transition to another institutional accreditor. COCA’s role as a programmatic accreditor for COMs would not change.

The COCA welcomes comments on any and all of these three issues. Please submit your comments to predoc@osteopathic.org. Comments must be received by 5:00 p.m. CST on Monday, Nov. 27, 2023.

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