Testimony Exposes CCE's Accreditation Failures Tied to NBCE Part IV Centralization
Originally published: 2025-07-15
A Crisis of Legitimacy, Integrity & Trust: Accreditation at a Crossroads
At the July 11, 2025 Council on Chiropractic Education (CCE) Semi-Annual Business Meeting in Minneapolis, the Chiropractic Freedom Coalition (CFC) took center stage. In both written and oral testimony, the CFC delivered a forceful indictment of the Council’s ongoing entanglement with the National Board of Chiropractic Examiners (NBCE), specifically targeting the monopolistic centralization of Part IV of the licensure exam and its entrenchment in CCE accreditation via Policy 56.
CLICK HERE for a copy of the Coalition’s written testimony
Representing the Coalition, Dr. Mike Guinosso spoke with clarity and conviction. He warned that CCE is now in violation of multiple federal recognition criteria by enforcing Policy 56 while failing to address the massive shift initiated by NBCE in relocating all Part IV testing to its Greeley, Colorado headquarters.
“This assessment, subject to new travel, cost, and capacity constraints, was never shown to be an appropriate, multifactorial measure of student achievement.”
—Dr. Mike Guinosso, Chiropractic Freedom Coalition
The Fallout of Policy 56
Policy 56, a CCE directive, effectively ties chiropractic program accreditation to pass rates on NBCE exams, especially Part IV. While CCE has attempted to suggest that licensure data could be used instead, the reality is stark: state boards do not provide timely or reliable licensure data. This makes NBCE pass rates the default, and only, option.
By doing so, Policy 56 creates a closed feedback loop that embeds NBCE’s testing monopoly into the very structure of chiropractic education. The recent move to centralize Part IV in Colorado has only deepened these concerns, cutting off geographic access and burdening students with steep travel and lodging costs.
“The centralized format is being enforced without the procedural safeguards and oversight required by law.”
—Written Testimony, Chiropractic Freedom Coalition
Violations of Federal Recognition Criteria
Dr. Guinosso outlined how the CCE’s inaction violates three specific U.S. Department of Education regulations that accrediting bodies must follow:
602.16(a)(1)(i): Requires accreditation standards to reflect clear, valid measures of student success
602.22(a)(3)(iii)(C): Demands reporting and reevaluation when a program undergoes substantive change
602.21(a–d): Mandates stakeholder input on major decisions affecting accreditation
None of these criteria, according to the CFC, were met before NBCE’s centralization of Part IV. There was no public review, no hardship data collected, no reconsideration of the 80% outcome benchmark, and no stakeholder engagement.
“Stakeholders, including educators, state boards, and now nearly 2,000 signatories to the student doctor petition, were not given meaningful opportunity to comment.”
—Dr. Mike Guinosso
A Broad Coalition Rising
The Chiropractic Freedom Coalition isn’t acting alone. As of the July meeting, over 60 organizations, representing more than 7,000 chiropractors and students, have endorsed the CFC’s resolution opposing the one-site Part IV model. A petition backing this stance includes nearly 2,000 verified signatures. The CFC also presented a cost analysis worksheet showing the real impact of the change: an additional $1,400 per student, far exceeding the NBCE’s claimed $430.
“NBCE is reporting something like $430, which is pretty silly.”
—Dr. Mike Guinosso
Barrier to Transparency: CCE Shuts the Door on Virtual Access and Recordings
The CCE refused to allow virtual attendance at its July meeting or permit the recording of public testimony. When pressed for justification, CCE President and CEO Craig Little stated that the Council is not subject to Arizona’s Open Meeting Law and that “customs and standing rules” prohibit recordings, citing Roberts Rules of Order (RRO) 2:23.
However, the specific rule prohibiting recordings is not available in any of CCE’s public documents, bylaws, or published policies. Little admitted that the rule is embedded in “internal operating instructions and Council training presentations” and was “established based on past Council customs and directives.”
This raises serious concerns about transparency and accountability. When an accrediting agency overseeing professional education for thousands of students cannot produce documentation of a claimed rule that governs basic meeting procedures, questions must be asked about how it operates and whom it ultimately serves.
“The CCE is a private, nonprofit organization in Arizona and is not subject to the Open Meeting Law... [the recording ban] has been in place for decades and was established based on past Council customs.”
—Craig S. Little, DC, CCE President and CEO
A Path Forward: Stop the Centralization Now
The CFC’s remedy request was clear: CCE must immediately halt all enforcement of Policy 56 based on Part IV outcomes until it has conducted proper legal review, stakeholder engagement, and developed fairer, multifactorial metrics for evaluating student competency.
“We simply ask the Council to follow the federal criteria designed to ensure fairness to our students and all stakeholders in chiropractic education.”
Will CCE Answer the Call?
With legal vulnerabilities mounting and grassroots opposition gaining strength, the CCE faces a defining moment. Will it cling to the status quo and its alliance with NBCE’s monopolistic practices, or will it reform its accreditation standards in service of transparency, fairness, and access?
The profession is watching. And so is the U.S. Department of Education.
