Recently, the Association for Clinical Pastoral Education (ACPE)Â made the unexpected decision to withdraw its application for renewed recognition by the United States Department of Education (USDE). This decision has sparked significant discussion and concern within the ACPE community and among its key partners, including healthcare institutions receiving Medicare pass-through funding, Veterans Affairs (VA)Â hospitals, and military chaplaincy programs. Unfortunately, not all the information about this situation is in one place or up-to-date, and much of it is contested.
In this article, I will provide a detailed timeline of events, examine the impact on critical areas such as Medicare pass-through funding, VA programs, and military chaplaincy, and explore the pivotal issue of federal linkage according to information shared with ACPE members in a recent town hall. Finally, I will outline the steps ACPE leadership reported that they are taking to address these challenges and prepare for the future.
Timeline of Events
2017
2019
September 2020
July 2022
September 2024:
ACPE submitted its final report and supporting materials to renew USDE's recognition as an accreditor. This submission followed years of preparation to address the USDE's evolving standards for accreditation. (Town Hall, Lynette Glass, 5:28-5:47)
Early October 2024:
The USDE analyst contacted ACPE following the submission to request additional documentation. During this conversation, the analyst indicated that ACPE likely faced an unfavorable outcome due to observed deficiencies. These deficiencies were primarily related to demonstrating student achievement, program progression, and clarity in policies and procedures. (Town Hall, Lynette Glass, 5:49-6:47)
Mid-October 2024:
ACPE requested an extension from the USDE to revise and resubmit its application to address the deficiencies. (Town Hall, Lynette Glass, 7:00-7:10)
The USDE denied this request, stating that ACPE would likely not succeed even with an extension. (Town Hall, Lynette Glass, 7:10-7:14)
A meeting was held between ACPE representatives (including the board chair, chair-elect of the Accreditation Commission, and executive director) and the USDE analyst. The analyst reaffirmed that an extension would not be granted. (Town Hall, Lynette Glass, 7:15-7:35)
October 20–22, 2024:
The ACPE Board of Directors convened to deliberate the best course of action in light of the USDE's response. Over 72 hours, the board decided to withdraw the application for renewal rather than receive a formal denial. (Town Hall, Lynette Glass, 7:36-7:54)
October 31, 2024:
November 5, 2024:
In another public announcement, ACPE reiterated its decision to pause the USDE recognition renewal process to strengthen its application, with plans to reapply within the next 12 months. The ACPE indicated that all current ACPE-accredited programs, activities, and Medicare Pass-through funding eligibility remain unaffected, ensuring continued validity and high standards in CPE.
November 12, 2024:
A town hall meeting was held to address members' questions and provide clarity about the implications of the withdrawal. ACPE leadership emphasized that the decision to withdraw would not impact the validity of its current accreditations and Medicare pass-through funding.
Reasons for the Withdrawal from USDE Recognition
Since 1969, ACPE has been recognized by the USDE as a programmatic accreditor, validating its role in accrediting CPE programs. However, ACPE encountered challenges meeting updated USDE standards during the recent reapplication process.
These challenges included:
Demonstrating measurable student achievement and progression.
Aligning programs with articulated standards.
Clarifying accreditation policies and procedures.
Facing a likely denial, ACPE withdrew its application, aiming to address the identified deficiencies before reapplying in 2025. ACPE continues to accredit existing programs, and the validity of units earned remains intact.
Key Impacts: Medicare Pass-Through Funding, VA Programs, and Military Programs
Medicare Pass-Through Funding
One of the most immediate concerns expressed by ACPE members during the town hall meeting was whether the withdrawal of USDE recognition would impact Medicare pass-through funding provided by the Centers for Medicare and Medicaid Services (CMS). This funding supports CPE residencies in healthcare settings, offering hospitals financial assistance to train chaplains.
ACPE programs remain eligible for Medicare pass-through funding because this funding is legislatively tied to ACPE's accreditation rather than recognition by the USDE. This safeguard is significant as it ensures that CPE programs can continue operating without disrupting their financial support structures, thereby maintaining their ability to train chaplains effectively in healthcare settings.
Veterans Affairs (VA) Hospitals
The Department of Veterans Affairs (VA) relies on ACPE accreditation for its CPE programs. According to the ACPE's Accredited Program Directory, there are currently 24 VA CPE programs accredited by ACPE. While these programs remain accredited and operational, ACPE leadership acknowledged the need to reinforce their relationship with the VA to address any long-term concerns stemming from withdrawing from USDE recognition. They expressed a commitment to ongoing dialogue with VA leadership to ensure continuity and support for VA CPE students and educators. Just days after the town hall meeting, other VA-affiliated ACPE-certified educators reported on social media that the Office of Academic Affiliations (OAA) informed ACPE-accredited CPE programs in the VA that their funding is secure without USDE recognition for 2024 and 2025.
Military-Based Programs
The military has a longstanding relationship with ACPE for training chaplains, particularly through the US Army Institute for Religious Studies. The military's reliance on federal accreditation standards means that withdrawing USDE recognition could pose challenges in demonstrating compliance with specific federal training requirements. In response, ACPE is engaging in discussions with military leadership to explore ways to continue supporting these programs, hoping to ensure their accreditation remains valid and recognized.
Federal Linkage
Federal linkage refers to the requirement for programmatic accreditors to demonstrate how their accreditation supports access to federal funding or fulfills federal mandates. The USDE's revised standards in 2020 tightened these requirements, leading to greater scrutiny. ACPE historically cited its relationship with the VA, J1 visas for international students, and eligibility for the GI Bill as its federal linkage. However, the USDE determined that these were insufficient under the revised criteria. The USDE now requires accreditors to show active and verifiable access to federal funds tied directly to their accreditation. For ACPE, this has proven complicated, as only a small number of its programs currently access GI Bill funds or other qualifying federal benefits. Moving forward, ACPE plans to revisit its federal linkage strategy, potentially identifying stronger connections through partnerships with federal agencies or expanded use of federal benefits by its programs.
Next Steps
ACPE leadership stated that they are committed to addressing the deficiencies identified by the USDE and reapplying for recognition in 2025.
Key next steps include:
Establishing a Task Force
ACPE is forming a task force of internal and external experts in accreditation, government relations, and healthcare administration. The task force has two primary objectives: to review the feedback from the USDE and strengthen the 2025 application and to explore alternative accreditation models or partnerships that could complement or supplement USDE recognition.
Strengthening Communication and Transparency
ACPE will conduct regular town halls, provide FAQs, and issue updates to ensure all stakeholders are informed about progress. Additionally, strategic communications will be developed to support programs addressing stakeholder concerns effectively.
Enhancing Policies and Procedures
ACPE will comprehensively review its accreditation standards, policies, and documentation to ensure closer alignment with USDE expectations. These efforts will prioritize demonstrating measurable student outcomes and programmatic excellence.
Bolstering Federal Partnerships
ACPE will work to deepen its relationships with CMS, VA, and military agencies to strengthen its role in supporting federal training initiatives. This effort includes clarifying and expanding its federal linkage rationale to bolster future accreditation efforts.
Conclusion
It remains to be seen what the true impact of the ACPE's decision to withdraw from USDE recognition will be. Let's stay calm and curious while waiting to learn more about the situation. Remaining calm and curious does not mean remaining silent, though. We should express our concerns and work with our colleagues currently in ACPE leadership roles to determine the best next steps for everyone. Â
(Please note that much of this information is taken from the ACPE Town Hall on Nov. 12, 2024. Using a transcript of the Town Hall meeting, I have used ChatGPT significantly to help me organize and synthesize this information for this article. If you find inaccurate information, please let me know. Kindly provide sources for your information, as I have tried to do here. Some of my links point to sources available only to ACPE members, so not all readers will be able to access them.)
