Public comment urges neutral accreditation language; board hears explanations of visiting Japanese chiropractic program

A representative of the Chiropractic Society of Texas urged the Texas Board of Chiropractic Examiners on Aug. 21 to change licensure eligibility language that currently names a single accrediting organization and instead anchor eligibility to accrediting agencies recognized by the U.S. Department of Education.

Dr. Steve Tullius spoke on behalf of Dr. Scott Kelly and the Chiropractic Society of Texas and asked the board to direct staff to publish rule text replacing “Council on Chiropractic Education” language with neutral U.S. Department of Education (USDE) recognition wording. Tullius said the proposed change “ensures Texas is aligned regardless of which qualified agency is recognized in the future by the Department of Education.” He offered to provide draft line edits to staff for notice-and-comment rulemaking.

Why it matters: The commenter argued that the board’s current language effectively ties Texas licensure to a single private accreditor (the CCE) and that several other U.S. jurisdictions use USDE‑recognition language to allow any nationally recognized accrediting agency to qualify graduates.

Texas Chiropractic College and international visitors: The board also heard from Texas Chiropractic College (TCC) President Sandra Hughes and Dr. Steven Foster, immediate past president of TCC, who described a longstanding partnership with the Japan Chiropractic Association (JCA).

Hughes said the short visits to TCC are “part of their overall program of their education in Japan” and that “they are not treating any individuals when they are here in Texas.” Foster said TCC’s engagement with the Japanese groups has continued for roughly 25 years and that visiting practitioners generally come to receive cadaver-lab and anatomy instruction that they cannot obtain in Japan, where chiropractic is unregulated.

Board and staff questions focused on scope and safety. Several board members said they were primarily concerned with whether visitors receive hands-on adjustments while in Texas; TCC representatives confirmed some limited hands‑on instruction on peer participants but emphasized the proportion of hands-on technique hours was small relative to the overall program. Foster said the TCC-issued document for attendees is an attendance record, not a Texas license or a credential that permits practice in the United States.

Legal and regulatory context: Board members noted the distinction between educational offerings and licensure; one member reminded the room that the board’s authority over college curricula is limited and that the board’s jurisdiction is primarily over in‑state clinical practice. Staff said the JCA and other Japanese organizations use varying domestic pathways, including an internal “safety” examination and registry mechanisms that differ from U.S. licensing.

Next steps: The public commenter asked the board to approve a clerical correction and authorize staff to pursue a companion rulemaking to replace prescriptive accreditor language with USDE recognition language. The board did not vote on a rule change at the meeting; rules committee members said rule proposals will be revisited after the Texas Register filing issue is resolved.

Ending: Board leadership thanked TCC and the public speaker for clarifying the record and said staff will take the request for neutral accreditation language under advisement when the board resumes rulemaking.