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	<title>Healthcare Archives - Charles F. Mullen</title>
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	<description>Challenges and Opportunities in Optometry and Optometric Education</description>
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	<title>Healthcare Archives - Charles F. Mullen</title>
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		<title>A Unique Opportunity for Osteopathic Health Sciences Centers to Develop an Innovative Optometry Degree Program and Postgraduate Residency Training</title>
		<link>https://www.charlesmullen.com/opportunity-for-osteopathy-to-develop-innovative-optometry-degree-program/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sat, 10 Aug 2019 15:14:18 +0000</pubDate>
				<category><![CDATA[Building Quality Institutions]]></category>
		<category><![CDATA[Board Certification]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[GME]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=1007</guid>

					<description><![CDATA[<p>The expanded use of technology will significantly alter the traditional role of optometrists over the next 10 years.</p>
<p>The post <a href="https://www.charlesmullen.com/opportunity-for-osteopathy-to-develop-innovative-optometry-degree-program/">A Unique Opportunity for Osteopathic Health Sciences Centers to Develop an Innovative Optometry Degree Program and Postgraduate Residency Training</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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<p>The expanded use of technology will significantly alter the traditional role of optometrists over the next 10 years. Large corporations with sophisticated marketing will dominate the multi-billion dollar eye care market. However, there is unmet need for medical eye care in the Medicaid and Medicare populations, and with changes to optometric education and clinical training, this unmet need can be addressed. State and Federal legislative/regulatory advocacy would need to be initiated concurrently with the development of the new optometric educational model.</p>

<p>Osteopathic Health Sciences Centers across the Nation currently offer innovative curricula in medical and other health care professions&#8217; education, and now have a unique opportunity to develop and offer an innovative program in optometric education and residency training that would prepare optometrists to provide medical eye care. Such a new program would replace the traditional optometric curriculum where clinical training is contained within the four year degree program. Having no requirement for postgraduate clinical training, optometry is not eligible for the multi-billion dollar Graduate Medical Education (GME) program. </p>

<p>Optometrists are classified as physicians under Medicare and are judged by medical standards including specialty clinical training and <a href="https://abcmo.org">board certification</a>. Optometric education must now align with national standards and guidelines derived from medical education.</p>

<p>Such a proposed restructuring plan is politically challenging with numerous sensitive professional and educational issues. Implementation of the plan requires bold leadership. I look to Osteopathic Health Sciences Centers with their tradition of leadership and innovative programs to lead the change in optometric education. This proposal recommends restructuring optometric education and postgraduate training by placing it in parallel with medicine.</p>

<h2>New Program</h2>

<p><strong>Three Years for OD Degree + One Year Postgraduate Training = Licensure</strong></p>
<p>Three years of classroom education, laboratory and clinical clerkships to earn the Doctor of Optometry (OD) degree followed by one year of postgraduate clinical training for licensure in General (Traditional) Optometric Practice. <i>This would replace the current 4th year which essentially is the first year of residency training</i>.</p>
<p><strong>One Additional Year of Specialty Clinical Training to Provide Medical Eye Care</strong>.</p>
<p>One year of additional specialty clinical training in medical eye care and Board eligibility required by State Optometry Regulatory Boards to provide medical eye care.</p>
<p><strong>Advantages of the New Curriculum and Clinical Training Model Include:</strong></p>
<ol>
<li>The new model would encourage specialty clinical training and board certification as emphasis would shift from General (Traditional) optometric practice to primarily medical eye care.</li>
<li>By restructuring the curriculum and requiring postgraduate clinical training, optometry would become eligible for Graduate Medical Education (GME) payments to address clinical training costs.</li>
</ol>
<h2>Actions Required</h2>
<ol>
<li>Apply for a Center for Medicare/Medicaid Services (CMS) Innovation Grant to Fund Implementation, Entitled — &#8220;Restructuring of Optometric Education and Clinical Training To Meet Unmet Need for Medical Eye Care in Medicare/Medicaid Populations&#8221;</li>

<li>Amend States&#8217; optometric licensing laws/regulations to require a minimum of one year of postgraduate, residency training in General/Traditional optometry for licensure.</li>
<li>And require an additional one year of training in specialty medical eye care with Board eligibility to practice medical eye care.</li>
<li>Amend the Social Security Act to include optometry in the Graduate Medical Education Program (GME) and expand GME support of residency training to all optometric clinical training venues.</li>
</ol>
<p>The post <a href="https://www.charlesmullen.com/opportunity-for-osteopathy-to-develop-innovative-optometry-degree-program/">A Unique Opportunity for Osteopathic Health Sciences Centers to Develop an Innovative Optometry Degree Program and Postgraduate Residency Training</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>NAVAO Founding Member Spotlight: An Interview with Dr. Charles Mullen</title>
		<link>https://www.charlesmullen.com/navao-founding-member-interview/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 11 Aug 2015 11:47:42 +0000</pubDate>
				<category><![CDATA[Emerging Trends and Issues]]></category>
		<category><![CDATA[Board Certification]]></category>
		<category><![CDATA[Credentials]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=1409</guid>

					<description><![CDATA[<p>The following interview was published in Optimum VA, The Official Newsletter of the National Association of Veterans Affairs Optometrists (NAVAO), Summer 2015.</p>
<p>The post <a href="https://www.charlesmullen.com/navao-founding-member-interview/">NAVAO Founding Member Spotlight: An Interview with Dr. Charles Mullen</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>The following interview was published in <strong>Optimum VA, The Official Newsletter of the National Association of Veterans Affairs Optometrists (NAVAO), Summer 2015</strong>.</p>
<div><img fetchpriority="high" decoding="async" src="https://www.charlesmullen.com/wp/wp-content/uploads/2015/08/US-DeptOfVeteransAffairs-Seal-Large-300x300.png" alt="Seal of the US Department of Veterans Affairs" width="240" height="240" class="alignright size-medium wp-image-1418" srcset="https://www.charlesmullen.com/wp/wp-content/uploads/2015/08/US-DeptOfVeteransAffairs-Seal-Large-300x300.png 300w, https://www.charlesmullen.com/wp/wp-content/uploads/2015/08/US-DeptOfVeteransAffairs-Seal-Large-150x150.png 150w, https://www.charlesmullen.com/wp/wp-content/uploads/2015/08/US-DeptOfVeteransAffairs-Seal-Large-1024x1024.png 1024w, https://www.charlesmullen.com/wp/wp-content/uploads/2015/08/US-DeptOfVeteransAffairs-Seal-Large.png 1200w" sizes="(max-width: 240px) 100vw, 240px" /></div>
<p>Upon being asked to be featured in the NAVAO Optimum VA Newsletter, Dr. Mullen expressed the following:</p>
<blockquote><p>“Thank you for your kind invitation to share my experiences in VHA and also to offer recommendations for the future of VA Optometry. It is an unexpected privilege to recall my tenure as Director,<br />
VA Optometry Service (1990-96). In reviewing my files in preparation for this interview, I remembered the many outstanding VA optometrists whose dedication and support were essential in developing and implementing the objectives of the Optometry Service Strategic Plan. It was an honor to have such outstanding clinicians and educators as colleagues.”</p></blockquote>
<h2>How did you first become actively involved with VA Optometry?</h2>
<p>In the 1970s, while serving as the Director of NECO’s clinical program, Dr. Ken Myers, Founding Director of the VA Optometry Service, called and asked if NECO was interested in sponsoring a VA funded residency program at the Boston VA OPC. After establishing the OPC residency program and agreeing to further development of residency programs at other Boston VA facilities, I then served on Dr. Myers’ Advisory Group for a number of years. Ken and I shared a similar view on the importance of optometrists practicing in collaboration with physicians. I became increasingly interested in the potential that VA Optometry could offer in advancing the Profession of Optometry in patient care, clinical education and research. When Dr. Myers resigned as Director in 1990, I enthusiastically agreed to succeed him.</p>
<h2>What contributions to VA Optometry have you participated in that you feel proud of?</h2>
<p>After arriving at VACO, I soon learned that Dr. Myers had built a solid foundation for the VA Optometry Service. His meticulous attention to detail in working with the AOA Washington Office positioned VA optometrists in Title 38 along with physicians and dentists. Dr. Myers wrote the Qualification Standards which established very high standards for the appointment and promotion of optometrists. He also developed the first optometry residency program and academic affiliation with a college of optometry, and later established numerous clinical training programs for optometry students and residents. He wrote the Optometry Service’s first Plan and encouraged the development of NAVAO. Although my contributions pale in comparison to the significant accomplishments of Dr. Myers, I am proud of the following:</p>
<ul>
<li>Appointed the first Optometry Field Advisory Group.</li>
<li>In collaboration with NAVAO, ASCO and the AOA, I updated and enhanced the Optometry Service Strategic Plan. ASCO forwarded the Plan to VACO and the Undersecretary for Health instructed me to implement the key elements of the Plan including the addition of 53 centrally-funded optometry positions, 21 residents and the necessary eye care equipment.</li>
<li>At the invitation of the Undersecretary for Health, briefed the senior administration of VHA on all aspects of the Optometry Service and gained standing in VACO for the Optometry Service.</li>
<li>Standardized the optometry clinical education program in cooperation with ASCO.</li>
<li>Disseminated numerous clinical guidelines including preferred practice patterns, credentialing and privileging, eye care space criteria, staffing models and productivity standards.</li>
<li>With assistance from several NAVAO members, conducted a system-wide inventory of all VHA eye care (optometrists and ophthalmologists) manpower, facilities and training programs. The results were presented to SMAG by the Optometry Representative along with recommendations to further increase eye care manpower, facilities and equipment.</li>
<li>At the request of the VHA senior administration, interviewed and recommended for appointment the first ophthalmological consultant to VHA, and effectively advanced an agenda of cooperation between the two eye care disciplines.</li>
<li>Appointed by the Undersecretary for Health to a high level Eye Care Advisory Group consisting of nationally recognized optometrists and ophthalmologists. In consultation with the Group, advised the Undersecretary on policy to improve collaboration between the two eye care disciplines in patient care, education and research.</li>
<li>Stimulated research in low vision rehabilitation with $6 million in funded research projects.</li>
<li>Reduced the average waiting time for primary eye care services by 30%.</li>
<li>Initiated a nation-wide recruitment effort to reach under-represented groups for placement in VA optometry staff and residency positions resulting in a significant increase in female staff and residency appointments.</li>
</ul>
<h2>What advice would you give to new ODs entering the profession?</h2>
<p>Complete a Specialty Residency Program and achieve Specialty Board Certification preferably in Medical Optometry. The most challenging and rewarding positions in optometry will be within hospitals and other medical facilities and specialty credentials will be required for appointment.</p>
<h2>What would you like to see happen in the future of VA Optometry?</h2>
<p>Dr. Townsend has done an outstanding job in increasing the number of VA optometrists, residents and students on clinical rotation. He has instituted innovative programs such as research fellowships while significantly expanding low vision programs. He has developed the VA Optometry Service into one of the most productive in VHA. The Eye Care Handbook he authored has positioned optometry as a major patient care and clinical training component in the VA as an equal partner with ophthalmology. The Handbook is considered the model for all optometry programs located within medical facilities.</p>
<p>Despite the impressive progress, more needs to be done. I would like to see the following completed in the next two years.</p>
<ul>
<li>Optometry Qualification Standards updated to include requirements for Specialty Residency Training and Specialty Board Certification in appropriate sections.</li>
<li>Optometry Service Strategic Plan Updated in collaboration with NAVAO, ASCO and AOA and submitted to the Undersecretary for Health with specific recommendations.</li>
<li>Restrictions or caps on optometrists pay removed to encourage retention of the most experienced clinicians.</li>
<li>Optometry Service Field Advisory Group to brief the new Optometry SMAG Representative on the challenges and opportunities in VA Optometry.</li>
<li>Encourage more active involvement of academic affiliates with VA facilities including participation on Deans Committees and other advisory groups.</li>
<li>Appointment of a VA representative to the ACOE.</li>
<li>Continue VA Optometry’s leadership in Specialty Training and Board Certification by ABCMO. Encourage the development of the American Board of Optometry Specialties (ABOS) similar to the American Board of Medical Specialties (ABMS). This oversight board would establish and ensure high standards for all Specialty Certification Boards.</li>
</ul>
<p>Thank you for the opportunity to share my VA experiences with NAVAO.</p>
<p>The post <a href="https://www.charlesmullen.com/navao-founding-member-interview/">NAVAO Founding Member Spotlight: An Interview with Dr. Charles Mullen</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Medicare Teaching Compliance Protocol for New England Eye</title>
		<link>https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 10 Sep 2013 12:30:29 +0000</pubDate>
				<category><![CDATA[Building Quality Institutions]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<category><![CDATA[Students]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=986</guid>

					<description><![CDATA[<p>The Teaching Compliance Protocol for New England Eye (PDF) describes the practical implementation of NEE Health Insurance Teaching Compliance Policy.</p>
<p>The post <a href="https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/">Medicare Teaching Compliance Protocol for New England Eye</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<div><img decoding="async" src="https://www.charlesmullen.com/wp/wp-content/uploads/2013/09/NEE-logo.png" alt="New England Eye Logo" width="147" height="147" class="alignright size-full wp-image-992" /></div>
<p>New England Eye is the Patient-Centered Care and Clinical Education Affiliate of the New England College of Optometry.</p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Health-Care-Insurance-Teaching-Compliance-Policy.pdf">The Teaching Compliance Protocol for New England Eye (PDF)</a> describes the practical implementation of NEE Health Insurance Teaching Compliance Policy.</p>
<p>Authors: Senior Management Staff, NEE.</p>
<p>The post <a href="https://www.charlesmullen.com/teaching-compliance-protocol-for-new-england-eye/">Medicare Teaching Compliance Protocol for New England Eye</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Restructuring the Profession of Optometry &#8211; The Next Bold Move</title>
		<link>https://www.charlesmullen.com/restructuring-optometry/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Fri, 16 Aug 2013 13:51:56 +0000</pubDate>
				<category><![CDATA[Building Quality Institutions]]></category>
		<category><![CDATA[Presentations]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Faculty]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Optometry]]></category>
		<category><![CDATA[Patient]]></category>
		<category><![CDATA[Students]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=966</guid>

					<description><![CDATA[<p>Align Optometry more completely with National health care policy, standards and guidelines by adopting important principles derived from medicine. </p>
<p>The post <a href="https://www.charlesmullen.com/restructuring-optometry/">Restructuring the Profession of Optometry &#8211; The Next Bold Move</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<blockquote><p>We must not let anyone else write our future.</p>
<p> &#8211; Dr. Ronald Hopping, President AOA</p></blockquote>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Restructuring-Optometry.pdf">Restructuring the Profession of Optometry (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/Restructuring-Optometry.ppt">Restructuring the Profession of Optometry (PPT)</a></p>
<p>Charles F. Mullen<br />
Roger Wilson<br />
Janice E. Scharre<br />
David S. Danielson</p>
<p>The post <a href="https://www.charlesmullen.com/restructuring-optometry/">Restructuring the Profession of Optometry &#8211; The Next Bold Move</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>A Strategic Framework for Optometry and Optometric Education</title>
		<link>https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Tue, 16 Apr 2013 16:20:19 +0000</pubDate>
				<category><![CDATA[Presentations]]></category>
		<category><![CDATA[Signature Papers]]></category>
		<category><![CDATA[Strategic Planning and Measured Performance]]></category>
		<category><![CDATA[Accreditation]]></category>
		<category><![CDATA[Board Certification]]></category>
		<category><![CDATA[Clinical Training]]></category>
		<category><![CDATA[Education]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Medical]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=876</guid>

					<description><![CDATA[<p>An eight step plan to comprehensively restructure the profession of optometry by placing optometry in parallel with medicine.</p>
<p>The post <a href="https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/">A Strategic Framework for Optometry and Optometric Education</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<blockquote><p>If optometry is to maintain its position as the Nation’s leader in primary eye and vision care in a rapidly evolving health care system&#8230; we have a responsibility to frame our own future.</p></blockquote>
<h2>Abstract</h2>
<p>The following slide presentation describes an eight step plan to comprehensively restructure the profession of optometry to meet the expectations of private, Federal and State insurers, external certifying agencies, and credentialing and privileging boards by placing optometry in parallel with medicine.</p>
<p>Significant changes to optometric education, clinical training, licensure requirements, board certification and accreditation are described (1) to qualify optometry for inclusion in the Graduate Medical Education Residency Program (GME), a $10 billion annual program which currently funds post graduate training for physicians, dentists and podiatrists, and (2) to meet Federal insurance compliance guidelines for teaching programs.</p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/2016/01/A-Strategic-Framework-for-Optometry.pdf">A Strategic Framework for Optometry and Optometric Education (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/2016/01/A-Strategic-Framework-for-Optometry.ppt">A Strategic Framework for Optometry and Optometric Education (PPT)</a></p>
<p>Charles F. Mullen<br />
Janice E. Scharre<br />
David S. Danielson</p>
<p>The post <a href="https://www.charlesmullen.com/a-strategic-framework-for-optometry-and-optometric-education/">A Strategic Framework for Optometry and Optometric Education</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Eight Strategic Steps to a Secure Future for Optometry</title>
		<link>https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Thu, 16 Aug 2012 15:10:07 +0000</pubDate>
				<category><![CDATA[Strategic Planning and Measured Performance]]></category>
		<category><![CDATA[Accreditation]]></category>
		<category><![CDATA[Healthcare]]></category>
		<category><![CDATA[Medical]]></category>
		<category><![CDATA[Medicare]]></category>
		<category><![CDATA[Optometry]]></category>
		<guid isPermaLink="false">https://www.charlesmullen.com/?p=700</guid>

					<description><![CDATA[<p>Since optometrists are classified as physicians under Federal law, they are (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards of medical facilities and third party insurers utilizing the medical model as the standard.</p>
<p>The post <a href="https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/">Eight Strategic Steps to a Secure Future for Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<blockquote><p>The tranquilizing drug of incremental progress &#8211; Anonymous</p></blockquote>
<h2>Background</h2>
<p>Over the past 40 years, changes to optometric practice laws and Federal/State current and anticipated health care policy have been addressed by specific, <em>incremental</em> modifications to licensure requirements, clinical education, postgraduate training and advanced competency certification/re-certification rather than systemic restructuring of the profession in accordance with a comprehensive strategic plan.</p>
<p>Consequently, unaddressed <em>structural</em> issues persist and weaken optometry&#8217;s position as an independently licensed profession in a third party dominated health care system. Also, structural issues prevent optometry from receiving Federal support for clinical training. Currently, clinical training costs are often passed on to the optometry student in the form of higher tuition resulting in additional graduate debt.</p>
<p>Since optometrists are classified as physicians under Federal law, they are (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards of medical facilities and third party insurers utilizing the <em>medical model</em> as the standard. Optometrists, like physicians, will be/or are already expected to demonstrate clinical competency by board certification and maintenance of competency by re-certification.</p>
<p>Also, all optometric clinical teaching venues are expected to comply with the Center for Medicare/Medicaid Services (CMS) Guidelines for Teaching Physicians, Interns and Residents.</p>
<p>A <em>eight-step approach</em> is recommended to comprehensively restructure the profession by placing optometry in parallel with medicine.</p>
<h2>Most Important Events of the Past 40 Years</h2>
<ul>
<li>Expansion of optometric state laws, initiated in Rhode Island in 1972, authorizing the use of pharmaceuticals and advanced clinical procedures.</li>
<li>Creation in 1976 of the Department of Veterans Affairs Optometry Service, now the largest optometric patient care and clinical training program in the country with 675 VA optometrists providing 1.5 million visits annually. And clinical training provided for 80% of optometric students and over 50% of all residents.</li>
<li>Inclusion in Medicare in 1987, now $1.0 billion in optometric services are provided annually.</li>
<li>Optometry&#8217;s broad-based inclusion in the Affordable Care Act (ACA) will likely be another significant event. Participation in the ACA will also facilitate inclusion in other Federal Programs such as the Graduate Medical Education Program (GME) and the National Health Service Corps (NHSC).</li>
</ul>
<p>Although these were major achievements, the absence of a visionary plan at the time resulted in missed opportunities:</p>
<ul>
<li>to advocate for the passage of broadly drafted state optometric practice laws that would allow for the future expansion of the scope of practice without further amendments,</li>
<li>to agree on the purpose of optometric post graduate clinical training. Was it intended to qualify for state licensure and/or board certification or just advanced training?</li>
<li>and to include optometric clinical training support (GME) in the Medicare component of the Social Security Act.</li>
</ul>
<h2>Three Major Challenges Facing Optometry</h2>
<ol>
<li>Optometry is (or will) be judged by Federal and State governments, external certifying organizations, credentialing and privileging boards and third party insurers utilizing the medical model as the standard.</li>
<li>The $10 billion Graduate Medical Education (GME) program is based on the medical clinical training model and optometry&#8217;s clinical training, licensure requirements and advanced competency certification/re-certification do not meet GME expectations for participation.</li>
<li>The Center for Medicare/Medicaid Services Guidelines for Teaching Physicians, Interns and Residents prohibit optometric students from providing billable services in all training venues.</li>
</ol>
<h2>Detailed Structural Issues and Missed Opportunities</h2>
<h4>Postgraduate Clinical Training and Advanced Competency Certification</h4>
<ul>
<li>No mandatory postgraduate training is required for optometric licensure with the exception of Arkansas and Delaware.</li>
<li>No nationwide acceptance of optometric postgraduate specialty training, board certification and maintenance of certification presently exists, however, the American Board of Optometry(ABO) has been recognized by the Center for Medicare/Medicaid Services (CMS) for bonus payments (PQRS) and the American Board of Certification in Medical Optometry (ABCMO) has been recognized by the Joint Commission on Accreditation of Health Care Organizations (JCAHO) as a certifying agency.</li>
<li>Although a significant provider of Medicare services ($1.0 billion annually), optometry is not included in the Graduate Medical Education Program (GME) the educational component of Medicare because optometry&#8217;s clinical training model does not meet GME expectations.</li>
<li>Because of the above, current optometric residents are not recognized by the Department of Health and Human Services (HHS).</li>
<li>No expeditious route presently exists for board certification in General Optometry for most new optometric graduates. In 2012 there were only 367 available resident positions for 1600-1800 graduates.</li>
</ul>
<h4>Education</h4>
<ul>
<li>The increasing costs of optometric clinical training are passed on to students in the form of higher tuition. </li>
<li>Debt is too high for optometry school graduates averaging $140,000 (public) to $175,000 (private) vs. median annual income of $95,000.</li>
<li>The Bureau of Labor Statistics is projecting a 33% increase in demand for optometrists or 11,300 additional optometrists for the period (2010-2020), however, the student applicant pool is declining.</li>
<li>The declining student applicant pool for optometric schools (only 1.0 unique applicants per entering seat) is exacerbated by the proliferation of new schools (five schools added in recent years) and by expanded enrollments in existing schools. This is significant problem now and will likely be continued in the future. High debt to potential income and increasing commercialization of the profession are likely contributing factors.</li>
<li>Schools and colleges of optometry perpetuate a curriculum where optometric clinical training required for licensure is contained within the basic curriculum. GME only supports <em>postgraduate</em> clinical training and paid an average of $95,000 per medical resident to hospitals in 2010.</li>
</ul>
<h4>Medicare/Medicaid Compliance</h4>
<ul>
<li>CMS Guidelines for Teaching Physicians, Interns and Residents compliance vulnerabilities persist in all clinical teaching venues including externship sites, because optometric students are restricted by regulation from providing billable services. Also, private insurers apply CMS Guidelines. Two optometry schools have already been cited by the Office of Inspector General (OIG) for violations</li>
</ul>
<h2 id="steps">Eight Strategic Steps to a Secure Future for Optometry</h2>
<p><em>The proposed actions are highly sensitive, politically challenging and replete with timing and sequencing issues. However, there is no easy path, if optometry is to maintain its independence as a doctoral-level prescribing profession in a rapidly evolving health care system.</em></p>
<p>Again, the states are called upon to lead the profession, as Rhode Island did in the 1970&#8217;s. ASCO member institutions, NBEO and ACOE would likely follow with compensatory actions as they have historically done.</p>
<p>The steps are designed to facilitate synergism among State licensure requirements, postgraduate training, board certification/re-certification, optometric curricula; and position optometry to meet the expectations of private/Federal/State insurers, external certifying agencies, credentialing and privileging boards and the Graduate Medical Education Program (GME).</p>
<ol>
<li>
<p>States should mandate one or two years of mandatory post graduate training for optometric licensure. Only Delaware and Arkansas already mandate post graduate training. State Optometric Practice Laws amended to include — &#8220;One or (two) years of postgraduate clinical training, in an accredited program leading to Board Certification, is required for licensure.&#8221;</p>
</li>
<li>
<p>It would be necessary for optometric educational institutions to adjust curricula by awarding the O.D. degree after three years and to reclassify the 4th year as the first year of residency.</p>
<p><em>Two optometry colleges already offer accelerated programs, the New England College of Optometry offers a two year program and in the past, a three-year program and Salus University a three year program (deferred) while medical schools are now offering three year programs.</em></p>
<p>Consolidation of curriculum into three years can be accomplished by moving basic course material to pre-optometry requirements and extending the academic year to twelve months, permitting completion of all competency-based course material in three calendar years. Increased use of on-line instruction would facilitate completion of the accelerated curriculum.</p>
<p>A three calendar year curriculum would allow reallocation of 1600-1800 current 4th year student placements for postgraduate residency training.</p>
<p><em>A three-year O.D. degree program along with GME residency stipends would reduce optometry student debt $30,000 to $50,000 or more.</em></p>
<p><strong><em>U.S. Medical Schools (Allopathic &#038; Osteopathic) Offer 3-Year Degrees.</em></strong></p>
<p><em>In the last five years, at least four medical schools have initiated or are developing three-year programs including Mercer University School of Medicine, Lake Erie Osteopathic College of Medicine, Texas Tech University Health Sciences Center, Louisiana State University School of Medicine.</em></p>
<p><em>Also, three other schools have applied for Federal funds (CMS Innovation Grants) to develop three-year programs: Indiana University School of Medicine, East Tennessee State University Quillen College of Medicine, and the University of Kentucky College of Medicine.</em></p>
<p><em>The Carnegie Foundation for the Advancement of Teaching recommends all medical schools consider a three-year option.</em></p>
<p><em>Two Canadian Medical schools have three-year programs.</em></p>
<p><em>The three-year program will save the medical student $50,000 in debt.</em></p>
</li>
<li>
<p>National Board of Examiners in Optometry (NBEO) examination sequencing would need to be adjusted to accommodate new curriculum and mandatory postgraduate training.</p>
</li>
<li>
<p>One year of postgraduate training required for certification in General Optometry, two years for specialties and three years for fellowship trained sub-specialties.</p>
<p>Certifications boards need to developed and/or recognized for General Optometry (ABO) and the Specialties of Medical Optometry (ABCMO), Cornea/Contact Lenses, Pediatrics, and Vision Rehabilitation. Also, sub-specialty certification boards for Neuro-Optometry and Glaucoma developed.</p>
</li>
<li>
<p>To ensure consistent standards among various certification boards, establish an oversight board for all specialty certification boards, the American Board of Optometric Specialties (ABOS).</p>
<p>There is an immediate need for an oversight board as three newly developed optometric certifying boards, as well as other organizations awarding advanced competency status, have varying standards.</p>
</li>
<li>
<p>Only postgraduate clinical training programs accredited by the Accreditation Council on Optometric Education (ACOE) would be recognized for board certification. Mechanisms must be established to record resident patient care experiences to ensure the resident has received the quantity and diversity of patient care encounters to qualify for board certification.</p>
<p>Consideration should be given to accrediting existing and new schools to a maximum enrollment.</p>
<p>Care (CCOC) should be re-instated to ensure high standards of optometric patient care and sufficient patient volume at all clinical training venues</p>
</li>
<li>
<p>With completion of Steps 1-6, optometry would now be parallel with medicine and consistent with current and anticipated Federal/State policies, external certifying agencies, credentialing and privileging boards and private insurers&#8217; requirements.</p>
</li>
<li>
<p>Also, optometry’s clinical training model, licensure requirements and advanced competency certification/re-certification process would meet GME expectations and comply with CMS Guidelines for Teaching Physicians, Interns and Residents. AOA advocacy could now move forward with a credible position.</p>
<p>Since optometric clinical training is largely in outpatient facilities, GME regulations would need to be expanded from hospitals only to include outpatient patient care/clinical training.</p>
</li>
</ol>
<h2>Resources</h2>
<ul>
<li><a href="http://abcmo.org/">American Board of Certification in Medical Optometry</a></li>
<li><a href="http://americanboardofoptometry.org/board-certification/get-certified/">American Board of Optometry</a></li>
</ul>
<p>The post <a href="https://www.charlesmullen.com/eight-strategic-steps-to-a-secure-future-for-optometry/">Eight Strategic Steps to a Secure Future for Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>New England College of Optometry Commencement Remarks</title>
		<link>https://www.charlesmullen.com/new-england-college-of-optometry-commencement-remarks/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sun, 20 May 2012 12:00:49 +0000</pubDate>
				<category><![CDATA[Emerging Trends and Issues]]></category>
		<category><![CDATA[Federal and State Initiatives]]></category>
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					<description><![CDATA[<p>The model of inter-professional collaboration between optometry and ophthalmology pioneered at the New England College of Optometry formed the basis for affiliations between optometry colleges and medical schools in Philadelphia and Chicago.</p>
<p>The post <a href="https://www.charlesmullen.com/new-england-college-of-optometry-commencement-remarks/">New England College of Optometry Commencement Remarks</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
]]></description>
										<content:encoded><![CDATA[<p>Remarks of Charles F. Mullen, O. D.<br />
Upon Receiving the Honorary Degree, Doctor of Ocular Science<br />
New England College of Optometry Commencement<br />
Back Bay Events Center, Boston, MA<br />
May 20, 2012</p>
<p>Thank you for this high honor. It is a distinct privilege to join my fellow honorees, Dr. Joan Exford and Dr. David Reynolds on the dais this morning.</p>
<p>Trustees, President Scott, colleagues, honored guests and above all doctoral degree candidates.</p>
<p>I know you are eager to receive your degrees and celebrate your hard earned achievement. However, as tradition dictates—there will be no degrees until the old alumnus speaks.</p>
<p>Today, I join with families and friends in sharing the pride of an outstanding accomplishment—your Doctorate in Optometry.</p>
<p>You have been fortunate for the past four years to have received your professional education at an institution that is a leader in community-based clinical training and collaborative medical care.</p>
<p>Your future is bright with unparalleled opportunities in a rapidly evolving health care environment.</p>
<p>An excellent faculty and clinical attending staff have thoroughly prepared you for success in the areas of public health, patient care and clinical education.</p>
<p>In the area of public health&#8212;There are opportunities for you to meet the needs of special populations in medically underserved areas.</p>
<p>Those who live in poverty, the homeless, the frail elderly, the homebound, the developmentally disabled and the visually impaired.</p>
<p>The College’s subsidiary, New England Eye’s network of affiliations serves as the National model for outreach to special populations.</p>
<p>In patient care, practice opportunities are available in interdisciplinary care as optometrists manage more complex clinical conditions and diseases.</p>
<p>Telemedicine technologies and electronic health records provide the means for more effective patient management.</p>
<p>The model of inter-professional collaboration between optometry and ophthalmology pioneered at the New England College of Optometry formed the basis for affiliations between optometry colleges and medical schools in Philadelphia and Chicago.</p>
<p>The College’s nationally recognized research programs provide valuable insights to clinicians in the diagnosis, treatment and prevention of eye and vision conditions.</p>
<p>In clinical education, there are opportunities for you, as preceptors, to share your experiences in:</p>
<ul>
<li>patient-centered clinical education</li>
<li>and clinical training in interdisciplinary facilities.</li>
</ul>
<p>The College’s externship program is the most extensive and diverse in optometric education.</p>
<p>My education, like yours, prepared me not only to be a clinician, but also to contribute to the profession’s future.</p>
<p>Your professional status will provide entree to numerous civic and political activities.</p>
<p>In the past, the foresight and persistence of dedicated optometrists expanded the profession’s responsibilities by including pharmaceuticals, advanced clinical procedures, creation of the VA Optometry Service and participation in Medicare.</p>
<p>You are now called upon to make such a contribution.</p>
<p>Important matters face the profession of optometry. </p>
<p>Board Certification and Continued Competency initiatives require your attention and understanding of their place in your profession.</p>
<p>I encourage your active participation at the local, state or national level in planning for your profession’s future.</p>
<p>With major changes expected in health care policy at the Federal level, there are unprecedented opportunities for optometry to seek inclusion in three major Federal programs.</p>
<p>First and already in progress, is the expansion of optometry’s impact in the community health care system.</p>
<p>The New England College of Optometry was the first optometric institution to recognize its responsibility to the medically underserved community by developing affiliations with Boston Area community health centers. </p>
<p>Today, community health centers provide accessible and cost effective primary medical care to 20 million Americans in rural areas and poor urban neighborhoods.</p>
<p>However, only 20% of federally qualified health centers offer eye care services, despite the growing need in rural and inner-city America.</p>
<p>It is estimated that 5,000 optometrists would be needed in the Nation’s underserved areas over the next decade.</p>
<p>Federal funding is required to establish optometric services in all of the Nation’s community health centers.</p>
<p>Second, efforts must be made to attract more optometrists to medically underserved areas through financial incentives, such as tax free student loan repayment, by including optometrists in the National Health Service Corps.</p>
<p>Third is optometry’s inclusion in the Graduate Medical Education program, GME, the clinical educational component of Medicare. Participation in this $10 billion program would address:</p>
<ul>
<li>the increasing costs of clinical training as the scope of optometric practice continues to expand.</li>
<li>and growth in the demand for eye care services by the Medicare population.</li>
</ul>
<p>Optometrists have been participating physicians in the Medicare program since 1987 and currently provide $1 billion in services annually. </p>
<p>Now is the time to join medicine, dentistry and podiatry as a recipient of GME funding for clinical training.</p>
<p>Your participation in advancing initiatives in Community-Based Eye Care, the National Health Service Corps and the Graduate Medical Education Program is essential to their success.</p>
<p>Although the work ahead will be challenging, optometry’s inclusion in these three major Federal programs would provide eye care to tens of thousands of underserved Americans, new practice opportunities, and forever change the clinical training and financial landscapes of optometric education.</p>
<p>I am confident that the profession’s future leaders are in the auditorium today.</p>
<p>And as those before you, you must move forward with a balance of discretion and audacity.</p>
<p>Be willing to take risks with innovative approaches. </p>
<p>In whatever you do, follow the example of your Alma Mater and strive for pinnacles of excellence.</p>
<p>For excellence is a mandate not an option.</p>
<p>Values will always be a source of strength. Character and contribution will define your success.</p>
<p>For in the final analysis, it is neither about financial rewards nor power, but pride in your professional and personal achievements. </p>
<p>Thank you and congratulations.</p>
<p>The post <a href="https://www.charlesmullen.com/new-england-college-of-optometry-commencement-remarks/">New England College of Optometry Commencement Remarks</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>How to Position Optometry for Inclusion in the Graduate Medical Education Program (GME)</title>
		<link>https://www.charlesmullen.com/how-to-position-optometry-for-inclusion-in-the-graduate-medical-education-program-gme/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Mon, 19 Dec 2011 19:44:50 +0000</pubDate>
				<category><![CDATA[Emerging Trends and Issues]]></category>
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		<guid isPermaLink="false">https://www.charlesmullen.com/?p=608</guid>

					<description><![CDATA[<p>Clinical education is inherently inefficient and expensive with costs likely to rise as a result of increased training requirements as the profession continues to expand clinical practice.</p>
<p>The post <a href="https://www.charlesmullen.com/how-to-position-optometry-for-inclusion-in-the-graduate-medical-education-program-gme/">How to Position Optometry for Inclusion in the Graduate Medical Education Program (GME)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2012 Position for GME.pdf">How to Position Optometry for Inclusion in the Graduate Medical Education Program (PDF)</a></p>
<p><a href="https://www.charlesmullen.com/wp/wp-content/uploads/publications/2012 Position for GME.ppt">How to Position Optometry for Inclusion in the Graduate Medical Education Program (PPT)</a></p>
<p>The post <a href="https://www.charlesmullen.com/how-to-position-optometry-for-inclusion-in-the-graduate-medical-education-program-gme/">How to Position Optometry for Inclusion in the Graduate Medical Education Program (GME)</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>Testimony in Support of Senate Bill 1255, An Act Relative to the Modernization of Optometry</title>
		<link>https://www.charlesmullen.com/support-of-senate-bill-1255-an-act-relative-to-the-modernization-of-optometry/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Wed, 02 May 2007 22:50:05 +0000</pubDate>
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					<description><![CDATA[<p>Thank you for the opportunity to testify before the Joint committee on Public Health.  Accordingly, I respectfully request that this Committee release SB 1255 with a favorable report.</p>
<p>The post <a href="https://www.charlesmullen.com/support-of-senate-bill-1255-an-act-relative-to-the-modernization-of-optometry/">Testimony in Support of Senate Bill 1255, An Act Relative to the Modernization of Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<p>I am Charles Mullen. I am a graduate of the University of Virginia and received my Doctor of Optometry degree from the New England College of Optometry. I have over 36 years of experience in optometric education at three institutions. I am the former President of the Illinois College of Optometry and former Director of the Department of Veterans Affairs Optometry Service, the largest optometric patient care and clinical training program in the Nation. Currently I serve on the Board of Trustees of the Pennsylvania College of Optometry and the Board of Directors of the New England Eye Institute. I am also an Adjunct Clinical Professor at the State University of New York.</p>
<p>My remarks today pertain to the impact that the current restriction on Massachusetts optometrists treating glaucoma has on the clinical education of students enrolled at the New England College of Optometry.  From a national perspective, this restriction places the College and its faculty at a competitive disadvantage for the best and brightest applicants for admission.  Upon learning of the restriction in the treatment of glaucoma, many highly qualified applicants and, for that matter, many highly qualified optometrists seeking a faculty appointment at the New England College of Optometry choose other Colleges of Optometry – simply because Massachusetts cannot offer the comprehensive opportunities they are seeking.  No other optometry school across the country faces this problem.</p>
<p>Forty-nine states permit optometrists to treat glaucoma. It is now the national expectation; if not the standard.  Students of the New England College of Optometry are expected upon graduation to be fully prepared to treat eye disease; including, the management of patients with glaucoma.  Yet, without the ability to practice in Massachusetts, the New England College of optometry must seek training venues outside the Commonwealth or in federal facilities where the treatment of glaucoma is permitted. This is ironic given that Massachusetts is known to be a world leader in health care education.  Forty-nine states and the federal system allow for optometrists to treat glaucoma, but the home state of one of the best optometry schools does not.  Again, no other optometry school in the Nation is so limited.</p>
<p>Nationwide, optometrists provided $846 million in eye care services to Medicare beneficiaries in 2006.  As the incidence of glaucoma increases with age and with the onset of the “baby boomer” retirement, graduates of the New England College must be fully prepared to meet the health care needs of the rapidly growing elderly population.  This means they must be able to treat glaucoma.</p>
<p>I can assure you that optometric education and the profession of optometry are constantly evolving. Advances in the biomedical and visual sciences impact both the methods of treating patients and the methods of educating students. Given this quickly changing environment, it is essential that optometrists in Massachusetts be granted the authority to treat glaucoma – allowing both the New England College of Optometry and its students to remain competitive on a national level.</p>
<p>Thank you for the opportunity to testify before the Joint committee on Public Health.  Accordingly, I respectfully request that this Committee release SB 1255 with a favorable report.</p>
<p>Testimony of Charles F. Mullen, O.D.<br />
Delivered May 2, 2007</p>
<p>The post <a href="https://www.charlesmullen.com/support-of-senate-bill-1255-an-act-relative-to-the-modernization-of-optometry/">Testimony in Support of Senate Bill 1255, An Act Relative to the Modernization of Optometry</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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		<title>My Best Day in Optometric Education: Signing the Affiliation Agreement Between  the Illinois College of Optometry and the University of Chicago</title>
		<link>https://www.charlesmullen.com/my-best-day-in-optometric-education-signing-the-affiliation-agreement-between-the-illinois-college-of-optometry-and-the-university-of-chicago/</link>
		
		<dc:creator><![CDATA[Charles Mullen]]></dc:creator>
		<pubDate>Sat, 30 Sep 2006 21:00:53 +0000</pubDate>
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					<description><![CDATA[<p>Although I remain convinced that affiliation with academic medicine will significantly enhance both clinical education and patient care for both optometry and ophthalmology, there are other challenges that also need to be addressed before optometric clinical education can reach its full potential.</p>
<p>The post <a href="https://www.charlesmullen.com/my-best-day-in-optometric-education-signing-the-affiliation-agreement-between-the-illinois-college-of-optometry-and-the-university-of-chicago/">My Best Day in Optometric Education: Signing the Affiliation Agreement Between  the Illinois College of Optometry and the University of Chicago</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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										<content:encoded><![CDATA[<p>In 1996, I accepted the position of president, Illinois College of Optometry (ICO) and brought with me nearly thirty years of experience in collaborative relationships between optometry and ophthalmology. My conviction of the importance of cooperation between the two professions began at the New England College of Optometry in Boston’s community health centers, was carried forward at the Pennsylvania College of Optometry with the affiliation with Hahnemann University’s Department of Ophthalmology. It was tempered by my federal government experience as the director of optometry service at the VA and was fully realized with the signing of a comprehensive patient care, education and research affiliation between ICO and the University of Chicago (UofC).</p>
<p>Thus, October 16, 1997 was my best day in optometric education and reinforced my conviction that cooperation between the two disciplines presents numerous opportunities for enhancing patient care and clinical training for students and residents, and for fostering a better understanding and respect between the two professions, while reinforcing their natural synergism. The affiliation continues to this day, as a vibrant patient care and clinical education collaboration.</p>
<p>Although I remain convinced that affiliation with academic medicine will significantly enhance both clinical education and patient care for both optometry and ophthalmology, there are other challenges that also need to be addressed before optometric clinical education can reach its full potential. Some schools and colleges of optometry have addressed several of these challenges, but much still needs to be done. With continued support from the American Optometric Association (AOA) and the Association of Schools and Colleges of Optometry (ASCO), many of these objectives can be achieved within the next five years.</p>
<ul>
<li>Include optometry in the federal programs of Graduate Medical Education (GME) and the National Health Service Corps (NHSC). </li>
<li>Increase collaboration with community health care programs and increase commitment to public health responsibilities. </li>
<li>Downsize large single purpose and costly campus-based clinics and replace with smaller referral centers and community-based training sites. </li>
<li>Achieve Joint Commission for the Accreditation of Health Care Organizations (JCAHO) accreditation for campus-based and college-operated clinical facilities. </li>
<li>Reorganize the colleges’ clinical programs into separate legal entities with their own administrations and governing boards. </li>
<li>Implement incentive-based compensation (IBC) plans for faculty that integrate student and resident training. </li>
<li>Develop and operate ophthalmic surgi-centers in partnership with medical school affiliates. </li>
<li>Establish a national clearinghouse and placement service for optometric externships. </li>
<li>Fund the Regional Centers of Eye Care Excellence (RCEE) within the Department of Veterans Affairs (VA) and expand the Vision Impairment Centers to Optimize Remaining Sight (VICTORS). </li>
</ul>
<p>Dr. Mullen was president of the Illinois College of Optometry from 1996 to 2002. He is currently on the Board of Trustees at the Pennsylvania College of Optometry and on the Board of Directors of the New England Eye Institute.</p>
<p>Journal of Optometric Education, 2006</p>
<p>The post <a href="https://www.charlesmullen.com/my-best-day-in-optometric-education-signing-the-affiliation-agreement-between-the-illinois-college-of-optometry-and-the-university-of-chicago/">My Best Day in Optometric Education: Signing the Affiliation Agreement Between  the Illinois College of Optometry and the University of Chicago</a> appeared first on <a href="https://www.charlesmullen.com">Charles F. Mullen</a>.</p>
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