Element 3.3: Takeaways from a recent LCME webinar

It has been a goal of mine to use this blog to foster information sharing across the medical education accreditation community.  So, I was thrilled when Dr. Polly Hofmann accepted my invitation in the last newsletter to submit a piece for this space. She describes her takeaways from a recent LCME webinar that outlined upcoming changes to accreditation expectations involving Element 3.3.

The LCME webinars are an invaluable resource for medical education professionals, and we share this post in an effort to amplify the LCME’s work and support schools that are closely examining their diversity and inclusion efforts in light of recent federal and state legislative changes.  Note that Dr. Hofmann, MSAG, and this space do not represent that we are or that we speak for the LCME.

As the LCME has noted on their website, “The LCME Secretariat and the publications on [the LCME] website are the only official sources of information regarding LCME policies, procedures, and issues related to the intent of elements.” Anyone who has specific questions may wish to direct them to the Secretariat. 

– Lois Margaret Nora, MD, JD, MBA

Dear Colleagues,

The LCME Secretariat Webinar in March focused on the upcoming changes to Element 3.3, Diversity Programs and Partnerships.  These changes impact student and faculty diversity efforts, and they will be incorporated into the 2025-2026 Data Collection Instrument (DCI).  The changes were, in part, a response to the Supreme Court ruling that race-based college admissions policies are in violation of the Constitution.  This ruling was accompanied by a landslide of legislative activity related to diversity in various states. Thus, the LCME reconsidered Element 3.3 to ensure all schools would be able to meet accreditation requirements without being in conflict with state and federal law.  The following describes my takeaways from the points presented, along with a synopsis of the webinar Q&A.

Addressing Student Diversity

After offering some historical perspective, the Secretariat discussed changes to how diversity is handled.  A formal policy with diversity categories is no longer required. However, tables in the 2025-2026 DCI will continue to require school-identified diversity categories for students with reporting of outcomes in offers and enrollment in the MD program. Further, a diversity pathway program(s) with tracking of outcomes continues to be required. A new narrative response question in the 2025-2026 DCI will be “Describe how the medical school expresses its commitment to the value of diversity in the academic learning environment and aligns this commitment with its mission.”1 Thus, a “mission statement, strategic plan, or policy must demonstrate the school’s commitment to the value of diversity in the academic learning environment.”1

The Secretariat and LCME recognize that some schools may elect to change their student diversity categories and, as such, have minimal outcomes data to support the efficacy of a given activity.  For example, a school may shift from presenting 10 years of data on outcomes associated with race-conscious efforts to presenting limited data on efforts focused on students from underserved ZIP codes and/or students of lower socioeconomic status.  A reduction in available data is expected with a change in diversity categories and, depending on the specifics of that school, would at most warrant monitoring by the LCME.  In a nutshell, the LCME values diversity, but also offers flexibility to schools to select their unique student diversity categories based on the mission of the school.  Please note, the LCME does not prohibit schools from continuing to have race or gender as part of their school-identified diversity categories.  However, early and clear communication by schools with their own General Counsel and system leadership about their student diversity categories is recommended.

Addressing Faculty Diversity

Faculty and senior administrator diversity categories and related reporting of outcomes have been eliminated from the 2025-2026 DCI. Consistent with this, tables in this portion of the DCI have been modified to remove faculty and senior administrators. In addition, Element 3.3 will now read:

“A medical school has effective policies and practices in place, and engages in ongoing, systematic, and focused recruitment and retention activities, to achieve mission-appropriate diversity outcomes among its students, faculty, senior administrative staff, and other relevant members of its academic community. These activities include the use of programs and/or partnerships aimed at achieving diversity among qualified applicants for medical school admission and the evaluation of program and partnership outcomes.”1 (Strike-through added to show exact text to be removed). 

To address the important role of faculty in diversity, the LCME added a new narrative response to the 2025-2026 DCI.  Specifically, “Describe how the medical school ensures that its faculty and senior administrative staff are prepared to support its diverse student body. How does the school determine that this support is adequate and effective?”1

For Schools Shortly Undergoing Review

The Secretariat provided direction to schools that are actively preparing for a survey visit and using the 2024-2025 or older DCI.  They clarified that Element 3.3 performance, starting immediately and through June 2025, “will be based on the following:

  • Mission statement, strategic plan, or policy that demonstrates the school’s commitment to the value of diversity in the academic learning environment

  • Mission-aligned diversity categories for students and tracking of recruitment outcomes

  • Pathway programs and partnerships, and tracking of program outcomes”1

In addition, effective immediately, schools do not need to have a policy defining the student diversity categories on their website.

Questions and Answers (paraphrased)

Q: Given that the public will have the opportunity to provide feedback about the changes in Element 3.3, what happens to these planned DCI changes if comments are extensive and concerning?

A: Any change to the DCI requires 18 months to go through proper vetting.  As such, the 2025-2026 DCI changes as presented will be going forward.

 

Q: What will happen to schools already given an unsatisfactory for Element 3.3 based on a failure to, for example, collect outcomes data on faculty diversity or any such information or programs that are no longer required in the 2025-2026 DCI? 

A: These schools will have their final report amended, and the citation will be expunged.  They will not be required to respond to the citation in the school status report.  However, caution is warranted as some citations involving Element 3.3 are based on criteria that will continue to be needed for accreditation.  As an example, outcomes data for pipeline programs aimed at increasing the number of diverse student applicants is still required.  If a school is unsure whether they should respond to a 3.3 citation, the Secretariat should be consulted.

 

Q: For schools about to undergo a self-study or site visit using an older DCI, will Element 3.3 tables and narrative responses related to faculty and senior administrators still be a part of their upcoming review?

A: No, the LCME will no longer look at or take this information into consideration. Further, schools that have not yet completed the Element 3.3 tables specifically related to faculty and senior administrators may leave those table cells blank and instead provide a notation like “Given that the LCME is no longer looking at this information, it was not collected and reported.”

 

Q: Is it required that the word “diversity” be used in response to Element 3.3.

A: No, a synonym or descriptive phrase is acceptable as long as the principle or concept is preserved.

 

Q: How far out do schools need to track students in pipeline programs?

A: For college students, it is reasonable to look at whether they went on to apply to medical school.  For pipelines that work with younger students, such as high school students, the outcomes might include how they rated the program and how it affected their next step, e.g., college enrollment.

 

I encourage those who are interested in this topic to download the webinar slides from the LCME website.  The revised tables and narrative responses are presented.

 

— Polly Hofmann, PhD

Professor & Senior Executive Associate Dean of Faculty Affairs Emeritus

University of Tennessee College of Medicine

 

1 Connecting with the LCME Secretariat Webinar, March 7, 2024.  Speakers Veronica Catanese, MD, MBA; Barbara Barzansky, PhD, MHPE; Robert Hash, MD, MBA.  Slides can be found at https://lcme.org/event/mar-2024-connecting-webinar/

 

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