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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Oklahoma Department of Career & Technology Education (1976/2016)
                  (The dates provided are the date of initial listing as a recognized agency and the date of the agency’s last grant of recognition.)
 
2.
Action Item:   Petition for Continued Recognition
 
3.
Scope of Recognition:   State agency for the approval of public postsecondary vocational education.
4.
Date of Advisory Committee Meeting:   December, 2015
 
5.
Staff Recommendation:   Continue the agency's current recognition and require the agency to come into compliance within 12 months, and submit a compliance report 30 days after the 12 month period that demonstrates the agency's compliance with the issues identified below.
 
6.
Issues or Problems:   It does not appear that the agency meets the following sections of the Secretary’s Criteria for Recognition. These issues are summarized below and discussed in detail under the Summary of Findings section.

-- Additional information is requested as to whether and how technology centers that are not part of the Baldrige pilot project are being reviewed, and especially whether they are being reviewed within the specified five year review cycle).
[§603.24(a)(1)(ii)]

-- The agency is requested to revise its Accreditation Guidelines to include the requirement that administrative staff, teaching faculty, students, governing body, and other appropriate constituencies be involved in the development of the self-study document.
[§603.24(a)(3)(ii)(A)]

-- Additional information is needed regarding the agency's formal standards review process and procedures.
[§603.24(b)(1)(iii)]

-- The agency is requested to provide samples of completed on-site review team reports as documentation of the type of review team feedback that is provided to institutions following the on-site review.
[§603.24(b)(1)(iv)]

-- The agency is requested to provide additional information and documentation as to how it encourages experimental and innovative programming, as required under this section.
[§603.24(b)(1)(v)]

-- The agency is requested to attach supporting documentation demonstrating the steps of the agency's approval process. [§603.24(b)(1)(vi)]

-- The agency is requested to provide documentation of the steps it undertakes to obtain feedback related to the regular and ongoing review of its standards, including documentation of input from the constituencies specified in its published standards review procedures.
[§603.24(b)(1)(vii)]

-- The agency is requested to revise its on-site review procedures in order to formally solicit feedback from students and other personnel during the course of the on-site review team's visit.
[§603.24(b)(2)(i)]

-- The agency is requested to provide supporting documentation in the form of a sample completed on-site review report.
[§603.24(b)(2)(ii)]

-- The agency is requested to provide supporting documentation demonstrating that it is implementing the requirement specified within its policies and procedures that an institution be given an opportunity to respond to the on-site review report.
[§603.24(b)(2)(iii)]

-- The agency is requested to describe how its policies, procedures, and standards require that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of the agency's requirements [§603.24(d)(1)]

-- The agency is requested to describe how it verifies that its institutions are implementing its policies, procedures, and standards regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of this verification.
[§603.24(d)(2)]



EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Oklahoma Board of Career and Technology Education (OBCTE) is recognized for the approval of public postsecondary vocational education programs offered at institutions in the State of Oklahoma that are not under the jurisdiction of the Oklahoma State Regents for Higher Education. The OBCTE is vested with the power to govern and establish criteria and procedures for 29 technology center districts encompassing 57 campuses across the state. Approval (accreditation) by the OBCTE enables the technology centers to receive funding under Title IV, as well as under other federal programs related to vocational education.

There have been no complaints filed against the agency since its last appearance before the NACIQI.

 
 
Recognition History
 
The OBCTE was first recognized in 1976 and has held continued recognition since that time. The agency's last full review was considered at the Fall 2011 NACIQI meeting. At that time, the agency was requested to submit a report on certain compliance issues at the Fall 2013 NACIQI meeting. The report was submitted as requested but, due to its director's retirement, the agency was granted an extension for good cause and requested to submit an additional report on two remaining compliance issues. That report was considered and accepted at the Fall 2014 NACIQI meeting, and the agency was granted continued recognition for a period of one year, which was the maximum amount of time allowable under its four-year recognition period as a state approval agency. The agency subsequently submitted its next full petition for renewed recognition, which is the subject of the current staff analysis.


PART II: SUMMARY OF FINDINGS

 
§603.24 Criteria for State agencies
The following are the criteria which the Secretary of Education will utilize in designating a State agency as a reliable authority to assess the quality of public postsecondary vocational education in its respective State.
(ii) Clearly sets forth the scope of its objectives and activities, both as to kinds and levels of public postsecondary vocational institutions or programs covered, and the kinds of operations performed;

 
The state's statutes specify that the Board will be responsible for the supervision of the ODCTE, as well as for the state's technology center schools and colleges, except for three colleges whose programs are under the supervision of the state's Board of Regents. The Board may enter into agreements with federal agencies for participation in various federal programs. The Board is responsible for vocational education curriculum development in the state and is responsible for developing plans to provide vocational offerings that are accessible to all students. It is responsible for acquiring equipment, materials, supplies, and property for the operation of the state's technology center schools. It is responsible for developing plans for teacher training and providing for the installation of technology in order to modernize vocational education programs in the state.

The agency's narrative states that it is responsible for "developing, administering, and coordinating the evaluation and approval of public postsecondary programs not offered for college credit in Oklahoma's postsecondary institutions." However, it also notes that, in its Baldrige pilot programs, the selection and training of evaluation teams, the scheduling of on-site review, and the development of on-site review reports is "done in collaboration with others." No information is given as to who these "others" are, how they are qualified to take over this responsibility from the Accreditation Unit, or why they have been given this responsibility.

The agency states that during 2014-2015, it conducted eight comprehensive on-site reviews, two of which were Baldrige pilot projects. During the 2015-2016 school year, eight evaluations are being conducted, all of which are of the Baldrige pilots. More information is also requested as to the ongoing evaluation of technology centers that are not in the Baldrige pilot program, and particularly whether those schools are still being reviewed as originally scheduled (in other words, are they being reviewed within the specified five year review cycle).

The agency provided a variety of documentation related to the requirements of this section. However, additional information and documentation are still needed.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information regarding the ongoing evaluation of technology centers that are not in the Baldrige pilot program, and particularly whether those schools are still being reviewed as originally scheduled (in other words, are they being reviewed within the specified five year review cycle).

In response to the draft staff analysis, the agency provided additional narrative regarding the evaluation of the technology centers that are part of the Baldrige pilot project. However, the agency did not address ED staff's question of whether and how centers that are not part of the Baldrige pilot are being monitored. Additional information is still requested in this area.
 

(A) Self-analysis shall be a qualitative assessment of the strengths and limitations of the instructional program, including the achievement of institutional or program objectives, and should involve a representative portion of the institution's administrative staff, teaching faculty, students, governing body, and other appropriate constituencies.

 
All technology centers are subject to comprehensive reviews at least every five years. As part of the review process, the institution must prepare a self-study document with input from a variety of stakeholders, including current and former students, local board of education, technology center advisory committees, agency partners, other stakeholders, and the institution's faculty and administrators. The evaluations must be comprehensive and address strengths and weaknesses in both administrative and programmatic areas. Institutions and their representatives are provided with instruction on what must be addressed in the institutional self-study document.

Under the current system, instructions are provided with summary evaluation questionnaires that must be completed for programmatic and administrative areas. The information contained in the self-study is evaluated and verified by agency staff and review team members, who then prepare reports that lead to action plans that must be developed by the institutions and accepted by the state's Board.

Under the pilot system, the institutions must address over 350 criteria related to various areas of self-assessment. Because the Baldrige materials are proprietary, the agency was unable to provide documentation related to those criteria. The agency reports that the self-study is divided into two parts. There is a five-page organizational profile and a 50-page "performance system" that is reportedly composed of six categories that "define a technology centers' processes and the results it achieves." ED staff has serious concerns related to the pilot assessment. First, to have an assessment tool that is not publicly available is not acceptable. Second, ED staff has concerns regarding the assessment's possible lack of specificity to vocational technical education, as opposed to a focus merely on process. The Baldrige "Areas of Focus" that the agency appears to be using as standards in the pilot projects are brief, general, and not tailored to vocational education.

As documentation, the agency provided a copy of the summary evaluation form tied to its current standards, and a sample questionnaire tied to the evaluation of administration and personnel services. However, much additional information and supporting documentation are needed regarding the agency's use of the Baldrige system in the self-study process.

Analyst Remarks to Response:
In the draft staff analysis ED staff raised concerns related to the agency's implementation of its Baldrige pilot project, including the agency's use of a Baldrige assessment tool that was not publicly available and was not specific to vocational education in the state of Oklahoma.

In its response to the draft analysis, the agency notes that it has modified its review process based upon feedback received during the implementation of its Baldrige pilot project. The agency has developed an Accreditation Guidelines document for the review of the state's technology centers. Because the guidelines have been developed by the state agency, they are publicly available. A section in the guidelines on the self-assessment application (i.e., self-study) contains detailed information for use by the state's technology centers in preparing their self-study documents. The guidelines require that self-studies include a five-page institutional overview, followed by a 75-page self-study that addresses the state's requirements regarding: leadership and administration; instruction and training; support services; measurement and analysis; personnel; operations; and system impact. Although the newly developed guidelines specify the information that is to be included in the self-study document, it does not appear to specify that administrative staff, teaching faculty, students, governing body, and other appropriate constituencies be involved in the development of the center's self-study.

The agency is requested to revise its Accreditation Guidelines to include the requirement that administrative staff, teaching faculty, students, governing body, and other appropriate constituencies be involved in the development of the self-study document.
 

(iii) Provides advance public notice of proposed or revised standards or regulations through its regular channels of communications, supplemented, if necessary, with direct communication to inform interested members of the affected community. In addition, it provides such persons the opportunity to comment on the standards or regulations prior to their adoption;

 
In its narrative, the agency notes that its accreditation advisory committee meetings are open to the public. ED staff verified that meeting announcements are provided on the agency's web site. The agency states that feedback regarding its standards will be solicited electronically for at least 30 days. The agency makes an effort to directly solicit feedback from identified stakeholder by sending a "blast" email to certain individuals in an effort to gain their input into the standards review process. The agency states that revised standards are implemented in the school year following their adoption by the Board.

As documentation the agency provided a list of 25 individuals that it will email in order to notify them of the standards review process. While this is commendable, the agency did not provide any documentation related to its most recent standards review process (online notices, categories of participants, changes that resulted from the most recent standards review process, etc.). ED staff also questions how the agency will be able to review and revise the Baldrige standards that it is moving to implement in its pilot projects, since the standards are proprietary. Additional information is also requested as to how the agency will be able to solicit feedback and alter its standards under the Baldrige model.

The agency is requested to provide additional information and documentation regarding its most recent standards review process, including participants, feedback received, and the resulting revisions to its standards. More information is also needed on how the Baldrige standards can be revised if they are implemented across all of the technology centers in the future.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information and documentation regarding its most recent standards review process, including participants, feedback received, and the resulting revisions to its standards. More information was also needed on how the Baldrige standards can be revised if they are implemented across all of the technology centers in the future.

In its response to the draft analysis, the agency clarified that the Baldrige standards currently in use in its pilot project are available to the public. ED staff further notes that, based upon feedback received during the Baldrige pilot project, the agency has developed a hybrid review model using its own Accreditation Guidelines document, which contains the standards and procedures against which the state's technology centers will be reviewed. Because this is a document that has been developed by the state, it may be modified as necessary. This addresses staff concerns that the state would not be able to modify its standards and procedures if it continued to use the Baldrige model, rather than the hybrid that will now be used.

Although the agency has addressed the staff concerns regarding the ownership of its standards and procedures, it has not provided the requested documentation regarding its most recent standards review process. An agenda from an October 2015 Board meeting indicates that that board accepted the state's standards. However, it does not provide any documentation about how feedback was actively solicited regarding changes to the standards, which constituent groups provided feedback, how proposed changes to the standards were published for public comment, etc.

Additional information is needed regarding the agency's formal standards review process and procedures.
 

(iv) Secures sufficient qualitative information regarding the applicant institution or program to enable the institution or program to demonstrate that it has an ongoing program of evaluation of outputs consistent with its educational goals.

 
The agency states that the summary evaluation questionnaires that are used during the course of the agency's current comprehensive on-site evaluation process provide the agency with sufficient qualitative information to show that a technology center's programs are meeting institutional goals. The agency also states that it collects data on student enrollment, placement, completion, as well as follow-up data and that this is put into a format for on-site evaluators to use. The agency also states that information from previous evaluations is compiled and provided to evaluators to use during the on-site assessment.

As documentation, the agency did provide a sample technology center profile. The profile contained information on demographics/enrollment, district population, financial data, number of instructors and their certifications, completion data, and placement data.

The agency did not provide any completed summary evaluation questionnaires as evidence of the information that is collected during on-site reviews, nor did it provide any samples of the compilations of previous evaluations that it states are also used by review team members during the on-site assessment. It also did not provide any information or supporting documentation demonstrating how the requirements of this section are met under the Baldrige model that the state is piloting and apparently plans to implement in the near future. Additional information and supporting documentation are needed in these areas.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to completed summary evaluation questionnaires and other site review team materials as evidence of the information that is collected during on-site reviews.

In its response, the agency provided several documents that it states are related to the current year's pilot reviews. However, none of the documents are examples of on-site review team (evaluator) reports. These documents do not appear to be used to provide feedback to the technology centers for use in developing compliance or improvement plans. Additional documentation is still needed in this area.

The agency is requested to provide samples of completed on-site review team reports as documentation of the type of review team feedback that is provided to institutions following the on-site review.
 

(v) Encourages experimental and innovative programs to the extent that these are conceived and implemented in a manner which ensures the quality and integrity of the institution or program;

 
The agency listed steps that it apparently feels could be used to encourage experimental and innovative programs. It did not indicate that it is actually following these steps, nor did it provide any information or documentation demonstrating how it currently encourages experimental and innovative programs, as required under this section. Additional information and documentation as to how the requirements of this section are being addressed under the agency's current practices, as well as information as to how the requirements would be met under the Baldrige model, are therefore requested.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information and documentation as to how it encourages experimental and innovative programming.

In its response to the draft analysis, the agency states that one of its technology centers has recently applied to be an experimental site for competency based education. No supporting documentation was provided, since presumably the center application has not yet been finalized.

The agency is requested to provide additional information and documentation as to how it encourages experimental and innovative programming, as required under this section.
 

(vi) Demonstrates that it approves only those institutions or programs which meet its published standards; that its standards, policies, and procedures are fairly applied; and that its evaluations are conducted and decisions are rendered under conditions that assure an impartial and objective judgment;

 
The agency has described its review process under this and previous sections. Institutions that are found out of compliance with the agency's standards are put on probation for one year. If the institution has not brought itself into compliance with the agency's standards within one year, its approval/accreditation is withdrawn. The institution may then reapply for approval/accreditation after one year.

ED staff notes that under the agency's current system, an institution that is shown to have areas of non-compliance or weakness is required to develop an action plan. Under the current system, the institution must develop the plan within 60 days. Under the agency's Baldrige pilot program, the plan must be developed within six months. ED staff is unclear about the timelines for the approval and implementation of these action plans, how progress towards compliance is monitored, and how these timelines are factored into the agency's requirement that areas of non-compliance are corrected within the one-year probationary period.

As documentation, the agency provided information regarding the ethics requirements for its on-site evaluators. Evaluators who are state employees must abide by the state's extensively detailed ethics rules. Evaluators who are not state employees must certify that they have no ethics conflicts by signing an attestation.

The agency did not provide any documentation related to the institutional approval process. For example, the following types of documentation would be useful to demonstrate the steps of the approval process: an on-site review report noting areas of non-compliance with the agency's standards; the action plans developed as a result of that on-site review report; minutes of Board meetings where that on-site review report, institutional response and action plan were discussed and an approval/accrediting decision was reached; the decision letter that was sent to the institution notifying it of the Board's decision and outlining any follow-up measures that must be taken; documentation that the institution took corrective action; subsequent action by the Board accepting or rejecting the institution's corrective measures; and so forth. Additional documentation is requested that demonstrates how the agency implements its program approval process and approves only those institutions that meet its standards. Information is especially needed related to institutional approval under the pilot Baldrige model.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information about its timelines for requiring compliance, as well as documentation demonstrating the steps of the agency's approval process, such as: an on-site review report noting areas of non-compliance with the agency's standards; the action plans developed as a result of that on-site review report; minutes of Board meetings where that on-site review report, institutional response and action plan were discussed and an approval/accrediting decision was reached; the decision letter that was sent to the institution notifying it of the Board's decision and outlining any follow-up measures that must be taken; documentation that the institution took corrective action; subsequent action by the Board accepting or rejecting the institution's corrective measures; and so forth.

In its response to the draft analysis, the agency described the steps of the approval process and referenced supporting documentation related to those steps. However, the agency did not attach the supporting exhibits to this section for staff review. The agency is requested to upload the supporting documentation/exhibits to each section in order that they may be viewed by staff and the Committee members in conducting their analysis.

The agency is requested to attach supporting documentation demonstrating the steps of the agency's approval process.
 

(vii) Regularly reviews its standards, policies and procedures in order that the evaluative process shall support constructive analysis, emphasize factors of critical importance, and reflect the educational and training needs of the students;

 
This section requires that an agency have (and implement) an established process to evaluate its standards, policies, and procedures on a regular basis in order to determine that they are appropriate to the educational and training needs of the students who are served by the agency's approved/accredited institutions.

The agency reports that its standards are reviewed annually by its Accreditation Advisory Committee and that the Advisory Committee makes recommendations to the Board, which is responsible for "selecting" (rather than approving) the agency's standards. No information or documentation was provided to describe the agency's established process for the ongoing review, revision, and approval of its standards, policies,and procedures.

ED staff has three areas of serious concern regarding the agency's compliance with the requirements of this section:

1) The agency has not demonstrated that it has a written policy/procedure for the regular evaluation of its standards, nor that such a policy/procedure is being followed. The expectation for standards review under this section is that the agency's standards will be formally reviewed on a regular and ongoing basis, with input actively solicited from the agency's stakeholder groups, including students, regarding the effectiveness and appropriateness of the agency's standards for the institutions in that state. Those standards, which should be specific to the review of the state's technology centers, should be revised based upon that stakeholder input. Any proposed revisions should subsequently be available for public comment, which should be factored into the acceptance or rejection of the proposed standards revisions. Once approved by the Board, the revised standards should then be made publicly available and consistently implemented until they are reevaluated under their next regularly scheduled review.

2) No information has been provided as to how the agency will be able to implement a standards review process if it moves to replace its current state standards with the Baldrige standards that are currently being used in the agency's pilot program. The Baldrige process is proprietary and not under the control of the state agency. The agency stated in a previous section that it was unable to share some information about the Baldrige process with ED due to this fact. This is not acceptable. How will feedback be obtained from the state's stakeholders regarding the Baldrige process if there is no access granted to those who have not been licensed to view or use the Baldrige materials? Since the Baldrige standards, processes, and procedures belong to a proprietary organization and do not belong to the state, how can the state expect to make any necessary revisions to them based upon feedback received from its stakeholders? The state agency, and not the Baldrige organization, is the entity recognized by the Secretary. ED staff cannot emphasize strongly enough that it is not acceptable for the state to cede control of its standards, policies, and procedures governing state vocational education programs to another organization.

3) The state agency is currently recognized by the Secretary a nationally recognized state approval agency for public postsecondary vocational education. As such, the agency has been determined to be a reliable authority as the the quality of public postsecondary vocational education in the state of Oklahoma. The Baldrige organization, whose program and materials the state is piloting, has very general standards that are used in a variety of settings. The Baldrige standards are not specific to vocational education, nor to vocational education in the state of Oklahoma.

Much additional information and documentation are needed to demonstrate that the state has a process in place to review its standards, policies, and procedures, that the state would maintain complete control of its standards, policies, and procedures under the proposed Baldrige review process, and that it has developed standards that are specific to the evaluation of public postsecondary vocational education in the state of Oklahoma.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information and documentation to demonstrate that the state has a process in place to review its standards, policies, and procedures, that the state would maintain complete control of its standards, policies, and procedures under the proposed Baldrige review process, and that it has developed standards that are specific to the evaluation of public postsecondary vocational education in the state of Oklahoma.

In its response to the draft analysis, the agency notes that its standards review procedure is available under its both its current accreditation model and the Baldrige pilot model and are included in its newly developed Accreditation Guidelines document. The procedures described in the related documents appear to be identical (Exs. 5, 11, and 12). The procedures indicate that agency staff confer with counterpart agencies, as well as national and regional accrediting agencies. They also state that the agency's Advisory Council advises the agency and that the council is comprised of representatives from public services, employers, employees, postsecondary and technology educators, students, and members of the public.

As documentation of the implementation of its standards review process, the agency provided a copy of a Board meeting agenda showing that the Board was scheduled to make a decision upon the acceptance of the agency's standards. While this demonstrates ultimate Board approval, it does not document the involvement of the many parties that the agency's own procedures require be involved in the standards review process. Additional documentation is needed in this area.

The agency is requested to provide documentation of the steps it undertakes to obtain feedback related to the regular and ongoing review of its standards, including documentation of input from the constituencies specified in its published standards review procedures.
 

(i) Provides for adequate discussion during the on-site visit between the visiting team and the faculty, administrative staff, students, and other appropriate persons;

 
The agency states that on-site reviewers meet with the technology center personnel during the course of the on-site visit. The agency states that evaluators are "encouraged" (but apparently not required) to meet with students, as well as faculty and staff. Preliminary exit reports are given at the end of the site visit.

As documentation, the agency provided an agenda from an on-site review. The agenda lists the faculty members and administrators who are responsible for each program, and it obvious that the evaluators must meet with them in order to gain information about the program being reviewed. However, the agendas do not provide any documentation to show that the on-site evaluators are required to meet with students or other institutional personnel. Furthermore, the agenda that was provided appears to be related to a review conducted under the current evaluation system, and no documentation was provided related to the evaluations conducted under the Baldrige pilot system. Therefore, additional information and documentation are needed in this area.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide documentation showing that on-site evaluators are required to meet with students or other institutional personnel, as required under this section.

In its response to the draft analysis the agency states that examiners will "occasionally" speak with students and other personnel while on-site. However, based upon the sample agenda for on-site reviews specified in the agency's newly developed Accreditation Guidelines document (Ex. 5), it does not appear that on-site evaluators are required to meet with students and other personnel while on campus. For example, on-site review teams typically schedule formal sessions that students may attend, without institutional staff members present, in order to obtain candid feedback from the students' point of view. Similar meetings are typically scheduled for support staff, without institutional administrators present.

The agency is requested to revise its on-site review procedures in order to formally solicit feedback from students and other personnel during the course of the on-site review team's visit.
 

(ii) Furnishes as a result of the evaluation visit, a written report to the institution or program commenting on areas of strength, areas needing improvement, and, when appropriate, suggesting means of improvement and including specific areas, if any, where the institution or program may not be in compliance with the agency's standards;

 
The agency states that it provides on-site review reports to its institutions following the on-site review. However, no documentation was provided to support the agency's narrative. The agency is requested to provide sample final on-site review reports for both its current review process and its Baldrige pilot review process, demonstrating compliance with the requirements of this section.

Analyst Remarks to Response:
In the draft staff analysis the agency was requested to provide a sample final on-site review reports for both its current review process and its Baldrige pilot review process. The document that ED staff was requesting is the final on-site review report (i.e., feedback report) that is prepared by the on-site review team following the conclusion of the on-site review. This document is typically provided in draft form to the institution within a specified number of days following the on-site visit in order that the institution may make any changes of fact that have been incorrectly noted in the report. The report is then finalized and supplied to the institution for it to use in developing any action plans.

In its response, the agency notes that its on-site review teams develop site visit (feedback) reports, but no supporting documentation in the form of such a sample report was provided with this section.

The agency is requested to provide supporting documentation in the form of a sample completed on-site review report.
 

(iii) Provides the chief executive officer of the institution program with opportunity to comment upon the written report and to file supplemental materials pertinent to the facts and conclusions in the written report of the visiting team before the agency takes action on the report;

 
The agency states in its narrative that its technology centers are given the opportunity to respond verbally to the on-site visit report during the exit conference and to provide pertinent supplemental materials for the written on-site review report. The agency did not provide any documentation to support its narrative. Supporting documentation is requested demonstrating that the agency's institutions are given an opportunity to respond to the on-site review report. This information is requested for both the agency's current review process and its Baldrige pilot review process.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide supporting documentation demonstrating that the agency's institutions are given an opportunity to respond to the on-site review report.

In its response to the draft analysis, the agency notes that this requirement is specified in the agency's policies and procedures. However, staff again notes that no supporting documentation was provided to demonstrate the implementation of the agency's policies.

The agency is requested to provide supporting documentation demonstrating that it is implementing the requirement specified within its policies and procedures that an institution be given an opportunity to respond to the on-site review report.
 

(1) Promotes a well-defined set of ethical standards governing institutional or programmatic practices, including recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services;

 
The agency has addressed non-discrimination requirements in its response to this section. The agency is instead requested to describe how its policies, procedures, and standards require that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of the agency's requirements.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to describe how its policies, procedures, and standards require that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of the agency's requirements.

In its response to the draft analysis, the agency notes that its technology centers are required to have policies on file related to ethics, and that the state agency itself follows state code related to ethics.

It appears that the agency is misinterpreting the requirements of this section. This section requires that the agency's standards/policies specify that institutions follow ethical (non-predatory) recruitment practices, publish only accurate advertising, provide unfettered access to transcripts, adhere to Title IV requirements regarding tuition refunds, provide legitimate placement services, etc. Additional information regarding the agency's requirements for its institutions in these areas is still needed.

The agency is requested to describe how its policies, procedures, and standards require that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of the agency's requirements.
 

(2) Maintains appropriate review in relation to the ethical practices of each approved institution or program.

 
As was noted under the previous section, the agency is required to have policies, procedures, and standards require that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services. In this section, the agency is required to demonstrate that those required policies, procedures, and standards are subject to the agency's review and verification. Additional information and documentation are needed related to the requirements of this section.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to describe how its verifies that its institutions maintain compliance with the agency's policies, procedures, and standards requiring that its accredited institutions follow ethical practices regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of the agency's requirements.

As noted in the previous section, it appears that the agency is misinterpreting the requirements of this section. This section requires that the agency verify that its institutions follow its published standards/policies regarding ethical (non-predatory) recruitment practices, publish only accurate advertising, provide unfettered access to transcripts, adhere to Title IV requirements regarding tuition refunds, provide legitimate placement services, etc. Additional information regarding the agency's requirements for its institutions in these areas is still needed.

The agency is requested to describe how it verifies that its institutions are implementing its policies, procedures, and standards regarding recruitment, advertising, transcripts, fair and equitable student tuition refunds, and student placement services, as required under this section, including documentation of this verification.
 
 

PART III: THIRD PARTY COMMENTS

 
The Department did not receive any written third-party comments regarding this agency.