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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Midwifery Education Accreditation Council (2001/2016)
                  (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.
Current Scope of Recognition:   The accreditation and pre-accreditation throughout the United States of direct-entry midwifery educational institutions and programs conferring degrees and certificates, including the accreditation of such programs offered via distance education.
 
4.
Requested Scope of Recognition:   Same as above.
 
5.
Date of Advisory Committee Meeting:   December, 2015
 
6.
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.
 
7.
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.

-- The agency is requested to demonstrate that it has a set of monitoring and evaluation approaches that will allow it to identify problems related to continued compliance with agency standards, including developing a means for ensuring that programs/institutions submit all required information and that actions are taken against programs/institutions that are found to be out of compliance with the agency's standards.
[§602.19(b)]

-- The agency must demonstrate that it is tracking its programs'/institutions' compliance with agency standards on an ongoing basis, that it requires corrective action of any program or institution that is found to be in non-compliance, and that it requires all programs/institutions to come into compliance with its standards within the time periods specified under this section.
[§602.20(a)]

-- The agency must demonstrate that it is tracking its programs'/institutions' compliance with agency standards on an ongoing basis, that it requires corrective action of any program or institution that is found to be in non-compliance, and that it takes immediate adverse action unless the agency, for good cause, extends the period for achieving compliance.
[§602.20(b)]



EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Midwifery Education Accreditation Council (MEAC) is both a programmatic and an institutional accreditor. It accredits direct-entry midwifery educational programs and institutions awarding degrees and certificates throughout the United States. MEAC currently accredits or pre-accredits two programs and eight institutions located in nine states. Four of the institutions have components offered via distance education or correspondence education.

The agency’s accreditation enables its accredited, certificate and degree-conferring institutions to establish eligibility to participate in Federal programs administered by the Department of Education under the Higher Education Act (HEA) of 1965, as amended. Currently, three institutions accredited by MEAC participate in the HEA Title IV programs.

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

 
 
Recognition History
 
MEAC developed its accreditation standards and administrative policies and procedures in 1991 using a national consensus-building process with input from representative midwifery educators and schools. The agency began conducting its accreditation activities in 1993-94 and accredited its first institution in 1995. The National Advisory Committee on Institutional Quality and Integrity (NACIQI) considered MEAC for initial recognition at its Fall 2000 meeting and the Secretary’s letter officially conferring recognition was sent to the agency in 2001.

The agency's most recent comprehensive review occurred at the Fall 2010 NACIQI meeting. At that time, MEAC's recognition was deferred for one year and the agency was requested to provide a report to the Committee on several outstanding issues. That report was accepted at the Fall 2012 NACIQI meeting. Because the agency has already received a comprehensive review under the current regulations, it has been allowed to submit an abbreviated petition, which is the subject of the current staff analysis.


PART II: SUMMARY OF FINDINGS

 
§602.19 Monitoring and reevaluation of accredited institutions and programs.

(b) The agency must demonstrate it has, and effectively applies, a set of monitoring and evaluation approaches that enables the agency to identify problems with an institution's or program's continued compliance with agency standards and that takes into account institutional or program strengths and stability. These approaches must include periodic reports, and collection and analysis of key data and indicators, identified by the agency, including, but not limited to, fiscal information and measures of student achievement, consistent with the provisions of §602.16(f). This provision does not require institutions or programs to provide annual reports on each specific accreditation criterion.


 
In addition to periodic comprehensive reviews of its institutions/programs, the agency requires annual reports on key indicators of continued compliance. The annual reports include current program descriptions, faculty information, student policies, most recent financial reviews or audits, and measures of student achievement based on student headcount, enrollment status, and graduate placement data.

As documentation, the agency provided a copy of its annual report form, information from its web site providing information on completing the annual reports, a copy of the 2014 guidance that was provided to its institutions/programs on how to report on the required key indicators, a sample checklist for a school showing areas of concern related to its annual report, and a board action letter incorporating concerns related to issues identified in an institution's annual report.

ED staff accepts the agency's narrative and supporting documentation, and no additional information is requested regarding the agency's compliance with the requirements of this section.

Analyst Remarks to Response:
NOTE: Although this section was originally found to be met (based upon the information provided by the agency in the draft staff analysis), ED staff identified serious concerns related to the requirements of this section during an on-site observation of an agency board meeting in November 2015. Therefore, the final staff analysis identifies areas of non-compliance that were not included in the draft staff analysis.

At the November 2015 agency board meeting, institutional annual reports were being reviewed by the board members. There were no problems with the way that the board members reviewed the reports. The board's procedure was to have all of the board members review all of the reports, with two of the board members serving as the lead readers. However, ED staff noted issues related to some institutions' continued compliance with agency standards, based upon the information provided in the annual reports. The issues related to two areas:

1) Submission of required information
Although the annual reports were thoroughly reviewed by the board, ED staff observed that not all annual reports had been submitted in a complete and/or timely manner, that agency staff were reportedly spending months (and in one case, years) trying to obtain the required information, that in some instances agency staff were completing the reports for the institutions or contacting outside sources (such as accounting firms) in an effort to obtain the required information, and that there appeared to be few, if any, real consequences for the institutions that lagged in providing the required annual report information. It was also unclear to ED staff why annual reports that were submitted by the programs/institutions in the spring were not reviewed by the board until the fall, when the board meets on a monthly basis. It is possible that this was due to the problems that the agency has in obtaining the reports in a timely manner.

2) Compliance with agency requirements
The information that was provided in the annual reports was summarized in tables that were projected on a screen for the entire board to view and discuss on an institution-by-institution basis. The summary tables were well-formatted and easily understandable. However, a number of institutions were found lacking in various areas, particularly in areas related to outcomes measures, and there appeared to be no additional reporting requirements or corrective action plans required, other than updates that were to be provided at the time that the institution responded with its next annual report. In some instances, institutions that were found to be out of compliance were reportedly anticipated by the agency to come back into compliance within a timeframe of a year or two, but there did not appear to be any system in place to track the ongoing compliance issues or the timeframes required for coming into compliance. The board was extremely hesitant to take action against institutions that were not in compliance with the agency's requirements, despite one board member's assertion that the agency needed to "start showing its teeth." ED staff had a major concern that institutions were providing many excuses as to why they were not providing the required information, and that board members were not only accepting those excuses, but were making additional excuses for not taking any action against the institutions.

Given the extremely small size of the agency and the number of programs/institutions that it accredits, it should be relatively simple for the agency to follow-up with schools to obtain information and track compliance with agency standards. However, the agency's size presents additional problems in that perhaps the members of its small and tightly-knit community are hesitant to take punitive actions against other schools, especially when institutional representatives serve, or have served, on the agency's board. Additionally, the fact that the agency has had serious financial problems in the recent past and remains on a very tight budget raises concerns that it simply cannot afford to lose any of its programs/institutions and is therefore reluctant to take any action against them.

Regardless of the reasons, it appears that the agency is not effectively applying a set of monitoring and evaluation approaches that would enable it to identify problems with continued compliance with agency standards. In conference calls with agency staff subsequent to the November board meeting, ED staff encouraged the agency to develop a system to track submission of all required reporting information, identify areas of non-compliance with agency requirements, and track/demonstrate that programs/institutions bring themselves into compliance within required timeframes or face appropriate sanctions.

The agency does not meet the requirements of this section. The agency is requested to demonstrate that it has a set of monitoring and evaluation approaches that will allow it to identify problems related to continued compliance with agency standards, including developing a means for ensuring that programs/institutions submit all required information and that actions are taken against programs/institutions that are found to be out of compliance with the agency's standards.
 

§602.20 Enforcement of standards

(a) If the agency's review of an institution or program under any standard indicates that the institution or program is not in compliance with that standard, the agency must--

(1) Immediately initiate adverse action against the institution or program; or

(2) Require the institution or program to take appropriate action to bring itself into compliance with the agency's standards within a time period that must not exceed--

(i) Twelve months, if the program, or the longest program offered by the institution, is less than one year in length;

(ii) Eighteen months, if the program, or the longest program offered by the institution, is at least one year, but less than two years, in length; or

(iii) Two years, if the program, or the longest program offered by the institution, is at least two years in length.

 
The agency notes that it has a policy in place that specifies the required timelines for institutions/programs to bring themselves into compliance with the agency's standards, as well as a policy that states that prompt adverse action will be taken against any institution/program that does not conform to the timelines, unless the agency extends the timeline for good cause. The agency has developed a non-compliance tracking report that tracks its institutions/programs that are on reporting deadlines. The tracking report includes the name of the institution, the date of notification of non-compliance, any extensions for good cause, the reason for such an extension, the date the report is due, and a description of what must be addressed in the report.

As supporting documentation, the agency provided a copy of its policies, its tracking report, a sample report from a school, and the action letter related to the report following the board's review of the school's report.

ED staff accepts the agency's narrative and supporting documentation, and no additional information is requested regarding the agency's compliance with the requirements of this section.

Analyst Remarks to Response:
NOTE: Although this section was originally found to be met (based upon the information provided by the agency in the draft staff analysis), ED staff identified serious concerns related to the requirements of this section during an on-site observation of an agency board meeting in November 2015. Therefore, the final staff analysis identifies areas of non-compliance that were not included in the draft staff analysis.

As noted under 602.19(b), at the November 2015 agency board meeting, institutional annual reports were being reviewed by the board members. The annual reports were thoroughly reviewed by the entire board, with two board members serving as the lead readers for each institution.

As noted previously, required information was not being provided in a timely and/or complete manner and enforcement action by the agency was seriously lacking. For example, in at least one case, an institution was two years behind on submitting its financial information. The institution had reportedly told the agency that if it wanted the information, it should contact the institution's accounting firm itself, which the agency then attempted to do. The information still had not been obtained, but no action had been taken against the school.

Additionally, in several instances programs/institutions were identified as being out of compliance with the agency's outcomes measures thresholds. For instance, the minimum threshold in most instances was set at 50%, but in several instances the program's/institution's was out of compliance at 33%. The agency speculated that some institutions would probably come back into compliance within a year or two, and therefore no corrective action was required. The agency excused several programs/institutions from the outcomes requirements based upon their small size and noted that ED allowed accrediting agencies to make exceptions for good cause. ED staff must emphasize that exceptions for good cause should be used sparingly and not routinely, and that such exceptions must be tracked and thoroughly justified.

Despite that fact that ED observed that a number of programs/institutions had areas of non-compliance, it did not appear that the agency was taking any action against those programs/institutions and did not have a means for tracking compliance with the enforcement timelines specified under this section.

The agency does not meet the requirements of this section. The agency must demonstrate that it is tracking its programs'/institutions' compliance with agency standards on an ongoing basis, that it requires corrective action of any program or institution that is found to be in non-compliance, and that it requires all programs/institutions to come into compliance with its standards within the time periods specified under this section.
 

(b) If the institution or program does not bring itself into compliance within the specified period, the agency must take immediate adverse action unless the agency, for good cause, extends the period for achieving compliance.
 
As was noted and documented in the previous section, the agency has policies in place specifying that institutions/programs must bring themselves into compliance with the agency's standards within the timeframes specified in the ED regulations, or face prompt adverse action unless the agency provides an extension for good cause. As was also noted previously, the agency has developed a report to track its institutions/programs and any reports that are due, including due dates and information related to extensions for good cause.

As documentation, the agency provided information related to an institution that received an extension for good cause. The extension was related to the institution's compliance with the agency's newly revised 2013 standards and associated outcomes requirements. The agency determined that the institution was on track to meet the revised requirements. The agency continues to track the institution's progress toward meeting the revised requirements.

ED staff accepts the agency's narrative and supporting documentation, and no additional information is requested regarding the agency's compliance with the requirements of this section.

Analyst Remarks to Response:
NOTE: Although this section was originally found to be met (based upon the information provided by the agency in the draft staff analysis), ED staff identified serious concerns related to the requirements of this section during an on-site observation of an agency board meeting in November 2015. Therefore, the final staff analysis identifies areas of non-compliance that were not included in the draft staff analysis.

As noted under 602.19(b), at the November 2015 agency board meeting, institutional annual reports were being reviewed by the board members. The annual reports were thoroughly reviewed by the entire board, with two board members serving as the lead readers for each institution.

As noted previously, information required by the agency was not being provided in a timely and/or complete manner and enforcement action by the agency was seriously lacking. For example, in one case, an institution was two years behind on submitting its financial information. The institution had reportedly told the agency that if it wanted the information, it should contact the institution's accounting firm itself, which the agency then attempted to do. The information still had not been obtained, but no action had been taken against the school.

Additionally, in several instances programs/institutions were identified as being out of compliance with the agency's outcomes measures thresholds. For instance, the minimum threshold in most instances was set at 50%, but in several instances the program/institution was out of compliance at 33%. The agency speculated that some institutions would probably come back into compliance within a year or two, and therefore no corrective action was required. The agency excused several programs/institutions from the outcomes requirements based upon their small size and noted that ED allowed accrediting agencies to make exceptions for good cause. ED staff must emphasize that exceptions for good cause should be used sparingly and not routinely, and that such exceptions must be tracked and thoroughly justified.

Despite that fact that ED observed that a number of programs/institutions had areas of non-compliance, it did not appear that the agency was taking immediate action against those programs/institutions. In most instances, the agency was allowing the program/institution to submit additional information with its next annual report and did not appear to be requiring any substantive corrective action.

The agency does not meet the requirements of this section. The agency must demonstrate that it is tracking its programs'/institutions' compliance with agency standards on an ongoing basis, that it requires corrective action of any program or institution that is found to be in non-compliance, and that it takes immediate adverse action unless the agency, for good cause, extends the period for achieving compliance.
 
 

PART III: THIRD PARTY COMMENTS

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