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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Accreditation Council for Pharmacy Education (1952/2012)
                  (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 preaccreditation, within the United States, of professional degree programs in pharmacy leading to the degree of Doctor of Pharmacy, including those programs offered via distance education.
 
4.
Requested Scope of Recognition:   Same.
 
5.
Date of Advisory Committee Meeting:   June, 2017
 
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 issue 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.

-- ACPE does not meet the requirements of this section ACPE needs to revise its policy to stipulate that board members who participate in the evaluation process (as an active evaluator) must be recused during the decision-making process. [§602.15(a)(4)]



EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Accreditation Council for Pharmacy Education (ACPE) accredits and preaccredits professional degree programs in pharmacy leading to the Doctor of Pharmacy degree. Currently, the agency accredits approximately 114 programs, and preaccredits 16 programs, throughout the United States, Puerto Rico and the District of Columbia. Those programs are within institutions that are accredited by regional and national accrediting agencies recognized by the Secretary of Education. Since ACPE is not an institutional accreditor, and does not serve as a gatekeeper of Title IV funds, the agency is not required to meet the Secretary’s separate and independent requirements.
 
 
Recognition History
 
The agency was on the first list of nationally recognized accrediting agencies published in 1952. Since that time, the Secretary has periodically reviewed the agency and granted continued recognition. Originally known as the American Council on Pharmaceutical Education, the agency was renamed the Accreditation Council on Pharmacy Education (ACPE) in 2003.

The last full review of ACPE took place at the June 2012 meeting of the National Advisory Committee on Institutional Quality and Integrity (NACIQI). After that review, the Department extended the agency’s previous grant of recognition and required a compliance report on the issues cited in the staff analysis. As part of its evaluation of the agency’s current petition for continued recognition, Department staff reviewed the agency’s narrative and supporting documentation. Furthermore, no third-party comments were received in connection with the agency’s petition.

The agency petition for continued recognition by the Secretary Is the subject of this analysis and report.


PART II: SUMMARY OF FINDINGS

 
§602.15 Administrative and fiscal responsibilities
(4) Educators and practitioners on its evaluation, policy, and decision-making bodies, if the agency accredits programs or single-purpose institutions that prepare students for a specific profession;

 
The agency provided its board appointment criteria, qualifications, and current board roster, which clearly indicates that there are both educators and practitioners included. The agency provided the policy relating to the appeals panel composition, which clearly requires both educator and practitioner representation. As the agency stated in Section 602.15(a)(2) that it has not convened an appeals panel, it therefore could not provide documentation to verify implementation of its policies and procedures. In regards to site visitors, the agency included its on-site evaluation policy, which requires representation by an educator and practitioner. The agency provided sample on-site evaluation teams as documentation, which include both practitioners and educators. However, the agency did not provide resumes or CV’s for its Educator/Practitioner/ Representatives members (see Sec 602.15(a)(2)) to verify their qualifications. ACPE also failed to indicate (Exhibit 27) which board member are serving as educators or practitioners and or public members (which is required for Sec 602.15(a)(5)). The Department is also concerned that the agency indicates that a Board member serves as a site team member without providing any evidence of recusals of the Board member during decision meetings

The agency needs to provide resumes or CV’s to verify the qualifications of its educator and practitioner representatives. The agency also needs to clarify the position of its board members on site evaluation teams and what if any procedure is put in place for recusals of those members during commission decision meetings.

Analyst Remarks to Response:
In response to the staff's draft analysis, ACPE provided CV's verifying the qualifications of its educator and practitioner representatives and documentation demonstrating the roles each representative plays in the evaluation process (Exhibit A). The agency also provided additional clarification of its process of including board members on site evaluation teams and the processes it uses for recusals of board members during commission decision meetings. ACPE reaffirms that it has always included Board members as active participant of the on-site evaluation team. ACPE does not recuse the Board member that served on the evaluation team from discussion or vote on the program's accreditation at the Board meetings.

The agency states that its evaluation teams are carefully created to ensure a balance of perspectives, evaluation by representative members and to protect against conflicts of interest. In addition, the agency's evaluation process requires that individual programs review the proposed site teams for potential conflicts of interest and provide verification regarding the absence of any conflicts of interest among the selected evaluation site team members. The agency provided its conflict of interest policy (Exhibit G) and a signed conflict of interest form (Exhibit D2). The agency's process during its Board meeting is to open the meeting with a briefing from legal counsel on the importance of declaring conflicts of interest and solicitation of recusals from discussion should any new conflict or matter that would prevent any Board member from being non-partial and unbiased in the discussion and vote on any program on the meeting agenda arise (EXHIBIT E2, Conflict of Interest Presentation at Board Meeting). Consequently, any Board or staff member with a potential conflict of interest for a particular program is recused from discussion and deliberation at the Board meeting and is absent during the Board's deliberation and vote.

Department staff concludes that, in general, the agency has provided sufficient documentation to demonstrate that it has a rigorous conflict of interest policy. However, regarding board members serving in an active roll on site teams. While it is accepted practice to have board members accompany site-evaluation teams as observers (not as active participants, having a direct role in the evaluation process and making evaluation decisions and
recommendation) who may vote at board/commission meetings on the specific program visited. It would not be acceptable for a board member to actively serve as an evaluator and a decision maker. Evaluation bodies (site teams) and decision making body have distinct rolls in the accreditation process. Serving in both roles (evaluator and decision maker) can change the perspective of decision makers It is; however, a commonly accepted practice for those board members, that participate as site team evaluators when they are needed to serve in specific roles on site teams to recuse themselves from the decision making process.

ACPE needs to revise its policy to stipulate that board members who participate in the evaluation process (as an active evaluator) must be recused during the decision-making process.
 
 

PART III: THIRD PARTY COMMENTS

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