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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 on Optometric Education (1952/2015)
                  (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:   Compliance Report
 
3.
Current Scope of Recognition:   The accreditation in the United States of professional optometric degree programs, optometric technician (associate degree) programs, and optometric residency programs, and for the pre-accreditation category of Preliminary Approval for professional optometric degree programs.
 
4.
Requested Scope of Recognition:   The accreditation in the United States of professional optometric degree programs, optometric technician (associate degree) programs, and optometric residency programs, and for the preaccreditation category of Preliminary Approval for professional optometric degree programs.
 
5.
Date of Advisory Committee Meeting:   June, 2015
 
6.
Staff Recommendation:   Renew the agency’s recognition for two and one half years. As requested by the agency, remove the following preaccreditation category from the ACOE scope of recognition: Candidacy Pending for optometric residency programs in Department of Veterans Affairs facilities.
 
7.
Issues or Problems:   None


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The American Optometric Association, Accreditation Council on Optometric Education (ACOE) accredits professional optometric degree (O.D.) programs, optometric technician (associate degree) programs, and optometric residency programs.

The agency currently accredits 20 professional optometric degree programs, 5 optometric technician programs, and 191 optometric residency programs. In addition, the agency preaccredits 1 professional optometric degree program. These programs are all located throughout the United States and Puerto Rico. (The agency also accredits 2 professional optometric degree programs in Canada.)

The ACOE is a programmatic accreditor, and consequently is not required to meet the Secretary’s “separate and independent” requirements. The agency’s programs use the agency’s accreditation to enable them to establish eligibility for federal programs under the Title VII Public Health Service Act and for participation in the Department of Veterans Affairs, Veterans Health Administration education and training program for optometry residency programs.
 
 
Recognition History
 
The American Optometric Association was on the first list of nationally recognized accrediting agencies published, and has received periodic renewal of recognition since that time. The agency was last reviewed for continued recognition at the June 2013 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 compliance report, Department staff reviewed the agency’s narrative and supporting documentation. Furthermore, no third-party comments were received in connection with the agency’s compliance 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;

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to have a clear written policy that requires it to have an adequate representation of both educators, and practitioners, as it makes its selections for all site teams. In addition, the written policy needed to indicate what the agency uses to designate a person to serve in one category, as distinguished from the other.

Agency Response and Discussion: In response, the agency provided documentation to show that it has sufficiently defined what it means by an “educator” as distinguished a “practitioner.” In addition, the agency has incorporated those definitions into the relevant publicly-available manuals. As well, the agency has made its public manuals and written staff procedures more explicit to clarify that each site team will have the minimum number of educators and practitioners required, and how agency staff will implement that requirement consistently.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.

 

§602.16 Accreditation and preaccreditation standards
(a) The agency must demonstrate that it has standards for accreditation, and preaccreditation, if offered, that are sufficiently rigorous to ensure that the agency is a reliable authority regarding the quality of the education or training provided by the institutions or programs it accredits. The agency meets this requirement if -
(1) The agency's accreditation standards effectively address the quality of the institution or program in the following areas:
(i) Success with respect to student achievement in relation to the institution's mission, which may include different standards for different institutions or programs, as established by the institution, including, as appropriate, consideration of course completion, State licensing examination, and job placement rates.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to clarify and document how it evaluates the institutionally-established student achievement benchmarks against the benchmarks established by ACOE in its monitoring protocols for Professional Optometric Programs. In addition, the agency needed to clarify and document the level of authority formally assigned to the student achievement benchmarks that ACOE applies to Professional Optometric Programs.

Agency Response and Discussion: In response, the agency developed a sample site visit report and strengthened its training of site visitors, so that the importance of ACOE’s 70 percent ultimate pass rate on the national licensing examination is clearly highlighted. As well, the agency has reached out to its constituents and modified its published manual for Professional Optometric Programs. The modification emphasizes that the 70 percent benchmark set by ACOE will be monitored in the annual reports, and that the benchmark will only be changed after input from the agency’s constituents has been solicited.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 

(a)(1)(ix) Record of student complaints received by, or available to, the agency.
 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to ensure that any record of student complaints that was received directly by ACOE is made available to the on-site visiting team.

Agency Response and Discussion: In response, the agency provided documentation to show that it has revised its written policies to ensure that any complaints received by ACOE since the last evaluation will be provided to the on-site visitors, and that the record of those complaints will be maintained by the agency. ACOE attested that no complaints about its accredited programs have been received since the adoption of those new policies.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 

(a)(2) The agency's preaccreditation standards, if offered, are appropriately related to the agency's accreditation standards and do not permit the institution or program to hold preaccreditation status for more than five years.
 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to ensure that all of its preaccreditation standards are appropriately related to the agency's accreditation standards. In particular, the agency needs to avoid potential confusion in its public terminology, ensure that a site visit is conducted before granting any public status, and to clearly limit any preaccreditation status, or any combination of preaccreditation statuses, to five years total. In addition, the agency needs to provide documentation of its review and approval of program requests for preaccreditation status.

Agency Response and Discussion: In response, the agency provided documentation to show that it has adopted several changes in order to address the cited issues. The agency invited comments from its communities of interest who determined that the status of “candidacy pending” would be eliminated. The agency will now require the appropriate programs to go through the “preliminary approval” process for preaccreditation, which does include the prerequisite site visit, and is limited to five years.

Regarding documentation of a program that has been reviewed for preaccreditation, the agency attested that no program has gone through that process since it has been changed. (The agency included some documentation for a program that sought full accreditation in 2013.)

While undergoing the necessary revisions, ACOE took the opportunity to add two additional statuses (Stage One and Stage Two Applicants) to its processes. Regarding those statuses, the agency declares that each one is “not an official pre-accreditation classification, but rather a step toward pre-accreditation.” Since those statuses are not official ACOE preaccreditation classifications, they are not included in the Department’s scope of recognition for ACOE.

NOTE: In order to avoid confusion for the public and the programs themselves, ACOE will need to be continually careful to make those crucial distinctions clear on its website; in its relevant written publications; and in its written communications to the programs listed as “applicants.” The agency will be expected to clearly distinguish and separate those “applicant” programs from the programs that have been granted the official public statuses of preaccreditation (“preliminary approval”) or accreditation.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 

§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.


 
Agency Response and Discussion: In response, the agency provided documentation to show that it has added key points for review to the checklist used by the reviewers to help ensure consistency. As well, the agency revised the annual report template so that programs will know what types of changes are considered significant by the agency. Both of these revisions were clearly given a great deal of thought and should prove to be valuable supports for ensuring consistency.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 

§602.20 Enforcement of standards
(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.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to clarify how it limits an extension granted for good cause before ACOE is required to take an adverse action against a program.

Agency Response and Discussion: In response, the agency provided documentation to show that it has clarified its policies to specifically note that an extension for good cause is typically extended for six months, and after that, only one additional extension may be granted. In addition, the agency clarified that it had only granted one extension for good cause during the past several years, and that the case met the criteria included in the agency’s written policies.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 

§602.25 Due process
(f) Provides an opportunity, upon written request of an institution or program, for the institution or program to appeal any adverse action prior to the action becoming final.
(1) The appeal must take place at a hearing before an appeals panel that--
(i) May not include current members of the agency's decision-making body that took the initial adverse action;

(ii) Is subject to a conflict of interest policy;

(iii) Does not serve only an advisory or procedural role, and has and uses the authority to make the following decisions: to affirm, amend, or reverse adverse actions of the original decision-making body; and

(iv) Affirms, amends, reverses, or remands the adverse action. A decision to affirm, amend, or reverse the adverse action is implemented by the appeals panel or by the original decision-making body, at the agency's option. In a decision to remand the adverse action to the original decision-making body for further consideration, the appeals panel must identify specific issues that the original decision-making body must address. In a decision that is implemented by or remanded to the original decision-making body, that body must act in a manner consistent with the appeals panel's decisions or instructions.
(2) The agency must recognize the right of the institution or program to employ counsel to represent the institution or program during its appeal, including to make any presentation that the agency permits the institution or program to make on its own during the appeal.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that ACOE needed to clarify its written instructions to an appeal panel to ensure that the panel’s authority to reverse an ACOE decision is not undermined.

Agency Response and Discussion: In response, the agency provided documentation to show that it has revised its written policy regarding the authority of an appeals panel. It is now clear that the appeals panel has the authority to determine if the original decision “was arbitrary, capricious, or not supported by substantial evidence in the record on which it took action, or whether the procedures used by ACOE to reach its decision were contrary to ACOE’s standards or other established policies and practices, and that procedural error prejudiced ACOE’s consideration.” As well, it is emphasized that the appeals panel has the authority to reverse the original decision of the ACOE Council and that the Council must implement the decision of the appeals panel in a manner consistent with the instructions provided by the appeals panel. The agency again reported that it still has not had occasion to conduct an appeal.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of this section.
 
 

PART III: THIRD PARTY COMMENTS

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