Accreditation and State Liason (ASL) E-Recognition Web Site US Department of Education, Promoting educational excellence for all Americans.
Skip to main content | Home | OPE Home | ASL Home | NACIQI | NCFMEA | User Guide

Back

U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Montessori Accreditation Council For Teacher Education (1995/2016)
                  (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 of Montessori teacher education institutions and programs throughout the United States, including those 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 needs to submit clear documentation that the agency provides its entities with a detailed written report that consistently assesses the institution’s or program’s performance with respect to student achievement. In addition, the agency needs to submit clear documentation that its site visitors are consistently verifying the accuracy of the student achievement data that they receive, and that MACTE is clearly training them how to consistently verify the accuracy of that data. [§602.17(f)]

-- The agency needs to document that it effectively analyzes the monitoring data it collects to assess the continued compliance of each institution and program with MACTE standards throughout the period of accreditation, specifically including financial and student achievement information. [§602.19(b)]

-- The agency needs to have a clear written policy for extending the period for coming into compliance with a MACTE standard, when the institution or program had previously been cited for being in non-compliance. In addition, the agency needs to provide some guidance as to what MACTE would consider potential circumstances for granting a limited extension to demonstrate compliance in that particular case. [§602.20(b)]



EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Montessori Accreditation Council for Teacher Education (MACTE) is a national programmatic and institutional accreditor. The agency currently accredits 103 freestanding institutions, and 13 programs affiliated with a college or university, located throughout the United States.

Three of the freestanding institutions (one in Montana and two in Florida) include a substantial distance education component. All three of those institutions also require their students to attend at least 120 hours of residential instruction at their respective institutions in compliance with MACTE policies.

The agency’s recognition enables its institutions to establish eligibility to receive Federal student assistance funding under Title IV of the Higher Education Act of 1965, as amended (Title IV). MACTE serves as the Title IV gatekeeper for four of the freestanding institutions that the agency accredits. (The three institutions with a substantial distance education component do not participate in Title IV programs.)
 
 
Recognition History
 
The Secretary of Education first recognized MACTE in 1995. Since that time, the Secretary periodically reviewed the agency and granted continued recognition. The last full review of the agency took place at the December 2010 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 two issues cited in the staff analysis, one regarding distance education programs and one regarding enforcement timelines.

That compliance report was reviewed in December 2012 after which an extension was granted for good cause to allow MACTE the time necessary to finish its work on the one remaining issue, which concerned the accreditation of distance education programs. After the second compliance report was reviewed positively at NACIQI’s December 2013 meeting, it was accepted by the senior Department official.

As part of its evaluation of the agency’s current petition for continued recognition, Department staff reviewed the agency’s narrative and supporting documentation. In addition, Department staff attended an agency decision-making meeting conducted by conference call on June 29, 2015 (with corresponding documentation made available by “Dropbox”).

The Department received no written complaints regarding MACTE during this review period, and no third-party comments in connection with the agency’s petition for continued recognition.


PART II: SUMMARY OF FINDINGS

 
§602.17 Application of standards in reaching an accrediting decision.
The agency must have effective mechanisms for evaluating an institution's or program's compliance with the agency's standards before reaching a decision to accredit or preaccredit the institution or program. The agency meets this requirement if the agency demonstrates that it--

(f) Provides the institution or program with a detailed written report that assesses--

(1) The institution's or program's compliance with the agency's standards, including areas needing improvement; and

(2) The institution's or program's performance with respect to student achievement; and 

 
MACTE provides each institution or program with a written assessment of the areas where the site visiting team was able, or was unable, to verify the accuracy of the materials in the self-study, which are aligned to the agency’s quality principles or standards (cf. Exhibit 40). Most sections of the quality principles can be used to judge the institution’s or program’s responses in a straightforward manner. For those areas it is not difficult for the visiting team to note the areas where an institution or program may need improvement to fully meet the agency’s expectations.

However, describing MACTE’s expectations when it comes to acceptable, or unacceptable, levels of student achievement is difficult for the site visiting team to describe (and has been noted under another criterion). It is unknown whether this difficulty stems from MACTE’s revised (and less detailed) expectations regarding student achievement, and/or MACTE’s recent emphasis on site visitors as “verifiers” (rather than “evaluators”). Whatever the reason, the agency does not currently provide the institution or program with a detailed written report that clearly assesses the entity’s performance with respect to student achievement.

Until, this matter is addressed, a finding of compliance cannot be made.

Analyst Remarks to Response:
The draft staff analysis for this criterion found that the agency needs to provide its entities with a detailed written report that clearly assesses the institution’s or program’s performance with respect to student achievement.

[In the agency’s response to a related criterion [602.16(a)(1)(i)], it was noted that the student achievement thresholds had been inadvertently omitted from the agency’s Guide to Accreditation and had been recently reinstated. The acceptable MACTE threshold for completion rates and employment rates is 70%. MACTE primarily checks that the minimum acceptable rates have been provided by the institution or program in their annual reports.]

This particular criterion is primarily concerned with the detailed written report provided to the institution or program after the periodic on-site visit conducted by the trained MACTE evaluators. Specifically, the resulting written report must detail the visited institution's or program's performance with respect to student achievement. Furthermore, the on-site evaluators need to verify the information provided in the self-study for accuracy, and not simply accept them at face value, if they are following the commonly accepted practice of recognized accreditors.

The agency’s response to the draft staff analysis states that it is the responsibility of the on-site verifier to verify the information, and it is the responsibility of the MACTE Board to evaluate and determine whether the preponderance of the evidence presented in the full record is enough to support the claim that the program is graduating competent Montessori Teachers. The agency’s response also states that it provides a clear analysis of the outcomes. However, the agency response also indicates that feedback is provided only if the visited entity is out of compliance with the minimum achievement thresholds.

In the sample materials provided by MACTE, it is not evident that the written report from the on-site visit details the visited institution's or program's performance with respect to student achievement. On the contrary, it appears that the visitors simply verify that the numbers provided by the program itself meet the 70 percent threshold. If they meet the 70 percent threshold no comments are required.

Department staff is concerned because there is no evidence that the visitors do anything more than check if the entity-provided student achievement numbers reach the minimum threshold. More importantly, there is no evidence that the visitors do anything to verify that the entity-provided numbers are accurate and authentic. Since commentary is sparse, it is unclear if the visitors conducted any kind of systematic activity to verify the accuracy of the data. As well, it is unclear what percentage of recent graduates and their employers are contacted by the visitors as part of their process to independently verify student achievement data. It is also unclear how the MACTE decision-makers are assured that the verification process has gone beyond accepting the numbers provided by the visited institution or program itself.

MACTE did not submit clear documentation that the agency provides its entities with a detailed written report that consistently assesses the institution’s or program’s performance with respect to student achievement. In addition, MACTE did not submit clear documentation that its site visitors are consistently verifying the accuracy of the student achievement data that they receive, or that MACTE trains them how to consistently verify the accuracy of that data.

Until, this matter is addressed, a finding of compliance cannot be made.
 

§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.


 
The agency uses three basic monitoring approaches that include annual reports, interim reports, and the review of substantive changes.

Institutions and programs are required to submit applications for substantive change that must be approved by MACTE before the change can be included in the entity’s prior grant of accreditation.

MACTE also requires all institutions and programs to submit an annual report regarding changes such as headcount enrollments, changes in course length, and changes in course offerings. The annual report also asks how well the students are doing on internal assessments, and how the program or institution knows that its students are prepared to practice as Montessori teachers.

The third monitoring effort consists of a larger interim report due in the fourth year of the seven-year accreditation period. The major problem with that assessment is that it is still keyed to MACTE’s 2011 Handbook, as well as to the agency’s old standards, and is in need of updating.

It is unclear how MACTE analyzes and uses the limited data it requests in the annual reports and in the interim reports. Other types of basic data, such as current fiscal resources, any complaints received, and if appropriate, any Title IV compliance issues or the availability of financial assistance to students, are not regularly monitored.

The petition did not provide any evidence regarding its analysis of the data collected annually or in the interim reports. In addition, MACTE did not elaborate on its collection of financial and student achievement data, etc., or what actions MACTE has taken as a result of its monitoring efforts.

Until this matter is addressed, a finding of compliance cannot be made.

Analyst Remarks to Response:
The draft staff analysis for this criterion found that the agency needs to provide evidence that it analyzes and uses the monitoring data it collects from its institutions and programs, including the student achievement and financial information.

More specifically, since no evidence was provided, it was unclear how MACTE analyzes and uses the limited data it requests in the annual reports and in the interim reports for monitoring its institutions and programs. In addition, MACTE did not elaborate on its collection of financial and student achievement data, etc., or what actions MACTE has taken against an institution or program as a result of its monitoring efforts. Furthermore, it was noted that other types of data were not regularly monitored, such as any Title IV compliance issues or the availability of student financial assistance, as appropriate.

In response, the agency submitted a broad overview of its 2014-15 Annual Report Results (New Exhibit 74A). As well, the agency’s narrative highlighted the main use of the annual report summaries in broad overview terms, such as strengthening MACTE policies, or deciding which states need more attention from MACTE so Montessori credentials are recognized for state licensure.

These are all good uses of an annual report summary. However, the focus of this criterion is the monitoring done by MACTE for the specific purpose of identifying problems with an institution's or program's continuing compliance with MACTE standards.

As a result, MACTE still needs to present evidence that it is effectively monitoring each institution and program for continued compliance throughout the period of accreditation. As part of that evidence, MACTE should show it flags discrepancies or changes for follow-up that could affect an entity’s compliance with MACTE standards, specifically including financial and student achievement information. As well, sample documentation that the agency actually followed up with an entity as the result of a compliance problem identified through an annual report would be helpful.

Until this matter is addressed, a finding of compliance cannot be made.
 

§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.

 
This criterion examines how MACTE would handle an institution or program that does not bring itself into compliance with MACTE standards within the required enforcement timelines. Specifically, if an agency does not take immediate adverse action, then the agency is permitted to extend the period for achieving compliance, but only for good cause.

MACTE’s relevant policy seems to refer only to the regular accreditation renewals that normally take place every seven years. In that case, the entity would contact MACTE six months before applying for reaccreditation and request an extension of the date for reapplying. The written policy is not clear if it applies to extending the period for coming into compliance with a MACTE standard, when an institution or program had previously been cited for not meeting one or more standards. As well, there is no reference to the types of circumstances that MACTE would consider reasonable for granting a limited extension for good cause.

Until the agency addresses this matter, a finding of compliance cannot be made.

Analyst Remarks to Response:
The draft staff analysis found that the agency needs to have a clear written policy for extending the period for coming into compliance with a MACTE standard, when an institution or program had previously been cited for not meeting one or more standards. In addition, the agency needs to provide some guidance as to what MACTE would consider potential circumstances for granting a limited extension for good cause.

More specifically, it appeared that the good cause extension policy originally highlighted by MACTE only applied to a program or institution that could not submit its regular seven-year self-study on time for continued accreditation. It did not appear that the policy was related to the specific requirements of this criterion regarding an institution or program that had previously been cited for not meeting one or more MACTE standards. As well, it was unclear if the circumstance for granting an extension for submitting a late self-study were the same as those for granting an extension to remedy a previously-identified compliance citation.

In response, it is now clear that the materials submitted by MACTE only apply when a self-study cannot be submitted on the regular schedule. The materials do not correspond with the requirements of this section.

This section cannot be understood without reference to the previous criterion [602.20(a)] regarding the enforcement of standards. That standard requires an agency to take immediate adverse action when its evaluation of an institution or program identifies the entity as being out of compliance with an agency standard, or else requires the entity to bring itself into compliance within a limited time frame. As noted under the previous criterion, MACTE recently provided clear documentation (New Exhibit 76A) that it complied with the requirements of that section.

The current standard applies when an institution or program that was previously identified as being in noncompliance failed to bring itself into compliance within the period set by MACTE. At that point, the agency must take immediate adverse action, unless it determines that the original period for demonstrating compliance should be briefly extended for a very serious reason, or “good cause.” (The agency may want to use some of the serious reasons it has already identified as being reasonable for delaying the submission of a self-study.)

In any case, the agency still needs to have a clear written policy for extending the period for coming into full compliance with a MACTE standard when an institution or program had previously been cited for being in non-compliance, but it had failed to come into compliance within the time period granted to do so. In that particular case, MACTE might grant a brief extension if that institution or program clearly demonstrated that there was a very serious reason for being granted a “good cause” extension. Otherwise, MACTE would be required to take an immediate adverse action without further delay. (This requirement can only be properly understood in relation to 602.20(a) on the enforcement of standards.)

Until the agency addresses this matter, a finding of compliance cannot be made.
 
 

PART III: THIRD PARTY COMMENTS

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