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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Middle States Commission on Higher Education (1952/2013)
                  (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 and preaccreditation ("Candidacy status") of institutions of higher education in Delaware, the District of Columbia, Maryland, New Jersey, New York, Pennsylvania, Puerto Rico, and the U.S. Virgin Islands, including distance and correspondence education programs offered at those institutions.
 
4.
Requested Scope of Recognition:   Same as above
 
5.
Date of Advisory Committee Meeting:   December, 2014
 
6.
Staff Recommendation:   Renew the agency’s recognition for three years.
 
7.
Issues or Problems:   None.


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
Middle States Commission on Higher Education (MSCHE) is a regional accreditor that currently accredits 528 institutions of higher education located in five states, the District of Columbia, Puerto Rico, and the US Virgin Islands. In addition, the agency has approximately 7 institutions in candidacy status and is reviewing 4 applications for candidacy.

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). The agency serves as the Title IV gatekeeper for all but a handful of the institutions it accredits. Consequently, the agency must meet the Secretary’s separate and independent requirements.
 
 
Recognition History
 
MSCHE appeared on the first list of recognized accrediting agencies in 1952 and has received periodic renewal of recognition since that time. The agency was last reviewed for continued recognition at the December 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 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

The agency must have the administrative and fiscal capability to carry out its accreditation activities in light of its requested scope of recognition. The agency meets this requirement if the agency demonstrates that--

(a) The agency has--

(1) Adequate administrative staff and financial resources to carry out its accrediting responsibilities;

 
Previous Issue or Problem: During its December 2012 review of the agency, Department staff noted that MSCHE needed to document the completion of its separate incorporation, as well as to document the successful completion of the property transfer with solidified loan terms, in order to accurately calculate the agency’s future indebtedness and its ability to avoid additional losses.

Agency Response and Discussion: In response, the agency provided documentation to show that it has successfully completed its separate incorporation and the property transfer while maintaining its positive financial health. In addition, the agency adequately demonstrated that its future financial health should remain strong and provide for continued growth.

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

§602.21 Review of standards.

(a) The agency must maintain a systematic program of review that demonstrates that its standards are adequate to evaluate the quality of the education or training provided by the institutions and programs it accredits and relevant to the educational or training needs of students.


(b) The agency determines the specific procedures it follows in evaluating its standards, but the agency must ensure that its program of review--

(1) Is comprehensive;

(2) Occurs at regular, yet reasonable, intervals or on an ongoing basis;

(3) Examines each of the agency's standards and the standards as a whole; and

(4) Involves all of the agency's relevant constituencies in the review and affords them a meaningful opportunity to provide input into the review.

 
Previous Issue or Problem: During its December 2012 review of the agency, Department staff noted that MSCHE needed to provide current documentation that its standards review program is comprehensive; that it examines each of the agency's standards and the standards as a whole; and that it involves all of the agency's relevant constituencies in the review and affords them a meaningful opportunity to provide input into the review.

Agency Response and Discussion: In response, the agency provided documentation to show that it has undertaken the most recent comprehensive review of its standards during the 2013-2014 timeframe. Town hall meetings were held throughout the agency’s region that recorded the comments from the wide assortment of attendees. In addition, comments were able to be submitted by those not able to attend in person.

A meaningful opportunity to provide comments was provided to those on the agency’s email list. The emails were sent out to the top officials at each MSCHE institution including the Chief Academic Officer, the Chief Executive Officer, and the Accreditation Liaison Officer. As well, the invitation to comment was sent to the appropriate state regulators and commissioners of higher education, staff of selected accrediting agencies, the US Department of Education, and to a miscellaneous group designated as “Agency Contacts.”

As noted in the agency’s original narrative, additional activities were scheduled to take place after the compliance report was submitted in March 2014. As a result, the agency submitted a supplemental update in September 2014 regarding those activities (uploaded separately).

In summary, it is clear that MSCHE has reached out to numerous institutional administrators and government-related personnel, as well as to the agency’s numerous other constituencies, such as students, faculty and librarians. MSCHE has conducted its standards review process as planned; has involved its relevant constituencies in that review; and has afforded them a meaningful opportunity to provide input into that review.

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

§602.23 Operating procedures all agencies must have.
(c) The accrediting agency must--
(1) Review in a timely, fair, and equitable manner any complaint it receives against an accredited institution or program that is related to the agency's stan­dards or procedures.The agency may not complete its review and make a decision regarding a complaint unless, in accordance with published procedures, it ensures that the institution or program has sufficient opportunity to provide a response to the complaint;

(2) Take follow-up action, as necessary, including enforcement action, if necessary, based on the results of its review; and

(3) Review in a timely, fair, and equitable manner, and apply unbiased judgment to, any complaints against itself and take follow-up action, as appropriate, based on the results of its review.

 
Previous Issue or Problem: During its December 2012 review of the agency, Department staff noted that MSCHE needed to provide current documentation that the new policies and procedures for reviewing complaints was successfully processing all complaints in a consistently timely manner.

Agency Response and Discussion: In response, the agency provided documentation to show that it has incorporated a few basic timeframes into its revised complaint handling procedures. In addition, the agency noted that it has developed a complaint processing database so that it can more easily track the progress of complaints from receipt to final disposition. As evidence, the agency provided portions of some complaint records as evidence of the types of documents that can be found in the agency’s database. Furthermore, the agency has responded in a timely manner to the complaints forwarded to it by the Department.

As noted in the agency’s original narrative, a new complaint submission form was adopted a few months before the agency submitted its compliance report in March 2014. As a result, the agency submitted a supplemental update in September 2014 regarding its experiences in processing complaints.

In summary, MSCHE found it necessary to revise the original form and to combine unnecessary and redundant questions. As well, the agency found that the new complaint form actually resulted in an increase in the number of complaints that were clearly related to the agency’s standards and policies. Overall, the agency found that complaints could be resolved more expeditiously since communication with the complainants was improved.

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

§602.24 Additional procedures certain institutional accreditors must have.
(2) In reviewing and evaluating an institution's policies and procedures for determining credit hour assignments, an accrediting agency may use sampling or other methods in evaluation, sufficient to comply with paragraph (f)(1)(i)(B) of this section.

 
Previous Issue or Problem: During its December 2012 review of the agency, Department staff noted that MSCHE needed to consistently seek information from each institution as to how it was assigning credit hours, and the visiting teams needed to consistently describe what actual evidence they reviewed to come to their determination, beyond simply checking the institution’s written policy.

Agency Response and Discussion: In response, the agency provided documentation to show that it has appropriately revised its relevant materials and practices. In particular, the agency now requires every institution to electronically submit a detailed document with answers to specific questions based on a common MSCHE-provided template. The agency then has an independent reviewer write a report on the institution’s submission and its compliance with the agency’s expectation regarding the assignment of credit hours, among other compliance-related matters. The school submission and the reviewer’s report are then provided to the agency’s evaluation team or periodic report readers, as appropriate, for follow-up.

The agency provided several samples of the documents used in the new process. It is clear that MSCHE has developed a well-coordinated and documented approach that will better ensure more consistent credit hour assignment evaluations.

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.