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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Association of Advanced Rabbinical and Talmudic Schools (1974/2013)
                  (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 pre-accreditation ("Correspondent" and "Candidate") within the United States of advanced rabbinical and Talmudic schools to include Baccalaureate, Masters, Doctorate, and First Rabbinic and First Talmudic degrees programs
 
4.
Requested Scope of Recognition:   Same as above
 
5.
Date of Advisory Committee Meeting:   June, 2015
 
6.
Staff Recommendation:   Renew the agency’s recognition for two and one half years.
 
7.
Issues or Problems:   None


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Association of Advanced Rabbinical and Talmudic Schools, Accreditation Commission (AARTS) is a national institutional accreditor. The agency’s scope of recognition is for the accreditation and preaccreditation (“Correspondent” and “Candidate”) of advanced rabbinical and Talmudic schools. (“Talmud” is the collection of Rabbinic writings that date back to the third century whose writings form the basis of religious authority for traditional Judaism.) AARTS institutions grant postsecondary degrees such as the baccalaureate, master's, doctorate, first rabbinic and first Talmudic degrees.

Of the 75 AARTS institutions (62 accredited and 13 candidates), the majority are located within the New York metropolitan area. In addition, AARTS schools are located in California, Colorado, Connecticut, Florida, Illinois, Maryland, Michigan, New Jersey, New York, Ohio and Pennsylvania. Approximately 56 AARTS schools have a total enrollment of under 200 students (with 39 of those schools having less than 100 students). Nine schools have an enrollment of between 200 and 300, while ten schools have over 300 students.

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 almost all of the institutions it accredits. Consequently, the agency must meet the Secretary’s separate and independent requirements.
 
 
Recognition History
 
AARTS was first added to the list of nationally recognized accrediting agencies in 1974 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

 
§602.17 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--
(d) Allows the institution or program the opportunity to respond in writing to the report of the on-site review;

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to ensure that its written policies provide institutions with a reasonable period of time to respond to site visit reports.

Agency Response and Discussion: In response, the agency provided documentation to show that it has revised its Handbook appropriately. The AARTS Handbook now clearly states that an institution will ordinarily have at least three full weeks in which to respond to the site team report.

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

(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.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to provide documentation that when an institution is found out of compliance with any agency standard, that AARTS takes immediate adverse action, or else clearly requires the institution to come into compliance within the maximum timeframe permitted by the criteria. In addition, that documentation should be relatively recent; it should clearly focus on the actions of the decision-makers; and it should be sufficient to demonstrate that the AARTS accreditation actions regarding noncompliance consistently fall within the enforcement timelines required by this criterion.

Agency Response and Discussion: In response, the agency provided documentation to show that the AARTS decision-making body had determined that an institution had not corrected all of the problems cited by the agency within the maximum two-year period allowed. As a result, AARTS moved to remove the school’s accreditation. The school utilized its right to appeal the withdrawal of accreditation and was able to provide the needed compliance documentation to render the appeal moot.

The example provided by AARTS did demonstrate that the agency was complying with the requirements of this section. However, a single example was insufficient to demonstrate that AARTS was complying with the requirements consistently. (The need to demonstrate consistent practice was noted in the original citation.) Therefore, the agency provided additional examples, which have been uploaded under “Analyst’s Supporting Documents.” Those documents adequately demonstrated that AARTS was enforcing its standards within the established timelines on a consistent basis.

As a result of receiving this clarifying documentation, the agency can be found in compliance with the requirements of 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.
 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to provide clear evidence that its written policies and actions regarding extensions for good cause ensure that they are adequately justified and strictly limited in length.

Agency Response and Discussion: In response, the agency provided documentation to show that it had granted a limited extension for good cause to an institution for a clearly justified reason (the death of its primary administrator). In addition, the agency adopted a written policy that specified extensions can only be granted for serious reasons, and listed some of the reasons that could be typically justified. As well, the new written policy specified that an extension for good cause would normally be granted only once, and for a period not to exceed six months. (Evidence related to that new policy has been uploaded under “Analyst’s Supporting Documents.”)

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

§602.22 Substantive change.
(2)The agency's definition of substantive change includes at least the following types of change:

(i) Any change in the established mission or objectives of the institution.

(ii) Any change in the legal status, form of control, or ownership of the institution.

(iii) The addition of courses or programs that represent a significant departure from the existing offerings of educational programs, or method of delivery, from those that were offered when the agency last evaluated the institution.

(iv) The addition of programs of study at a degree or credential level different from that which is included in the institution's current accreditation or preaccreditation.

(v) A change from clock hours to credit hours.

(vi) A substantial increase in the number of clock or credit hours awarded for successful completion of a program.

(vii) If the agency's accreditation of an institution enables the institution to seek eligibility to participate in title IV, HEA programs, the entering into a contract under which an institution or organization not certified to participate in the title IV, HEA programs offers more than 25 percent of one or more of the accredited institution's educational programs.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to provide evidence that it thoroughly reviewed, and granted prior approval, of the identified substantive change (an institution’s substantive educational contract with a non-Title IV entity) following the relevant AARTS written policies.

Agency Response and Discussion: In response, the agency provided documentation to show that it has reinforced the language in its Handbook to ensure that no study abroad program could be implemented before its approval by AARTS. In addition, the agency provided documentation to show that it had reviewed and approved a study abroad agreement during a regular Accreditation Committee meeting. As well, AARTS provided documentation that it had followed up on its commitment to monitor the students’ performance, as required by the written AARTS policy on study abroad programs.

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 AARTS needed to provide documentation that it follows its written policies regarding the complete disposition of appeals under the circumstances cited by the Secretary’s criteria. In addition, the agency needs to demonstrate that the Appeals Board identifies specific issues that the Commission must address, when the Appeals Board amends, reverses or remands the adverse action to the Commission for further action, or to attest these occasions have never arisen.

Agency Response and Discussion: In response, the agency provided documentation to show that it did have occasion to institute an Appeals Board. The agency included a copy of the letter from the Appeals Board to the AARTS Accreditation Commission (Commission), and the letter did identify the specific issues that needed to be considered by the Commission.

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

(g) The agency notifies the institution or program in writing of the result of its appeal and the basis for that result.

 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to provide documentation that AARTS notifies the institution in writing of the result of its appeal, together with the reasons or basis for that result, in a timely manner.

Agency Response and Discussion: In response, the agency provided documentation to show that it had conducted an appeal; that it had notified the institution in writing of the result of the appeal; that the letter included the reasons for the decision of the Appeals Board; and that the letter was transmitted to the institution in a timely manner.

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

§602.26 Notification of accrediting decisions

(c) Provides written notice to the public of the decisions listed in paragraphs (b)(1), (b)(2) and (b)(3) of this section within 24 hours of its notice to the institution or program;


 
Previous Issue or Problem: During its June 2013 review of the agency, Department staff noted that AARTS needed to provide documentation regarding its new policies and procedures that will ensure that the public is notified by AARTS within 24 hours of the agency's notification to the institution of a final adverse decision.

Agency Response and Discussion: In response, the agency provided documentation to show that it had occasion to implement its new public notification mechanism. The agency provided copies of appropriately dated documentation to demonstrate that AARTS had notified the public within 24 of its notification to the adversely-affected institution.

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.