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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   National Association Of Schools Of Music (1952/2014)
                  (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 throughout the United States of freestanding institutions, and units offering music and music-related programs (both degree- and non-degree-granting), including those offered via distance education.
 
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 four years.

 
7.
Issues or Problems:   None


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The National Association of Schools of Music, Commission on Accreditation (NASM or the agency) is both a programmatic and institutional accreditor, however the agency is only requesting the accreditation of freestanding institutions as within its scope of recognition. The principal purpose of this agency is the accreditation of freestanding institutions that offer degree-granting and non-degree-granting music programs and the accreditation of music programs within institutions accredited by a national recognized regional accrediting agency. The agency's freestanding institutions may use its accreditation by the agency to establish eligibility to participate in Title IV, HEA financial aid programs. NASM accredits 14 institutions that are able to use its accreditation as their mechanism to establish eligibility to participate in Federal student aid programs. Five of these institutions currently establish eligibility through NASM accreditation.
 
 
Recognition History
 
NASM has been granted periodic renewal of recognition since its initial recognition in 1952. The last full review of the agency was conducted in December 2007 at which time the National Advisory Committee on Institutional Quality and Integrity (NACIQI or Committee) recommended and the Secretary concurred that the agency’s recognition be renewed for five years and that its scope be expanded to include programs offered via distance education.

In conjunction with the current review of the agency for its continued recognition, Department staff reviewed the agency’s petition and supporting documentation and observed a decision meeting in June 2014. At its last review for continued recognition in 2014, the agency was asked to respond to outstanding issues in a compliance report. The agency's compliance report is the subject of this analysis.



PART II: SUMMARY OF FINDINGS

 
§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 review of the agency's standards for student achievement define specific competencies for various program and credential levels. The standards provide guidance to institutions for developing competencies that meet the agency's requirements, and procedures for visiting evaluators provide guidance for site teams regarding their determination of institution's compliance with the agency's accreditation standards.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its student achievement standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s accreditation student achievement standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(a)(1)(ii) Curricula.
 
Previous review of the agency's standards for curricula define sufficiently detailed and clear ways that they agency assess curricula in verifiable ways and provide guidance to institutions. The procedures for visiting evaluators provide guidance on how to determine if an institution is compliant with the agency's curricula standards.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its curricula standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s accreditation curricula standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(a)(1)(iv) Facilities, equipment, and supplies.
 
Previous review of the agency's standards for facility establish specific requirements to ensure that students have safe and adequate space, equipment and supplies to successfully complete their program and that faculty have the appropriate space for their functions. The agencies standards require compliance with federal and state building and safety requirements. The agency has procedures for visiting evaluators to determine if an institution is complaint with the agency's facility standards.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its facilities, equipment, and supplies standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s facilities, equipment, and supplies standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(a)(1)(ix) Record of student complaints received by, or available to, the agency.
 
Previous review of the agency's standards for the record keeping of student complaints, found that policies existed for filing complaints against member institutions involving the agency's code of ethics and complaints involving its accreditation standards. Details were provided to indicate how the specific criteria must be met and list circumstances or conditions that would make it ineligible for review.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency reconfirmed the details of the maintenance of the student complaints for each accredited institutional member in perpetuity at the National office of the agency.

Additionally, the agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do notwhich is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its student complaint standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s student complaint standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(a)(1)(v) Fiscal and administrative capacity as appropriate to the specified scale of operations.
 
Previous review of the agency's accreditation standards related to assessing the quality of institutions relative to their fiscal and administrative capacity found that they were sufficient. The standards are specific in identifying the expectations for meeting those standards and include procedures to assist visiting evaluators with enough information to determine compliance with the agency's standards.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its fiscal/administrative capacity standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s fiscal and administrative capacity standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(a)(1)(vi) Student support services.
 
Previous review of the agency's standards for student support services provided evidence in a self-study and site visit report that showcased how student support service standards are reviewed.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its student support standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s student support standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

§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.


 
Previous review of the agency's standards for monitoring and reevaluation of accredited institutions and programs found that the agency has policies and procedures that help ensure institutions remain in compliance with its standards and employ multiple tools to conduct monitoring. Tools include the Higher Education Arts Data Service (HEADS) data survey, accreditation audits, affirmation statements, and supplemental annual reports.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its monitoring standards are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s monitoring standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

§602.22 Substantive change.

(a) If the agency accredits institutions, it must maintain adequate substantive change policies that ensure that any substantive change to the educational mission, program, or programs of an institution after the agency has accredited or preaccredited the institution does not adversely affect the capacity of the institution to continue to meet the agency's standards. The agency meets this requirement if--

(1) The agency requires the institution to obtain the agency's approval of the substantive change before the agency includes the change in the scope of accreditation or preaccreditation it previously granted to the institution; and

 
Previous review of the agency's standards for substantive change that established that decision made by the full Commission are required before a substantive change is included in the institutions' grant of accreditation and that the institutions must gain prior approval for any substantive change.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
In November 2014, the agency took affirmative action that indicates the policy applies to all institutions regardless of the designation of NASM as an institutional or programmatic accrediting body. The agency indicated that they began applying the newly-clarified policies upon approval and no actions have been taken (as of submission in January 2015) related to the clarified policies, as no issues of concern have arisen.

The agency has provided documentation included in Article V of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not. Although Article V does not limit the substantive change policy, it does reference the updates made to section XXI regarding exceptions to institutions.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for approvals of substantive change are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s approval standards for substantive change must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(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 review of the agency's standards for types and definitions of substantive change procedures are specific to the type of change being proposed. Its processes include the review of a written request and commission approval of all types of changed outlined and required by this change.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
In November 2014, the agency took affirmative action that indicates the policy applies to all institutions regardless of the designation of NASM as an institutional or programmatic accrediting body. The agency indicated that they began applying the newly-clarified policies upon approval and no actions have been taken (as of submission in January 2015) related to the clarified policies, as no issues of concern have arisen.

The agency has provided documentation included in Article V of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for types of substantive change are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s substantive change standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(ix) The acquisition of any other institution or any program or location of another institution.
(x) The addition of a permanent location at a site at which the institution is conducting a teach-out for students of another institution that has ceased operating before all students have completed their program of study.

 
Previous review of the agency's standards in the Rules of Practice publication and the standards for accreditation provide a clear and substantive process for reviewing and approving the types of substantive changes outlined in this criterion.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
In November 2014, the agency took affirmative action that indicates the policy applies to all institutions regardless of the designation of NASM as an institutional or programmatic accrediting body. The agency indicated that they began applying the newly-clarified policies upon approval and no actions have been taken (as of submission in January 2015) related to the clarified policies, as no issues of concern have arisen.

The agency has provided documentation included in Article V of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering the Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for other locations needing approval are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s other locations needing approval standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(3) The agency's substantive change policy must define when the changes made or proposed by an institution are or would be sufficiently extensive to require the agency to conduct a new comprehensive evaluation of that institution.

 
Previous review of the agency's standards to determine when a new evaluation is required found that the policy stipulates the types of substantive changes that would require institutions to undergo specific or comprehensive on-site evaluations. Additionally, the agency’s policy provided an adequate mechanism to assess multiple substantive change requests both individually and holistically.

When the agency's petition was last reviewed in June 2014, Department staff noted that the agency considered the site visit alone, constituted a new comprehensive evaluation. However, Department staff informed the agency that a new comprehensive evaluation must consist of a self-study, an onsite review, and new decision regarding accreditation.

Discussion:
In November 2014, the agency took affirmative action that indicates how to conduct a comprehensive review including procedures for the on-site visit, requirements for self-study, and required Commission activities. In order to be found compliant the agency must provide additional information and documentation demonstrating that it has applied the new policy related to providing comprehensive evaluations.

Analyst Remarks to Response:
Additional information provided by the agency reconfirms the steps that NASM's policies outline the procedures for a comprehensive review including the site visit, self-study, and new decision about accreditation. The agency has additionally noted that they have not had a chance to apply this policy during this review period.
 


(c) Except as provided in (a)(2)(viii)(A) of this section, if the agency's accreditation of an institution enables the institution to seek eligibility to participate in Title IV, HEA programs, the agency's procedures for the approval of an additional location where at least 50 percent of an educational program is offered must provide for a determination of the institution's fiscal and administrative capacity to operate the additional location. In addition, the agency's procedures must include--


 
Previous review of the agency's standards to determine fiscal and administrative capacity included procedures and policies needed for approval related to the administrative capacity in the additional location.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency needed to clarify that the additional locations should define where "at least 50% of an educational program is offered."

Discussion:
The agency has provided documentation included in article V of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been to define the additional locations that explain “where at least 50% of an educational program is offered.” Although the revised language in article V does not limited the applicability of the approval of fiscal and administrative capacity, the policy itself references additional requirements in section XXI of the standards which includes an exception for institutions that designate another recognized regional or national accrediting agency for the purposes of Title IV eligibility.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for fiscal and administrative capacity are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s fiscal and administrative capacity determination standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(c)(1) A visit, within six months, to each additional location the institution establishes, if the institution--
(i) Has a total of three or fewer additional locations;

(ii) Has not demonstrated, to the agency's satisfaction, that it has a proven record of effective educational oversight of additional locations; or

(iii) Has been placed on warning, probation, or show cause by the agency or is subject to some limitation by the agency on its accreditation or preaccreditation status;

 
Previous review of the agency's standards to determine approval of the additional location found that the agencies policies require that all additional locations to be visited within six months after the start of the first class and again at each review of accreditation of the main campus.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency clarify that the additional campus locations should define where "at least 50% of an educational program is offered."

Discussion:
The agency has provided documentation included in article V of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been to define the additional locations that explain “where at least 50% of an educational program is offered.” Although the revised language in article V does not limited the applicability of the approval for additional locations, the policy itself references additional requirements in section XXI of the standards which includes an exception for institutions that designate another recognized regional or national accrediting agency for the purposes of Title IV eligibility.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for approval of additional locations are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s approval of additional location standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 


(c)(2) An effective mechanism for conducting, at reasonable intervals, visits to a representative sample of additional locations of institutions that operate more than three additional locations; and
 
Previous review of the agency's standards to determine if there is an effective mechanism for visits found that the agencies policies require that all additional locations to be visited within six months after the start of the first class and again at each review of accreditation of the main campus.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency clarify that the additional campus locations should define where "at least 50% of an educational program is offered."

Discussion:
The agency has provided documentation included in article V of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been to define the additional locations that explain “where at least 50% of an educational program is offered.” Although the revised language in article V does not limited the applicability of the approval for 3+ locations, the policy itself references additional requirements in section XXI of the standards which includes an exception for institutions that designate another recognized regional or national accrediting agency for the purposes of Title IV eligibility.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for 3+ additional locations are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s additional approval of 3+ location standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(c)(3) An effective mechanism, which may, at the agency's discretion, include visits to additional locations, for ensuring that accredited and preaccredited institutions that experience rapid growth in the number of additional locations maintain educational quality.
 
Previous review of the agency's standards to determine if there is an effective mechanism for visits related to ensuring rapid growth found that the agencies policies do not specifically address rapid growth in the number of locations. Rather it is the oversight and monitoring of each additional location that provides an effective mechanism for ensuing that institutions experiencing rapid growth in the number of additional locations maintain educational quality.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency clarify that the additional campus locations should define where "at least 50% of an educational program is offered."

Discussion:
The agency has provided documentation included in article V of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been to define the additional locations that explain “where at least 50% of an educational program is offered.” Although the revised language in article V does not limited the applicability of the approval for rapid growth, the policy itself references additional requirements in section XXI of the standards which includes an exception for institutions that designate another recognized regional or national accrediting agency for the purposes of Title IV eligibility.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for approval of rapid growth are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s approval for rapid growth standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

§602.23 Operating procedures all agencies must have.

(d) If an institution or program elects to make a public disclosure of its accreditation or preaccreditation status, the agency must ensure that the institution or program discloses that status accurately, including the specific academic or instructional programs covered by that status and the name, address, and telephone number of the agency.


 
Previous review of the agency's standards to determine if the institution or program makes public disclosure of its accreditation or preaccreditation status found that the agency had written policies and procedures, however there was language included that caused it to be out of compliance.

When the agency's petition was last reviewed in June 2014, Department staff found the policy to stipulate that institutions should publish in on or more official documents concerning its music program, or otherwise make available upon request, the name, address and telephone number of NASM. This criterion requires the public disclosure of this information absent a specific request from the public.

Discussion:
The agency's Handbook still stipulates that institutions make the agency's name, address, and telephone number available, "upon request." The agency must ensure that if an institution makes public disclosure of its accreditation status, it must disclose the information stipulated under this section, and not narrowly "upon request".

Analyst Remarks to Response:
Additional information provided by the agency has indicated that there was a recent change in Handbook language in May 2015 to edit the language that was of concern to the Department. The agency has removed the language that indicated the information was available 'upon request.' The updated language in the policy explains that the institution shall provide information about its music program, the name, address, and telephone number of NASM. This new policy meets the criteria outlined in this section.
 

§602.24 Additional procedures certain institutional accreditors must have.
If the agency is an institutional accrediting agency and its accreditation or preaccreditation enables those institutions to obtain eligibility to participate in Title IV, HEA programs, the agency must demonstrate that it has established and uses all of the following procedures:

(a) Branch campus.
(1) The agency must require the institution to notify the agency if it plans to establish a branch campus and to submit a business plan for the branch campus that describes--
(i) The educational program to be offered at the branch campus;

(ii) The projected revenues and expenditures and cash flow at the branch campus; and

(iii) The operation, management, and physical resources at the branch campus.
(2) The agency may extend accreditation to the branch campus only after it evaluates the business plan and takes whatever other actions it deems necessary to determine that the branch campus has sufficient educational, financial, operational, management, and physical resources to meet the agency's standards.

(3) The agency must undertake a site visit to the branch campus as soon as practicable, but no later than six months after the establishment of that campus.

 
Previous review of the agency's standards to determine how the agency requires the institution to notify them if it plans to establish a branch campus and to submit a business plan for the branch campus found that the agency had a detailed approval process that required submission of a business plan, preliminary onsite review, and final approval by the Commission.

However, when the agency's petition was last reviewed in June 2014, Department staff found that while their standards existed, the agency had different requirements depending on whether the institution uses the agency’s accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Article V of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. Although the revised language in article V does not limited the applicability of the branch campus policy, the policy itself references additional requirements in section XXI of the standards which includes an exception for institutions that designate another recognized regional or national accrediting agency for the purposes of Title IV eligibility.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for branch campuses are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s branch campus standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(b) Change of ownership.

The agency must undertake a site visit to an institution that has undergone a change of ownership that resulted in a change of control as soon as practicable, but no later than six months after the change of ownership.

 
Previous review of the agency's standards to determine how the agency undertakes a site visit due to an institution that has undergone a change of ownership found that the agency has several policies with different requirements related to change of ownership.

When the agency's petition was last reviewed in June 2014, Department staff found that a distinction needed to be made that involved the agency stating that a site visit would be conducted to an institution undergoing a change of ownership within six months of the change of ownership. The agency's policy must address the specific requirements of this criterion and be applicable to all institutions accredited by the agency across the board.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates specific operational standards for all institutions of higher education accredited by NASM. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for a change in ownership are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s change in ownership standards must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(c) Teach-out plans and agreements.
(1) The agency must require an institution it accredits or preaccredits to submit a teach-out plan to the agency for approval upon the occurrence of any of the following events:

(i) The Secretary notifies the agency that the Secretary has initiated an emergency action against an institution, in accordance with section 487(c)(1)(G) of the HEA, or an action to limit, suspend, or terminate an institution participating in any title IV, HEA program, in accordance with section 487(c)(1)(F) of the HEA, and that a teach-out plan is required.

(ii) The agency acts to withdraw, terminate, or suspend the accreditation or preaccreditation of the institution.

(iii) The institution notifies the agency that it intends to cease operations entirely or close a location that provides one hundred percent of at least one program.

(iv) A State licensing or authorizing agency notifies the agency that an institution's license or legal authorization to provide an educational program has been or will be revoked.

 
Previous review of the agency's standards to determine how the agency requires an institution it accredits or preaccredits to submit a teach out plan found the current policy to be problematic because it was only applicable to institutions that use the agency's accreditation to participate in Title IV student aid program.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for teach out plan triggers are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s teach-out policy requirements must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(2) The agency must evaluate the teach-out plan to ensure it provides for the equitable treatment of students under criteria established by the agency, specifies additional charges, if any, and provides for notification to the students of any additional charges.

 
Previous review of the agency's standards to determine how the agency evaluates the teach out plan to ensure it provides for equitable treatment of students found that the agency's policy was currently only applicable to some of the institutions it accredits.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included Section XXI of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for student treatment are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s teach-out policy requirements must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(3) If the agency approves a teach-out plan that includes a program that is accredited by another recognized accrediting agency, it must notify that accrediting agency of its approval.

 
Previous review of the agency's standards to determine if the agency’s policy for approving teach out plans that involves a program that is accredited by another recognized accrediting agency, found that the current policy was only applicable to some of the institutions it accredits.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that do not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for notifying other agencies are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s notification of other agency's requirements must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(4) The agency may require an institution it accredits or preaccredits to enter into a teach-out agreement as part of its teach-out plan.

 
Previous review of the agency's standards to determine if the agency’s policy for approving teach out agreements as part of an institutions teach out plan found that it was currently only applicable to some of the institution's it accredits.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that are not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for requiring teach out agreements are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s teach-out policy agreement requirements must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

(5) The agency must require an institution it accredits or preaccredits that enters into a teach-out agreement, either on its own or at the request of the agency, with another institution to submit that teach-out agreement to the agency for approval. The agency may approve the teach-out agreement only if the agreement is between institutions that are accredited or preaccredited by a nationally recognized accrediting agency, is consistent with applicable standards and regulations, and provides for the equitable treatment of students by ensuring that--
(i) The teach-out institution has the necessary experience, resources, and support services to--
(A) Provide an educational program that is of acceptable quality and reasonably similar in content, structure, and scheduling to that provided by the institution that is ceasing operations either entirely or at one of its locations;

(B) Remain stable, carry out its mission, and meet all obligations to existing students; and
(ii) The teach-out institution demonstrates that it can provide students access to the program and services without requiring them to move or travel substantial distances and that it will provide students with information about additional charges, if any.

 
Previous review of the agency's standards to determine if the agency’s policy for approving teach out agreements found that policy was currently only applicable to some of the institution's it accredits.

When the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had different requirements depending on whether the institution uses the agency's accreditation to establish Title IV eligibility and those that are not.

Discussion:
The agency has provided documentation included in Section XXI of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. A distinction has been made to clarify which standards apply between institutions that use its accreditation to participate in Title IV student aid programs and those that do not which is confusing considering Department staff’s previous compliance determination.

In order to be found compliant the agency must clearly stipulate in its policy publications that its standards for approval of teach out agreements are applicable to all freestanding institutions of music regardless of whether the institution uses the agency’s accreditation to participate in Title IV Federal Student Aid programs or does not. The agency provide must also provide additional information and documentation demonstrating that it applies its standards to all of its accredited, freestanding institutions regardless of the Title IV designation.

Analyst Remarks to Response:
Previously, the Department had found that the agency’s teach-out policy requirements must be applied equally to all freestanding institutions accredited by the agency. Therefore, it was concluded that the agency must revise its policy to address this issue.

In May 2015, the agency has submitted a revision to its Standards for Accreditation, specifically section XXI of the NASM handbook that prescribes the specific operational standards for free standing institutions of higher education regardless of Title IV designation.

As a result of the change, the policy is now compliant with the Secretary's Criteria for Recognition. At the time of this review, the agency has not the chance to apply the new standards.
 

§602.28 Regard for decisions of States and other accrediting agencies.
(c) The agency may grant accreditation or preaccreditation to an institution or program described in paragraph (b) of this section only if it provides to the Secretary, within 30 days of its action, a thorough and reasonable explanation, consistent with its standards, why the action of the other body does not preclude the agency's grant of accreditation or preaccreditation.

 
Previous review of the agency's standards to determine how the agency may grant accreditation to an institution within 30 days of its acts action in regards for decisions of states and other accrediting agencies found that the agency did have a written policy.

However, when the agency's petition was last reviewed in June 2014, Department staff found while their standards existed, the agency had not specified that the notification needed to occur within the thirty days of the action. Additionally, the agency has affirmed that it had no cause to provide an explanation to the Secretary of Education during this recognition period.

Discussion:
The agency has provided documentation included in Appendix III of the NASM handbook that has a policy clarification that indicates the policy wording change suggested by the Department. The agency has indicated that they have not needed to provide an explanation to the Secretary of Education at this time.


 
 

PART III: THIRD PARTY COMMENTS

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