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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 Theatre (1982/2014)
                  (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 that offer theatre and theatre-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 Theatre (NAST) Commission on Accreditation, accredits freestanding institutions and schools of theatre within regionally-accredited institutions that offer theatre and theatre-related programs (both degree and non-degree granting), including those offered via distance education. While the vast majority of the agency's accrediting activities occurs in theatre and theatre arts programs in regionally-accredited colleges and universities, the agency establishes eligibility for participation in Title IV, HEA programs for 14 freestanding institutions of its total of 177 accredited programs/institutions.
 
 
Recognition History
 
The NAST Commission on Accreditation was granted intitial recognition in 1982 and has been
periodically reviewed for renewal of recognition since that time.The agency was last granted a five-year period of recognition in 2008 when Department staff reviewed the agency in conjunction with its three other arts organization counterparts (art and design; music; and dance). 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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that all its standards related to student achievement apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding theatre institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(a)(1)(ii) Curricula.
 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that all its standards related to curricula apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding theatre institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(a)(1)(ix) Record of student complaints received by, or available to, the agency.
 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that all its standards related to student complaints apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding theatre institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(a)(1)(vi) Student support services.
 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that all its standards related to student support services apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding theatre institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(a)(1)(x) Record of compliance with the institution's program responsibilities under Title IV of the Act, based on the most recent student loan default rate data provided by the Secretary, the results of financial or compliance audits, program reviews, and any other information that the Secretary may provide to the agency; and
 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that all its standards related to Title IV responsibilities apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding theatre institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

§602.19 Monitoring and reevaluation of accredited institutions and programs.

(b) The agency must demonstrate it has, and effectively applies, a set of monitoring and evaluation approaches that enables the agency to identify problems with an institution's or program's continued compliance with agency standards and that takes into account institutional or program strengths and stability. These approaches must include periodic reports, and collection and analysis of key data and indicators, identified by the agency, including, but not limited to, fiscal information and measures of student achievement, consistent with the provisions of §602.16(f). This provision does not require institutions or programs to provide annual reports on each specific accreditation criterion.


 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its monitoring activities apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 


(d) Institutional accrediting agencies must monitor the growth of programs at institutions experiencing significant enrollment growth, as reasonably defined by the agency.


 
Although the agency was not required to respond to this section, Department staff reviewed the submission for compliance.
 

§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.

 
Although the agency was not required to respond to this section, Department staff reviewed the submission for compliance.
 

§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

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
Although the agency was not required to respond to this section, Department staff reviewed the submission for compliance.
 


(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--


 
The agency has since amended its definition for branch campus to encompass additional locations where at least 50% of an educational program is offered.

However, Department staff noted in its previous review that all institutions accredited by the agency must meet all of the agency's policies for all freestanding institutions and not limit its policies to only those that designate the agency as its Title IV accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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;

 
The agency has since amended its definition for branch campus to encompass additional locations where at least 50% of an educational program is offered.

However, Department staff noted in its previous review that all institutions accredited by the agency must meet all of the agency's policies for all freestanding institutions and not limit its policies to only those that designate the agency as its Title IV accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 


(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
 
The agency has since amended its definition for branch campus to encompass additional locations where at least 50% of an educational program is offered.

However, Department staff noted in its previous review that all institutions accredited by the agency must meet all of the agency's policies for all freestanding institutions and not limit its policies to only those that designate the agency as its Title IV accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.
 
The agency has since amended its definition for branch campus to encompass additional locations where at least 50% of an educational program is offered.

However, Department staff noted in its previous review that all institutions accredited by the agency must meet all of the agency's policies for all freestanding institutions and not limit its policies to only those that designate the agency as its Title IV accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

§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.


 
Section 1D of 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, that it also discloses the information stipulated under this section, and not narrowly "upon request".

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that the agency's public disclosure policy requires the inclusion of the name, address, and telephone number of the agency, as required by this section. Specifically, the agency's policy now clearly states that institutions must publish the agency's name, address, and telephone number. The agency also stated that it has not yet had the opportunity to apply this policy and therefore, cannot provide documentation of implementation.
 

§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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its substantive change policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its teach-out policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its teach-out policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its teach-out policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its teach-out policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

(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.

 
The agency has not made compliant changes to Section XIX of its Handbook to ensure that it applies Section XIX to all of its freestanding institutions and not limit this section to only those institutions that designate NAST as its institutional accreditor.

Analyst Remarks to Response:
In response to the draft staff analysis, the agency provided information and documentation to demonstrate that its teach-out policies apply to all of its freestanding institutions. Specifically, section XIX of the handbook now clearly states that it is applicable to freestanding dance institutions of higher education that offer professional education and training in theatre or theatre-related programs, without exception. The agency also stated that it has not yet had the opportunity to apply these standards and therefore, cannot provide documentation of implementation.
 

§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.

 
Although the agency was not required to respond to this section, Department staff reviewed the submission for compliance.
 
 

PART III: THIRD PARTY COMMENTS

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