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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   North Central Association Of Colleges and Schools, The Higher Learning Commission (1952/2015)
                  (The dates provided are the date of initial listing as a recognized agency and the date of the agency’s last grant of recognition.)
 
2.
Action Item:   Compliance Report
 
3.
Current Scope of Recognition:   The accreditation and preaccreditation ("Candidate for Accreditation") of degree-granting institutions of higher education in Arizona, Arkansas, Colorado, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska, New Mexico, North Dakota, Ohio, Oklahoma, South Dakota, West Virginia, Wisconsin, and Wyoming, including the tribal institutions and the accreditation of programs offered via distance education and correspondence education within these institutions. This recognition extends to the Institutional Actions Council jointly with the Board of Trustees of the Commission for decisions on cases for continued accreditation or reaffirmation, and continued candidacy, and to the Appeals Body jointly with the Board of Trustees of the Commission for decisions related to initial candidacy or accreditation or reaffirmation of accreditation.
 
4.
Requested Scope of Recognition:   Same as above.
 
5.
Date of Advisory Committee Meeting:   June, 2015
 
6.
Staff Recommendation:   Renew the agency's recognition for two and one half years.
 
7.
Issues or Problems:   None


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Higher Learning Commission (HLC or the agency) is a regional institutional accreditor that accredits (or preaccredits) over 1,000 degree granting institutions in 19 states, tribal institutions and including those programs offered via distance education within these institutions.

Most of the institutions accredited by HLC use the Secretary’s recognition of the agency to establish eligibility to participate in the Title IV, HEA student financial assistance programs. Therefore, the agency must meet the separate and independent requirements.

The current recognition of HLC extends to the Institutional Action Council jointly with the Board of Trustees for decision on cases for continued accreditation or reaffirmation, and continued candidacy. The Secretary’s recognition also extends to the Appeals Panel jointly with the Board of Trustees of the Commission for decisions related to initial candidacy or accreditation or reaffirmation of accreditation.
 
 
Recognition History
 
HLC received initial recognition in 1952 and has received periodic renewal of recognition since that time. The last full review of the agency was conducted in June 2013, at which time the National Advisory Committee on Institutional Quality and Integrity (NACIQI or the Committee) and Department staff found the agency out of compliance with 11 sections, and recommended the continued recognition of the agency and that it come into compliance within 12 months and submit a compliance report. The senior Department official, Acting Assistant Secretary Brenda Dann-Messier, concurred with the recommendations, and this compliance report is in response to that requirement.

In 2009, Department staff conducted a special review of the agency following issuance of an Alert Memorandum by the Office of the Inspector General. Department staff sent the agency a report on the results of its review, which required the agency to develop a corrective action plan. One element of that plan was a requirement that the agency review and modify, as appropriate, substantive change policies, developing clear written procedures with internal controls consistent with stated procedures to assess exceptional circumstances, and demonstrate implementation of the specific procedures to deal with changes in ownership resulting in a change in control. This information was considered in the review of the interim report by Department staff and reviewed by NACIQI in December 2010.


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 issue: When the agency’s petition was last reviewed in June 2013, Department staff found the agency had standards in place; they had not been able to provide documentation of implementation of their new standards as related to student learning and assessment.

Discussion: In the agency’s submission, they reconfirmed that they have clear expectations regarding student achievement in relation to the institution’s mission, outlined in Criterion Four, Core Components 4.B and 4.C and in FDCR.A.10.080.

The agency provided additional information and documentation to demonstrate that it evaluates the appropriateness of the measures of student achievement chosen by its institutions, and that it assesses the compliance of institutions with its student achievement standards. Specifically, the agency provided two example self-studies and evaluation reports that explain how the institution itself and the evaluation team made a judgment about their measures of student achievement. The self-studies further document the selection of variable data, implementation of how the data that was collected from each institution, and how it was utilized for making improvements to each institution, respectively. Federal compliance data related to job placement was collected and will be used to assist future graduates.
 

(a)(1)(ii) Curricula.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to the curricula.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address curricula outlined in their standards in sections Criterion Three, Core Components 3.A and 3.B and Criterion Four, Core Component 4.A.

The agency provided additional information and documentation to demonstrate that it evaluates the appropriateness of the curriculum at each institution. Specifically, the agency provided two example self-studies and evaluation reports that showcase how each institution and the evaluation teams reviewed the curriculum standards to ensure compliance related to determinations of appropriateness for the degree-level and ensuring quality academic standards for programs offered both residentially and via distance education.
 

(a)(1)(iii) Faculty.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to faculty.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address faculty outlined in their standards in Criteria 3 and 5.

The agency provided additional information and documentation to demonstrate that it evaluates the appropriateness of faculty. Specifically, the agency provided two example self-studies and agency evaluation reports that explain how the institution itself and the agency evaluation team made a judgment about their faculty. Information provided showcases how faculty workloads, well-being, and appropriate credentials are considered are each institution.
 

(a)(1)(iv) Facilities, equipment, and supplies.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to facilities, equipment, and supplies.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address facilities, equipment, and supplies outlined in their standards in Criteria 3, 4, and 5.

The agency provided additional information and documentation to demonstrate that it evaluates the appropriateness of facilities, equipment, and standards. Specifically, the agency provided two example self-studies and evaluation reports that explain how the institution itself and the evaluation team made a judgment about the adequacy and appropriateness of each institution’s facilities, equipment, and supplies.
 

(a)(1)(ix) Record of student complaints received by, or available to, the agency.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to student complaints.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address its student complaint policies in FDCR.A.10.030.

In response to the Department’s finding, the agency provided two examples of how the institution student complaint process occurs. Specifically, the agency provides example agency evaluation team reports and federal compliance documentation that showed the process for how they reviewed the complaints, the timeliness of the response to the issue, and how they conduct a review to determine if there is a pattern for the complaints. In this example, few complaints had been received and there was no distinguishable pattern.
 

(a)(1)(v) Fiscal and administrative capacity as appropriate to the specified scale of operations.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to fiscal and administrative capacity.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address fiscal and administrative capacity outlined in their standards in Criteria 3 and 5.

The agency provided additional information and documentation to demonstrate that it evaluates fiscal and administrative capacity at each institution. Specifically, the agency provided two example self-studies and evaluation reports that explain how the institution itself and the agency evaluation team made a judgment about processes to ensure robust fiscal and administrative policies and procedures at the institutional level.
 

(a)(1)(vi) Student support services.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to student support services.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address student support services outlined in their standards in Criteria 3.

The agency provided additional information and documentation to demonstrate that it evaluates the appropriateness of the student support services each institution offers. Specifically, the agency provided two example self-studies and agency evaluation reports that explain how the institution itself and the evaluation team made a judgment about each institutions student support services including reviews of libraries, academic advising, and supportive of the student populations they serve.
 

(a)(1)(vii) Recruiting and admissions practices, academic calendars, catalogs, publications, grading, and advertising.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to its recruiting and admissions practices.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address recruiting and admissions practices outlined in their standards in Criteria 1, 2, and 4.

In response to the Department’s finding, the agency provided additional information and documentation to demonstrate that it evaluates an institution’s recruiting and admission practices. Specifically, the agency provided example agency evaluation team reports that demonstrate the review of the institutional disclosures related to admission requirements, tuition fees, financial aid, academic calendars and other required information.
 

(a)(1)(viii) Measures of program length and the objectives of the degrees or credentials offered.
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to its measures of program length and the objectives of the degrees or credentials offered.

Discussion: In the agency’s submission, they reconfirmed that they have developed policies and processes outlined to address its measures of program length and the objectives of the degrees or credentials offered outlined in their standards in Criteria 2 and 3.

In response to the Department’s finding, the agency provided additional information and documentation to demonstrate that it measures of program lengths and the objectives of the degrees or credentials offered at each institution. Specifically, an agency evaluation report determined that credit hours and measures of program length in the academic programs to be ‘appropriate and with the range of good practice of higher education.’ This determination was made through the review and evaluation of the institution’s practices against the agency’s credit hour worksheet.
 

(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
 
Previous issue: When the agency’s petition was last reviewed in June 2013, Department staff found while their standards existed, the agency had previously not been able to provide documentation of implementation of their new standards as related to its Title IV responsibilities.

Discussion: In the agency’s submission, the agency reconfirmed that they have developed policies and processes outlined to address its Title IV responsibilities in the agency's Federal Compliance Requirement (FDCR.A.10.060).

In response to the Department’s finding, the agency provided additional information and documentation (including Federal compliance documentation and agency evaluation worksheets) to demonstrate the process it follows to review of Title IV responsibilities at the institution level. Specifically, the agency provided example agency evaluation team reports and Federal compliance documentation that showed the process for how the agency ensures institutional compliance with federal Title IV processes.
 

§602.24 Additional procedures certain institutional accreditors must have.

(e) Transfer of credit policies.


The accrediting agency must confirm, as part of its review for initial accreditation or preaccreditation, or renewal of accreditation, that the institution has transfer of credit policies that--

(1) Are publicly disclosed in accordance with §668.43(a)(11); and

(2) Include a statement of the criteria established by the institution regarding the transfer of credit earned at another institution of higher education.
(Note: This criterion requires an accrediting agency to confirm that an institution's teach-out policies are in conformance with §668.43(a)(11).  For your convenience, here is the text of 668.43(a)(11): "A description of the transfer of credit policies established by the institution which must include a statement of the institution's current transfer of credit policies that includes, at a minimum –
(i) Any established criteria the institution uses regarding the transfer of credit earned at another institution; and
(ii) A list of institutions with which the institution has established an articulation agreement.")

 
Previous Issue: When the agency’s petition was last reviewed in June 2013, Department staff found that the agency did not demonstrate implementation of its transfer of credit policy related to the public disclosure of a list of institutions or programs with which the institution has established an articulation agreement. The agency provided its revised policy to include all elements required by this section, but could not submit documentation of implementation of this policy.

Discussion: In response to the Department’s finding, the agency provided additional information and documentation to demonstrate implementation of its use of the public disclosure list that indicates which institutions or programs have established articulation agreements. Specifically, the agency provided information on how it reviews institutions through its Federal compliance documentation and excerpts from agency evaluation team reports to demonstrate that it had reviewed institutions and their articulation agreements under this policy.
 
 

PART III: THIRD PARTY COMMENTS

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