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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   New England Commission of Higher Education (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 pre-accreditation ("Candidacy status") of institutions of higher education in Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont that award bachelor’s, master’s, and/or doctoral degrees and associate degree-granting institutions in those states that include degrees in liberal arts or general studies among their offerings, including the accreditation of programs offered via distance education within these institutions.
 
4.
Requested Scope of Recognition:   The agency's scope was revised in 2013. The agency is not requesting any additional changes to its scope of recognition.
 
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 New England Association of Schools and Colleges, Commission on Institutions of Higher Education is a regional accreditor that currently accredits approximately 230 institutions in the six states of Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont. The agency's accreditation is used by institutions in the region to establish eligibility to participate in the federal Title IV student financial assistance programs under the Higher Education Act. The agency is recognized for the accreditation and pre-accreditation ("Candidacy status") of institutions of higher education that award bachelor's, master's, and/or doctoral degrees and associate degree-granting institutions in those states that include degrees in liberal arts or general studies among their offerings, including the accreditation of programs offered via distance education within these institutions.
 
 
Recognition History
 
The NEASC-CIHE has been on the Secretary's list of recognized accrediting agencies since 1952. Its last full petition for continued recognition was reviewed at the Spring 2013 NACIQI meeting. At that time, the Secretary revised the wording of the agency's scope to remove any references to the NEASC's Board of Trustees and requested that the agency come into compliance with four issues within twelve months and submit a compliance report on those issues. That compliance report is the subject of the current staff analysis.


PART II: SUMMARY OF FINDINGS

 
§602.12 Accrediting Experience

(b) A recognized agency seeking an expansion of its scope of recognition must demonstrate that it has granted accreditation or preaccreditation covering the range of the specific degrees, certificates, institutions, and programs for which it seeks the expansion of scope.


(NOTE: Only recognized agencies seeking an expansion of scope need to respond.)


 
In its Spring 2013 petition, the Commission on Institutions of Higher Education (CIHE) of the New England Association of Schools and Colleges (NEASC) requested a rewording (not an expansion) of its scope of recognition. However, during the course of the staff analysis, it was found that the proposed scope contained references to the NEASC's Board of Trustees, which raised concerns related to the separate and independent requirements found under 602.14.

As a result of the 2013 staff analysis, the agency proposed a further rewording of its scope, which was accepted by the NACIQI at its Spring 2013 meeting. The second rewording removed any references to the NEASC's Board of Trustees, in order to accurately reflect the agency's revised organizational structure, and the acceptance of the revised scope was noted in the Secretary's July 2013 decision letter to the agency.

As noted above, the agency's revised scope has already been accepted and implemented as of July 2013. Staff accepts the agency's narrative and supporting documentation related to the 2013 changes, and no additional information is requested.
 

§602.14 Purpose and organization

(a) The Secretary recognizes only the following four categories of agencies:

The Secretary recognizes...

(1) An accrediting agency

(i) Has a voluntary membership of institutions of higher education;

(ii) Has as a principal purpose the accrediting of institutions of higher education and that accreditation is a required element in enabling those institutions to participate in HEA programs; and

(iii) Satisfies the "separate and independent" requirements in paragraph (b) of this section.

(2) An accrediting agency

(i) Has a voluntary membership; and

(ii) Has as its principal purpose the accrediting of higher education programs, or higher education programs and institutions of higher education, and that accreditation is a required element in enabling those entities to participate in non-HEA Federal programs.

(3) An accrediting agency for purposes of determining eligibility for Title IV, HEA programs--

(i) Either has a voluntary membership of individuals participating in a profession or has as its principal purpose the accrediting of programs within institutions that are accredited by a nationally recognized accrediting agency; and

(ii) Either satisfies the "separate and independent" requirements in paragraph (b) of this section or obtains a waiver of those requirements under paragraphs (d) and (e) of this section.

(4) A State agency

(i) Has as a principal purpose the accrediting of institutions of higher education, higher education programs, or both; and

(ii) The Secretary listed as a nationally recognized accrediting agency on or before October 1, 1991 and has recognized continuously since that date.

 
In the Spring 2013 staff analysis, the agency was requested to provide additional information and documentation establishing that it operates separately and independently of the NEASC Board of Trustees.

Based upon the agency's response and supporting documentation related to the separate and independent issues that are provided in this report under 602.14(b), staff accepts that the agency now operates independently of the NEASC Board of Trustees and that it meets the requirements of 602.14(a)(1). No additional information is requested.
 

(b) For purposes of this section, the term separate and independent means that--
(1) The members of the agency's decision-making body--who decide the accreditation or preaccreditation status of institutions or programs, establish the agency's accreditation policies, or both--are not elected or selected by the board or chief executive officer of any related, associated, or affiliated trade association or membership organization;

(2) At least one member of the agency's decision-making body is a representative of the public, and at least one-seventh of that body consists of representatives of the public;

(3) The agency has established and implemented guidelines for each member of the decision-making body to avoid conflicts of interest in making decisions;

(4) The agency's dues are paid separately from any dues paid to any related, associated, or affiliated trade association or membership organization; and

(5) The agency develops and determines its own budget, with no review by or consultation with any other entity or organization.

 
In the Spring 2013 staff analysis, concerns were noted regarding the CIHE's operations and its independence from the parent NEASC. Four areas of staff concern were: 1) the selection of CIHE Appeals Panel members; 2) budget autonomy related to CIHE dues; 3) control over CIHE staff contracts; and 4) the timeframes specified in a Memorandum of Understanding (MOU) between the NEASC and the CIHE. The CIHE was therefore requested to provide additional information and documentation demonstrating that it operates separately and independently of the NEASC in these four areas.

Appeals Panel
In response to the 2013 concerns, the NEASC amended its bylaws to specifically state that the CIHE will have the authority to independently appoint appeals panel members (Ex. 1, Article IV, Section 8(viii), p. 6). ED staff accepts the agency's narrative and supporting documentation related to this concern, and no additional information is requested.

Budget Autonomy
In response to the 2013 concerns, the NEASC amended its bylaws to specifically state that the CIHE will be independently responsible for the determination and collection of its membership dues (Ex. 1, Article IV, Section 8(vii), p. 6. Further, the MOU between the NEASC and the CIHE was revised to state that the CIHE sets and collects its dues from its members and determines its own operating budget (Ex. 2, Action Items 2 and 4, p. 2). A copy of the CIHE's 2014-2015 budget was also submitted (Ex. 4). ED staff accepts the agency's narrative and supporting documentation related to this concern, and no additional information is requested.

CIHE Staff
In response to the 2013 concerns, the NEASC amended its bylaws to specify that the CIHE will have the authority to independently select its own staff (Ex. 1, Article IV, Section 8(iii), p. 6). Documentation was provided demonstrating that the CIHE has its own staff evaluation system (Exs. 6 and 7). has job titles that differ from the other NEASC Commissions (Ex. 8), and that the NEASC made plans to revise its personnel policies to include an addendum related to the independence of the CIHE (Ex. 9). The agency notes in its narrative that, at the time the compliance report was submitted, the addendum referenced in Exhibit 9 had not yet been formally accepted by the NEASC Trustees.

ED staff accepts the agency's narrative related to the changes made to demonstrate the independence of staff selection, as well as most of its supporting documentation. However, the agency is requested to submit documentation demonstrating that the Proposed Addendum to NEASC Personnel Manual for CIHE 7.9.2014 (Ex. 9) related to the CIHE's authority to set salaries for CIHE staff was formally approved by the NEASC Trustees at its September 2014 meeting, as planned.

MOU
In response to the 2013 concerns, the MOU between the NEASC and the CIHE was revised. The original MOU specified a timeframe for the memorandum whose dates might not synchronize with the agency's period of ED recognition. The revised MOU states that the MOU will run from the signing date through the period of federal recognition and will automatically renew with each federal renewal of recognition (Ex. 2, p. 3). ED staff accepts the agency's narrative and supporting documentation related to this concern, and no additional information is requested.

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional documentation demonstrating that a proposed addendum to the NEASC Personnel Manual related to the CIHE's independence in staff selection had been formally accepted. In its response to the draft, the agency reports that the addendum was not accepted. Instead, the addendum was modified to instead change it to a stand-alone document. The agency provided a copy of the stand-alone document (Ex. 10). The document clearly states that the CIHE may offer employment contracts to exempt employees (p. 3). The stand-alone document also specifies other areas of personnel policy that will defer to the CIHE president or the CIHE executive committee, including areas related to personnel records, various types of leave, salaries, and performance reviews. The agency provided a copy of the minutes demonstrating that the stand-alone document had been formally accepted by the NEASC Trustees in December 2014 (Ex. 11).

Staff accepts the agency's narrative and supporting documentation, and no additional information is requested.
 

§602.22 Substantive change.

(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

 
In the Spring 2013 analysis, the agency was requested to revise its approval policies and procedures to address how it will select representative samples of additional locations for review during focused on-site visits.

In response to the 2013 concerns, the agency states that it revised its policies, as requested (Ex. 10, p. 6). The revised policy describes how a representative sample of off-campus locations will be selected. The sample will be selected in consultation with the CIHE staff, the institution, and the on-site review team's chair, who will review the number, enrollments, and geographic distribution of the institution's off-campus locations. If an institution has two or more off-campus locations, no fewer than two off-campus location will be visited. If there are campuses located in other states, at least one out-of-state location will be visited. If there are foreign campuses, at least one overseas location will be visited.

Staff accepts the agency's narrative and supporting documentation, and no additional information is requested.
 
 

PART III: THIRD PARTY COMMENTS

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