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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   Puerto Rico State Agency for the Approval of Public Postsecondary Vocational, Technical Institutions and Programs (1983/2006)
                  (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.
Scope of Recognition:   State agency for the approval of public postsecondary vocational education.
4.
Date of Advisory Committee Meeting:   June, 2016
 
5.
Staff Recommendation:   Continue the agency's recognition for one year
 
6.
Issues or Problems:   The agency has no remaining compliance issues.


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Puerto Rico State Agency for the Approval of Public Postsecondary Vocational, Technical Institutions and Programs (PRSAA) is the state agency in Puerto Rico for accrediting public postsecondary vocational education programs and institutions in the Commonwealth of Puerto Rico. The agency currently accredits programs located in seven vocational technical schools located in Puerto Rico, with one institution awaiting approval.

The agency approves institutions and programs in public postsecondary institutions that are legally authorized to offer postsecondary programs that have been operating for a minimum of two years. These institutions and programs award both Associate Degrees and Certificates, and admit as regular students only individuals with a high school diploma or its equivalent or who are above the compulsory school age to attend high school, which in Puerto Rico is 16 years of age.

According to the Accreditation Group's records, the Department has received no complaints about the agency during the current recognition cycle.
 
 
Recognition History
 
The PRSAA was granted authority to approve public postsecondary vocational technical education institutions and programs in Puerto Rico in 1982 by Puerto Rico's Secretary of Education. The agency was granted initial recognition as a state approval agency by the U.S. Secretary of Education in 1983 and has received continued recognition since that time.

The agency's most recent petition for continued recognition was reviewed at the Spring 2012 NACIQI meeting. Following that meeting, the Secretary continued the agency's recognition and requested that it submit a report on its compliance with certain issues. That report was considered at the Spring 2014 NACIQI meeting, at which time the Committee granted the agency an extension of its recognition for good cause and requested an additional compliance report. The agency's second report is the subject of this analysis.



PART II: SUMMARY OF FINDINGS

 
§603.24 Criteria for State agencies
The following are the criteria which the Secretary of Education will utilize in designating a State agency as a reliable authority to assess the quality of public postsecondary vocational education in its respective State.
(A) to participate on visiting teams,

 
In the Spring 2014 staff analysis, the agency was requested to provide additional information showing that
its policies had been revised to indicate how long or how often a site visitor may serve. The agency was also requested to provide additional documentation related to the implementation of policies that had been revised related to the size of the on-site visitor pool members and the pool members' qualifications, as well as annual training schedules, training materials, and sign-in sheets showing evidence that the agency was implementing its policies related to the training of its on-site reviewers.

In response to the 2014 analysis, the agency provided a copy of the agenda from a training session, sign-in sheets for training attendees, and a copy of the slides used in the training presentation, all of which are acceptable (Exs. 1, 1a, and 1b). The agency states that additional one-on-one training is provided for team members who are unable to attend the group training session. An additional refresher session is also held for the team on the first day of the site visit.

No information or documentation was provided showing that the agency's policies had been revised to indicate how long or how often a site visitor may serve, nor was any documentation provided related to the implementation of policies that had been revised related to the size of the on-site visitor pool members and the pool members' qualifications. There were 38 names of training session attendees on the sign-in sheets. However, several of the attendees appeared to be employees of the state agency and would not be considered members of the site visitor pool. Additional information and supporting documentation are still requested related to these areas.

Please provide information related to the following areas, as well as related supporting documentation:
-- policies indicating how long and how often site visitors may serve
-- policies related to the size of the on-site visitor pool
-- policies regarding on-site visitors' required qualifications

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide additional information showing that its policies have been revised to indicate how long or how often a site visitor may serve, as well as documentation related to the implementation of policies that have been revised related to the size of the on-site visitor pool members and the pool members' qualifications.

In response to the draft staff analysis, the agency provided a copy of its policies and procedures manual, which includes detailed information on the qualification of on-site reviewers and the on-site review process (Ex. 1, pp. 9-15). The agency notes in its narrative that it has conducted an assessment of how many evaluators are needed for its institutions, in total (Ex. 4). The agency provided a copy of its current list of on-site evaluators (Ex. 3) to demonstrate that it has 145 trained reviewers in its on-site evaluation pool, which is more than ample to cover the number of reviewers who are needed. The agency also reports that its on-site reviewers may serve more than one year, but that the agency attempts to bring in new reviewers on an ongoing basis in order to have a mix of both experienced and developing evaluators.

Staff accepts the agency's response, and no additional information is requested.
 

(B) to engage in consultative services for the evaluation and approval process, and

 
In the Spring 2014 staff analysis, the agency was requested to provide additional documentation related
to its current advisory body's membership, qualifications, and training.

In response to the 2014 analysis, the agency provided a copy of its Advisory Commission Bylaws (Ex. 3). The bylaws specify that the Commission will consist of seven members and one substitute, that members will be chosen based upon their education and knowledge of technical and vocational areas, and that all members will be required to have knowledge of public policy and laws and regulations related to postsecondary education (p. 2).

The agency provided a list of the seven current Commission members (Ex. 4). Five of the members have doctorates. Educators, employers, and public members are represented. All list appropriately related work experience.

The agency also provided a copy of the training presentation used for its 2015 training of Commission members (Ex. 2). the training included information on: the agency; the HEA; duties; the bylaws; the agency's handbook; the stages of the accreditation process; the steering committee; the self-study; the on-site visit; the evaluation guidelines; credit hour policies; and recent changes. The training appeared thorough and the topics appropriate.

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

(C) to serve on decision-making bodies.

 
In the Spring 2014 staff analysis, the agency was requested to provide supporting documentation related to the selection, length of terms, and training of its Board of Examiners members.

In response to the 2014 analysis, the agency provided a copy of the bylaws pertaining to its Board of Examiners, which is its decision-making body (Ex. 5). The bylaws specify that there will be five members of the Board, who will serve two year terms. The president may serve a three year term. The members must have appropriate educational background and experience as either a professor or an administrator in an occupational/technical area, as well as knowledge of the organization, administration, and operation of educational programs. The Board will meet as needed, but at least three times per year.

The agency also provided a copy of the training presentation used for its 2015 training of Commission members, which is similar to the training provided to the agency's Commissioners (Ex. 2a). the training included information on: the agency and its staff; the HEA; duties; the bylaws; the agency's handbook; the stages of the accreditation process; the steering committee; the self-study; the on-site visit; the evaluation guidelines; credit hour policies; and recent changes. The training appeared thorough and the topics appropriate.

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

(vii) Regularly reviews its standards, policies and procedures in order that the evaluative process shall support constructive analysis, emphasize factors of critical importance, and reflect the educational and training needs of the students;

 
In the Spring 2014 staff analysis, the agency was requested to provide information and documentation as to how often it conducts regularly scheduled reviews of its standards.

In response to the 2014 analysis, the agency states in its narrative that it conducts an annual review of its standards. As documentation, the agency provided a copy of its Advisory Commission's 2015 Working Plan, which is a calendar of the topics that the Commission will be addressing, by date (Ex. 7). The plan indicates that the Commission was scheduled to review the Puerto Rico State Agency Rules and Procedure Handbook's two parts at its June and December 2015 meetings.

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

(xi) Requires each approved school or program to report on changes instituted to determine continue compliance with standards or regulations;

 
In the Spring 2014 staff analysis, the agency was requested to provide additional information and documentation regarding how it collects information from its institutions related to substantive changes.

In response to the 2014 analysis, the agency states that it designed a new substantive change form to be submitted by its accredited institutions twice a year (Ex. 6). The agency's Advisory Commission approved the form, which is being sent to the institutions. When substantive changes are identified, the agency will send staff to visit the institution and evaluate the situation and prepare a report for review by the Commission, as well as by the agency's Secretary and by ED, if necessary.

The agency states that it has not yet received or reviewed any substantive changes. As documentation, the agency provided a copy of the substantive change form. The form describes the situations that constitute a substantive change and requires a signed attestation from the institution regarding such changes.

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

(iv) Provides the chief executive officer of the institution with a specific statement of reasons for any adverse action, and notice of the right to appeal such action before an appeal body designated for that purpose;

 
In the Spring 2014 staff analysis, the agency was requested to provide documentation related to the application of its appeals policies during the course of an appeal.

In response to the 2014 analysis, the agency provided documentation in the form of a letter to an institution whose appeal had been heard and resolved (Ex. 8). However, the agency did not provide any documentation demonstrating that, prior to the resolution of the appeal, the institution's CEO had been provided a notification letter stating the reason for the adverse action, along with a statement that the institution would have the right to appeal the adverse action before an appeals body, as is required under this section. Additional information is therefore requested.

Please provide the following documentation, in the form of a notification letter to an institution's CEO, that includes the following components:
-- the reason for the adverse action
-- the right to appeal the adverse action

Analyst Remarks to Response:
In the draft staff analysis the agency was requested to provide documentation demonstrating that an institution's CEO is provided a notification letter stating the reason for any adverse action, as well as a statement that the institution has the right to appeal the adverse action before an appeals body.

In response to the draft staff analysis, the agency provided a sample of a letter to a CEO providing notification of the right to appeal an adverse action (Ex. 5).

Staff accepts the agency's response, and no additional information is requested.
 

(vi) Continues the approval status of the institution or program pending disposition of an appeal;

 
In the Spring 2014 staff analysis, the agency was requested to document that it continues the approval status of the institution or program pending disposition of an appeal and that this requirement is addressed in its procedures manual.

In response to the 2014 analysis, the agency clearly states in its narrative that an institution/program will continue to be accredited until the final appeals decision is reached. However, the agency did not provide any supporting documentation to support its narrative. Additional information is therefore requested.

Please provide the following supporting documentation:
-- a copy of the agency's policy stating that an institution's/program's accredited status continues pending the outcome of the appeals process

Analyst Remarks to Response:
In the draft staff analysis, the agency was requested to provide a copy of its policy stating that an institution's/program's accredited status continues pending the outcome of the appeals process.

In response to the draft staff analysis, the agency provided a copy of its policies and procedures manual, which clearly specifies that an institution's accredited status continues pending the outcome of the appeals process (Ex. 1, p. 34).

Staff accepts the agency's response, and no additional information is requested.
 

(vii) Furnishes the chief executive officer of the institution or program with a written decision of the appeal body including a statement of its reasons therefore.

 
In the Spring 2014 staff analysis, the agency was requested to either provide a copy of a letter detailing the reasons for an appeal decision, or to state that it had not had an appeal and therefore had no decision letter to submit as documentation.

In response to the 2014 analysis, the agency provided a copy of a notification letter to an institution following an appeal (Ex. 8). As a result of the appeal, the institution was granted continued accreditation for a period of one additional year, with certain conditions that must be met. The letter included the date that the appeal was considered, specified the additional conditions, clearly stated the period of the extension, and provided contact information in case additional information was needed by the institution.

Staff accepts the agency's 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.