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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   WASC Accrediting Commission For Senior Colleges and Universities (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 and preaccreditation (“Candidate for Accreditation”) of senior colleges and universities in California, Hawaii, the United States territories of Guam and American Samoa, the Republic of Palau, the Federated States of Micronesia, the Commonwealth of the Northern Mariana Islands and the Republic of the Marshall Islands, including distance education programs offered at those institutions.
 
4.
Requested Scope of Recognition:   The agency is not requesting any changes to its scope of recognition.
 
5.
Date of Advisory Committee Meeting:   December, 2014
 
6.
Staff Recommendation:   Renew the agency's recognition for a period of three years
 
7.
Issues or Problems:   None.


EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The Accrediting Commission for Senior Colleges and Universities (WASC-Sr.) is one of three accrediting commissions that comprise the Western Association of Schools and Colleges (WASC). The agency is recognized as the regional accrediting body for the accreditation and preaccreditation of senior colleges and universities in California, Hawaii, the United States territories of Guam and American Samoa, the Republic of Palau, the Federated States of Micronesia, the Commonwealth of the Northern Mariana Islands, and the Republic of the Marshall Islands.

WASC-Sr. currently accredits 161 institutions located throughout its region. Accreditation by the agency enables those institutions to establish eligibility to participate in the Title IV student financial aid programs. The agency is a Title IV gatekeeper and meets the definition of separate and independent as required in the Secretary’s Criteria for Recognition.
 
 
Recognition History
 
The U.S. Commissioner of Education listed the Western Association of Schools and Colleges, Accrediting Commission for Senior Colleges and Universities on the initial list of recognized accrediting agencies in 1952. After establishing a successor in 1962, the Secretary has periodically continued to recognize this agency.

The NACIQI considered the agency’s last full petition for renewal of recognition at its Fall 2012 meeting. At that time, the Secretary continued the agency's grant of recognition and requested a report on a number of outstanding compliance issues. That report is the subject of the current analysis.


PART II: SUMMARY OF FINDINGS

 
§602.14 Purpose and organization
(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 Fall 2012 staff analysis, the agency was requested to provide information and documentation
regarding the changes it was currently making to its organizational structure. It was also requested to revise its bylaws to ensure the required ratio of one public member for every seven members going forward.

In response to the 2012 staff concerns, the agency submitted extensive documentation related to its recent reorganization. The Western Association of Schools and Colleges Senior College and University Commission (which is generally referred to by ED as WASC-Sr., but is also referred to in the agency's documentation as ACSCU) was formally separated from the WASC parent organization as of May 31, 2013 (Ex. 1). The document expressly states that the WASC parent group will have no control over the governance of WASC-Sr. (Ex. 1, p. 2).

The WASC-Sr. bylaws state that commissioners will be nominated by a nominating committee and voted upon by the presidents of the agency's accredited institutions (Ex. 2, Article IV, Section 4). At least 1/7 of the commission, or three members, which ever is greater, will be public members (Ex. 2, Article IV, Section 3). The agency submitted a list of its 24 current commissioners, as well as a list of its four current public members. This number satisfies the required 7:1 commissioner to public member ratio (Exs. 5, 6).
Commissioners will be subject to the agency's conflict of interest policies, and their conflict of interest statements will be reviewed by the agency's executive committee (Ex. 2, Article V, Section 4). The agency submitted a copy of its conflict of interest policy, as well as a sample conflict of interest form (Exs. 7, 8).

Dues to support the agency are paid by its accredited institutions. The agency submitted a sample invoice to demonstrate how its dues are collected (Ex. 9). The agency will have its own finance committee, which will make recommendations regarding all aspects of the agency's finances and budget (Ex. 2, Article V, Section 7). The agency provided a copy of its finance committee charter, which indicates that the committee will have oversight of the agency's finances (Ex. 10).

Staff accepts the agency's response and supporting documentation related to the requirements of this section, and no further information is requested.
 

§602.15 Administrative and fiscal responsibilities
(2) Competent and knowledgeable individuals, qualified by education and experience in their own right and trained by the agency on their responsibilities, as appropriate for their roles, regarding the agency's standards, policies, and procedures, to conduct its on-site evaluations, apply or establish its policies, and make its accrediting and preaccrediting decisions, including, if applicable to the agency's scope, their responsibilities regarding distance education and correspondence education;

 
In the Fall 2012 staff analysis, the agency was requested to provide additional documentation
regarding the qualifications of its pool of on-site reviewers. It was also requested to provide additional documentation as to how the appeals panel members are trained, as well as the qualifications of the appeals panel's public member(s).

Evaluators
In response to concerns raised in the 2012 analysis, the agency submitted several sample evaluator biographies (Ex. 11). These demonstrate the type of detailed information that the agency maintains on its evaluators and includes information on areas of expertise, academic disciplines, WASC schools visited in the past, educational background, institutional experience, other evaluator experience, foreign language fluency, evaluator training, evaluation areas, and committee membership.

Appeals panel members
The agency provided a copy of its appeals policy (Ex. 13). The agency provided a list of the appeals panel nominees, including public members (Exs. 14, 15). The nominees appear appropriately qualified to serve appeals panels. The agency also provided information from a web-based training session that was developed for its appeals panel members (Ex. 17). The training session covered the definition of an appeal, adverse actions, grounds for appeals, purpose of the appeals panel, conflicts of interest, legal counsel, required institutional evidence, documentation, new financial information, hearing procedures, appeals panel decisions, confidentiality, and the appeals panel policies.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(3) Academic and administrative personnel on its evaluation, policy, and decision-making bodies, if the agency accredits institutions;

 
In the Fall 2012 staff analysis, the agency was requested to address the requirements of this section regarding composition of appeals panels.

In response to concerns raised in the 2012 analysis, the agency provided a copy of its revised institutional appeals policy (Ex. 13). The policy appropriately defines both academic and administrative representatives to its appeals panels. The agency also provided a list of its appeals panel member pool, including brief biographies (Ex. 19). The members include two public members, four administrative members, and three academic members, and all pool members appear appropriately qualified to serve in their respective categories.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(5) Representatives of the public on all decision-making bodies; and

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation of its written policy
in this area, as well as evidence that its appeals panels include a public representative who meets the Secretary’s definition.

In response to the concerns raised in the 2012 analysis, the agency provided a copy of its revised appeals policy (Ex. 13). The policy appropriately defines public representatives to the agency's appeals panels. The agency also provided a list of its appeals panel members, which documents that its appeals panel pool includes two public members (Ex. 19). The list includes brief biographies of the appeals panel members, and the public members appear appropriately qualified to serve on the agency's panels. The agency also provided affidavits in which the public appeals panel pool members attest to their compliance with the agency's definition of a public member (Ex. 20).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(6) Clear and effective controls against conflicts of interest, or the appearance of conflicts of interest, by the agency's--
(i) Board members;

(ii) Commissioners;

(iii) Evaluation team members;

(iv) Consultants;

(v) Administrative staff; and

(vi) Other agency representatives; and

 
In the Fall 2012 staff analysis, the agency was requested to provide information and documentation of how its new appeals process meets the requirements of this section.

The agency provided a copy of its recently revised conflict of interest policy, which covers all of the groups required by this section (Ex. 7). The agency also provided sample signed conflict of interest forms for the required groups to document that it collects this information, as required (Ex. 21).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.16 Accreditation and preaccreditation standards
(a)(1)(ix) Record of student complaints received by, or available to, the agency.

 
In the Fall 2012 staff analysis, the agency was requested to revise its on-site review procedures in
order to ensure it reviews all of the complaints it requires its institutions to maintain to identify a pattern of complaints over an extended period of time.

In response to concerns raised in the 2012 analysis, the agency revised its complaints policy for how student complaints are reviewed during the course of on-site reviews. The revised policy states that complaints must be maintained for a period of at least six years (Ex. 27, p. 1). The agency has developed a complaints checklist for on-site teams to use during the review process. The agency provided a sample copy of a completed checklist (Ex. 28). The checklist requires the reviewers to verify that the institution has a complaint policy, has a procedure for addressing student complaints, and maintains, monitors, and tracks complaints.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(a)(1)(vii) Recruiting and admissions practices, academic calendars, catalogs, publications, grading, and advertising.
 
In the Fall 2012 staff analysis, the agency was requested to provide documentation that makes clear on what basis the team and the commission make a compliance determination regarding the agency's recruiting and other practices standard. The agency was also requested to provide evidence that its confidential email solicitation yields information relevant to the agency’s standards/guideline in this area.

In response to the 2012 analysis, the agency provided documentation of its review of its standard related to recruitment and other practices. A team report includes an appendix that the agency has added related to this requirement in which the team notes the materials reviewed answers specific questions related to this area (Ex. 23, Appendix E).

Regarding its email solicitation efforts that take place as a part of its on-site review process, the agency provided documentation of its standards review process in which the sources of feedback related to standards revision were supplied (Ex. 24).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(a)(1)(viii) Measures of program length and the objectives of the degrees or credentials offered.
 
In the Fall 2012 staff analysis, the agency was requested to provide information on how the information provided by an institution is reviewed to make a compliance determination regarding the agency's program length standard.

In response to the concerns raised in the 2012 analysis, the agency reports that its on-site review teams evaluate program length by using the agency's credit hour and program length checklist. The agency provided a copy of a completed team report that addressed credit hour and program length review (Ex. 26). The report provided federal definitions and required the team to answer questions and provide comments related to this area, as well as to list the documents that it reviewed.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(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
 
In the Fall 2012 staff analysis, the agency was requested to provide information and documentation as
to how its Title IV Compliance Policy is enforced.

In response to concerns raised in the 2012 analysis, the agency revised the way it reviews Title IV information. Institutions must submit information regarding cohort default rates and federal student aid composite scores with their annual reports for review by agency staff. As documentation, the agency provided sample copies of letters to institutions regarding the required information (Exs. 33, 34, 35, 36). It also submitted a copy of the report it develops on an annual basis that shows which of its accredited institutions have default rates above seven percent (Ex. 37). Institutions must describe the steps that they are taking to address their default rates, and this information becomes part of the institutional record.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(b) If the agency only accredits programs and does not serve as an institutional accrediting agency for any of those programs, its accreditation standards must address the areas in paragraph (a)(1) of this section in terms of the type and level of the program rather than in terms of the institution.


(c) If the agency has or seeks to include within its scope of recognition the evaluation of the quality of institutions or programs offering distance education or correspondence education, the agency's standards must effectively address the quality of an institution's distance education or correspondence education in the areas identified in paragraph (a)(1) of this section. The agency is not required to have separate standards, procedures, or policies for the evaluation of distance education or correspondence education;


 
In the Fall 2012 staff analysis, the agency was requested to revise its materials to remove references
to correspondence education and to ensure the consistent use of terminology related to distance education and to provide documentation of the changes.

In response to concerns raised in the 2012 analysis, the agency revised its documents to remove the outdated references to correspondence education, as requested (Exs, 38, 39, 40).

Staff accepts the agency's revised documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.17 Application of standards in reaching an accrediting decision.
The agency must have effective mechanisms for evaluating an institution's or program's compliance with the agency's standards before reaching a decision to accredit or preaccredit the institution or program. The agency meets this requirement if the agency demonstrates that it--
(d) Allows the institution or program the opportunity to respond in writing to the report of the on-site review;

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation that institutions are
provided the opportunity, within a reasonable amount of time, to review the draft on-site review teams' reports in order to correct factual errors.

In response to concerns raised in the 2012 analysis, the agency provided additional documentation to demonstrate that institutions are provided an opportunity to review draft on-site review reports in order to correct factual errors. The documentation includes timelines for team chairs that include the provision that institutions will be able to correct factual errors, emails from team chairs to institutions stating that corrections may be made, and responses from institutions containing corrections (Exs. 41, 42, 43, 44, 45).

Staff accepts the agency's additional documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.19 Monitoring and reevaluation of accredited institutions and programs.
(a) The agency must reevaluate, at regularly established intervals, the institutions or programs it has accredited or preaccredited.

 
In the Fall 2012 staff analysis, the agency was requested to provide a copy of its comprehensive
review calendar as documentation that it is implementing its published ten-year review cycle.

In response to the concerns raised in the 2012 analysis, the agency provided the additional documentation, as requested. The agency provided a copy of its master review calendar, which documents that the agency is implementing its published ten-year review cycle (Ex. 46). It also provided additional documentation showing its ongoing monitoring of institutions that exceeded the ten-year cycle, indicating why the ten-year limit was exceeded (Ex. 47).

Staff accepts the agency's documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(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.


 
In the Fall 2012 staff analysis, the agency was requested to devise and implement a method for periodically collecting and analyzing information related to measures of student achievement, as required under this section. It was also requested to provide documentation of its effective application of its policies and procedures in this area.

In response to concerns raised in the 2012 analysis, the agency is implementing a new mid-cycle review to serve as an update on progress on collecting information related to student learning, provide data on retention and graduation rates, and provide trend information related to annual reports. The agency will begin conducting the additional reviews in 2014. The agency provided information from its web site in which it informs institutions about the new review process (Ex. 50). The agency provided a copy of its database showing when institutions will be required to undergo the new reviews (Ex. 52). It provided sample letters to institutions regarding the new review process (Exs. 53, 54, 55). It provided information related to one institution showing the institution's upcoming schedule of reviews, to include the new mid-cycle review (Ex. 56). It provided an example of the information that institutions must report on an annual basis, to include the required indicators related to student achievement (Ex. 57).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(c) Each agency must monitor overall growth of the institutions or programs it accredits and, at least annually, collect headcount enrollment data from those institutions or programs.


 
In the Fall 2012 staff analysis, the agency was requested to provide additional information regarding
monitoring of growth and any requirements for institutions to provide annual headcounts of students.

In response to concerns raised in the 2012 analysis, the agency reports that it collects information related to headcounts via its annual reports and uses this information to monitor growth. The agency reports that it has had no institutions that have had a 20% or more increase during the four years that it has been collecting this information. As documentation, the agency provided a copy of its annual reporting elements (Ex. 57), as well as samples of enrollment data from two of its accredited institutions (Exs. 58, 59).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


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


 
In the Fall 2012 staff analysis, the agency was requested to provide additional information and
documentation as to how it is collecting headcount information and monitoring significant growth.

As was noted under 602.19(b), the agency collects information related to headcounts and significant growth via its annual reports. As noted previously, the agency has not yet had an institution that has had a 20% or greater increase in enrollment, so has no additional documentation to provide related to this section.

Staff accepts the agency's response as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§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.

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation that it is enforcing
the two-year enforcement timelines specified in this section.

In response to the concerns raised in the 2012 analysis, the agency provided additional supporting documentation, as had been requested. The agency provided sample letters to institutions that demonstrate that it is enforcing the two-year timeline specified in this section (Exs. 60, 61, 63, 64, 65).

Staff accepts the agency's supplemental documentation as evidence of its compliance with the requirements of this section, and no additional documentation is requested.
 

§602.21 Review of standards.

(a) The agency must maintain a systematic program of review that demonstrates that its standards are adequate to evaluate the quality of the education or training provided by the institutions and programs it accredits and relevant to the educational or training needs of students.


(b) The agency determines the specific procedures it follows in evaluating its standards, but the agency must ensure that its program of review--

(1) Is comprehensive;

(2) Occurs at regular, yet reasonable, intervals or on an ongoing basis;

(3) Examines each of the agency's standards and the standards as a whole; and

(4) Involves all of the agency's relevant constituencies in the review and affords them a meaningful opportunity to provide input into the review.

 
In the Fall 2012 staff analysis, the agency was requested to provide information about its comprehensive review of standards, including the solicitation of feedback. The agency was also requested to provide information as to when its next scheduled comprehensive standards review process is scheduled to begin.

In response to concerns raised in the 2012 staff analysis the agency provided additional information and documentation regarding its standards review process. The agency is on a ten-year standards review cycle. The agency's most recent review of standards was begun in 2010, and the standards went into effect in 2013. The agency reports that the next review cycle will begin no later than in 2021. The agency provided extensive documentation regarding the solicitation of feedback throughout its region during the most recent standards review cycle (Exs. 66A thru 66V). The documentation indicates that ample opportunity was provided for interested parties to provide comment.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(c) If the agency determines, at any point during its systematic program of review, that it needs to make changes to its standards, the agency must initiate action within 12 months to make the changes and must complete that action within a reasonable period of time. Before finalizing any changes to its standards, the agency must--

(1) Provide notice to all of the agency's relevant constituencies, and other parties who have made their interest known to the agency, of the changes the agency proposes to make;

(2) Give the constituencies and other interested parties adequate opportunity to comment on the proposed changes; and

(3) Take into account any comments on the proposed changes submitted timely by the relevant constituencies and by other interested parties.

 
In the Fall 2012 staff analysis, the agency was requested to document that its standards revision
process is specified in its policies and procedures, including the requirement that it obtain input from all of its constituencies and interested parties, that it initiate action within 12 months to make changes to its standards, and that it complete that action within a reasonable period of time.

In response to concerns raised in the 2012 analysis, the agency revised its standards review policy (Ex. 67). The revised policy states that if the agency determines that it needs to make changes to its standards during its standards review process, it will initiate action within 12 months to make the changes. The policy also states that standards review will be undertaken with notice given to institutions and other relevant constituencies and that ample opportunity will be provided to comment on any proposed changes. As noted in a previous section, the agency's next comprehensive standards review process will take place by 2021. Therefore, the agency has no additional documentation to provide related to its revised policy.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.22 Substantive change.
(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.

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation of its application of its policy regarding review of institutions experience rapid growth in the number of additional locations, or indicate it has not had an opportunity to do so.

In response to the concerns raised in the 2012 analysis, the agency notes that it has not had any institutions that have experienced rapid growth in the number of additional locations and therefore has no additional documentation to provide.

Staff accepts the agency's response as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.23 Operating procedures all agencies must have.
(a) The agency must maintain and make available to the public written materials describing--

(1) Each type of accreditation and preaccreditation it grants;

(2) The procedures that institutions or programs must follow in applying for accreditation or preaccreditation;

(3) The standards and procedures it uses to determine whether to grant, reaffirm, reinstate, restrict, deny, revoke, terminate, or take any other action related to each type of accreditation and preaccreditation that the agency grants;

(4) The institutions and programs that the agency currently accredits or preaccredits and, for each institution and program, the year the agency will next review or reconsider it for accreditation or preaccreditation; and

(5) The names, academic and professional qualifications, and relevant employment and organizational affiliations of--
(i) The members of the agency's policy and decision-making bodies; and

(ii) The agency's principal administrative staff.

 
In the Fall 2012 staff analysis, the agency was requested to address its compliance with the
requirements of this section, as it pertains to providing public information regarding its staff appeals panel pool members.

In response to concerns raised in the 2012 analysis, the agency notes that the required information is available via its web site. ED staff verified that the required information is available via the web, as stated by the agency (Ex. 16).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.24 Additional procedures certain institutional accreditors must have.
(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.

 
In the Fall 2012 staff analysis, the agency was requested to further revise its policies to reflect the
requirements of this section. In addition, the agency needed to provide documentation of its evaluation of a teach-out plan, or to indicate it has not had an opportunity to evaluate a plan under its revised policies.

In response to concerns raised in the 2012 analysis, the agency revised its teach-out plan policy. The revised policy specifies that teach-out plans must "provide for the equitable treatment of students by ensuring that the institution has the necessary experience, resources, and support services to provide an educational program that is of acceptable quality and reasonably similar in content, structure, and scheduling, and to meet all obligations to its existing students" (Ex. 68). The agency states that it has not yet had an opportunity to enforce its revised policy and therefore has no supporting documentation to provide.

Staff accepts the agency's response and documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(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.")

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation demonstrating that
it reviews an institution’s compliance with its revised transfer of credit policy.

In response to concerns raised in the 2012 analysis, the agency provided additional documentation of its review of institutions' compliance with the agency's transfer of credit policy. A sample completed on-site review report documents that the review evaluated the institution's policy on transfer of credit (Ex. 23, p. 37).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.25 Due process
(f) Provides an opportunity, upon written request of an institution or program, for the institution or program to appeal any adverse action prior to the action becoming final.
(1) The appeal must take place at a hearing before an appeals panel that--
(i) May not include current members of the agency's decision-making body that took the initial adverse action;

(ii) Is subject to a conflict of interest policy;

(iii) Does not serve only an advisory or procedural role, and has and uses the authority to make the following decisions: to affirm, amend, or reverse adverse actions of the original decision-making body; and

(iv) Affirms, amends, reverses, or remands the adverse action. A decision to affirm, amend, or reverse the adverse action is implemented by the appeals panel or by the original decision-making body, at the agency's option. In a decision to remand the adverse action to the original decision-making body for further consideration, the appeals panel must identify specific issues that the original decision-making body must address. In a decision that is implemented by or remanded to the original decision-making body, that body must act in a manner consistent with the appeals panel's decisions or instructions.
(2) The agency must recognize the right of the institution or program to employ counsel to represent the institution or program during its appeal, including to make any presentation that the agency permits the institution or program to make on its own during the appeal.

 
In the Fall 2012 staff analysis, the agency was requested to provide additional information on the
requirements of this section.

In response to concerns raised in the 2012 analysis, the agency revised its institutional appeals policy (Ex. 13). As noted in the agency's narrative, the revised policy reflects all of the requirements contained within this section. The agency notes that it has not had an institutional appeal under its revised policy and therefore has no additional documentation to provide.

Staff accepts the agency's response and its revised policy as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(h)(1) The agency must provide for a process, in accordance with written procedures, through which an institution or program may, before the agency reaches a final adverse action decision, seek review of new financial information if all of the following conditions are met:
(i) The financial information was unavailable to the institution or program until after the decision subject to appeal was made.

(ii) The financial information is significant and bears materially on the financial deficiencies identified by the agency.

(iii) The only remaining deficiency cited by the agency in support of a final adverse action decision is the institution's or program's failure to meet an agency standard pertaining to finances.
(h)(2) An institution or program may seek the review of new financial information described in paragraph (h)(1) of this section only once and any determination by the agency made with respect to that review does not provide a basis for an appeal.

 
In the Fall 2012 staff analysis, the agency was requested to provide additional information about its
compliance with the requirements of this section.

In response to concerns raised in the 2012 analysis, the agency revised its institutional appeals policy. As was noted in the previous section, the revised policy addresses all of the federal requirements, including the requirements related to new financial information as contained under this section (Ex. 13, p. 6). As was noted previously, the agency has had no institutional appeals under its new policy and therefore has no additional documentation to provide.

Staff accepts the agency's response and revised policy as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.26 Notification of accrediting decisions

The agency must demonstrate that it has established and follows written procedures requiring it to provide written notice of its accrediting decisions to the Secretary, the appropriate State licensing or authorizing agency, the appropriate accrediting agencies, and the public. The agency meets this requirement if the agency, following its written procedures--


(a) Provides written notice of the following types of decisions to the Secretary, the appropriate State licensing or authorizing agency, the appropriate accrediting agencies, and the public no later than 30 days after it makes the decision:

(1) A decision to award initial accreditation or preaccreditation to an institution or program.

(2) A decision to renew an institution's or program's accreditation or preaccreditation;

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation of its timely
notification to the relevant entities to demonstrate effective application of its policy.

In response to the concerns raised in the 2012 analysis, the agency provided a copy of its Public Disclosure of Accreditation Documents and Actions Policy (Ex. 69, p. 3). The policy states that public notification of the federally specified positive decisions will be made no later than 30 days after the decision has been reached. As documentation of such notifications, the agency provided examples of notifications it has provided to ED, as well as samples of announcements made available via its web site.

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(b) Provides written notice of the following types of decisions to the Secretary, the appropriate State licensing or authorizing agency, and the appropriate accrediting agencies at the same time it notifies the institution or program of the decision, but no later than 30 days after it reaches the decision:

(1) A final decision to place an institution or program on probation or an equivalent status.

(2) A final decision to deny, withdraw, suspend, revoke, or terminate the accreditation or preaccreditation of an institution or program;

(3) A final decision to take any other adverse action, as defined by the agency, not listed in paragraph (b)(2) of this section;

 
In the Fall 2012 staff analysis, the agency was requested to further revise its policies to meet the
requirements of this section and to provide documentation of its timely notification to all listed entities.

In response to the concerns raised in the 2012 analysis, the agency revised its Public Disclosure of Accreditation Documents and Actions Policy to specify that notification of negative actions will be given to an institution at the same time that ED and relevant accrediting agencies are notified (Ex. 69, p. 3). The agency notes that it has not yet had an occasion to implement its revised policy and therefore has no additional documentation to provide.

Staff accepts the agency's response and revised policy as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

(d) For any decision listed in paragraph (b)(2) of this section, makes available to the Secretary, the appropriate State licensing or authorizing agency, and the public, no later than 60 days after the decision, a brief statement summarizing the reasons for the agency's decision and the official comments that the affected institu­tion or program may wish to make with regard to that decision, or evidence that the affected institution has been offered the opportunity to provide official comment; and
 
In the Fall 2012 staff analysis, the agency was requested to provide documentation of its application of
its revised policy regarding the requirement to provide a brief summary within 60 days.

In response to concerns raised in the 2012 analysis, the agency provided additional documentation of the implementation of its revised policy, as had been requested. The agency provided a sample of an email to interested parties, including ED staff, providing a brief summary of accrediting actions (Exs. 73, 74). It also provided information from public statements made via its web page (Exs. 75, 76).

Staff accepts the agency's response and supporting documentation as evidence of its compliance with the requirements of this section, and no additional information is requested.
 


(e) Notifies the Secretary, the appropriate State licensing or authorizing agency, the appropriate accrediting agencies, and, upon request, the public if an accredited or preaccredited institution or program--

(1) Decides to withdraw voluntarily from accreditation or preaccreditation, within 30 days of receiving notification from the institution or program that it is withdrawing voluntarily from accreditation or preaccreditation; or

(2) Lets its accreditation or preaccreditation lapse, within 30 days of the date on which accreditation or preaccreditation lapses.

 
In the Fall 2012 staff analysis, the agency was requested to provide documentation of the application
of its revised policy related to notification of voluntary withdrawal.

In response to concerns raised in the 2012 analysis, the agency revised its Public Disclosure of Accreditation Documents and Actions Policy (Ex. 69, page 4). The policy specifies that within 30 days the agency will send email notification of voluntary withdrawal to ED and relevant accrediting agencies, as well as posting the information on its web site for the public and other governmental agencies. The agency notes that it has not had an occasion to implement its revised policy and therefore has no supporting documentation to provide.

Staff accepts the agency's response and revised policy as evidence of its compliance with the requirements of this section, and no additional information is requested.
 

§602.28 Regard for decisions of States and other accrediting agencies.
(e) The agency must, upon request, share with other appropriate recognized accrediting agencies and recognized State approval agencies information about the accreditation or preaccreditation status of an institution or program and any adverse actions it has taken against an accredited or preaccredited institution or program.

 
In the Fall 2012 staff analysis, the agency was requested to amend its bylaws to be consistent with its revised policy on information-sharing with other accrediting/approval bodies and the requirements of this section of the criteria.

In response to concerns raised in the 2012 analysis the agency revised its bylaws to remove references to information sharing and developed a policy on Sharing of Accreditation Information with Other Agencies (Ex. 77). The policy states that the agency will routinely share information about the pre-accreditation status of an institution or adverse actions it has taken with other accrediting agencies and state agencies.

Staff accepts the agency's response and newly adopted policy as evidence of its compliance with the requirements of this section, and no additional information is requested.
 
 

PART III: THIRD PARTY COMMENTS

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