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U.S. Department of Education

Staff Report
to the
Senior Department Official
on
Recognition Compliance Issues

RECOMMENDATION PAGE

1.
Agency:   American Board of Funeral Service Education (1972/2016)
                  (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:   Petition for Continued Recognition
 
3.
Current Scope of Recognition:   Scope of Recognition: The accreditation of institutions and programs within the United States awarding diplomas, associate degrees and bachelor's degrees in funeral service or mortuary science, including the accreditation of distance learning courses and programs offered by these programs and institutions.
 
4.
Requested Scope of Recognition:   Same as above.
 
5.
Date of Advisory Committee Meeting:   December, 2015
 
6.
Staff Recommendation:   Continue the agency's current recognition and require the agency to come into compliance within 12 months, and submit a compliance report 30 days after the 12 month period that demonstrates the agency's compliance with the issues identified below.
 
7.
Issues or Problems:   It does not appear that the agency meets the following sections of the Secretary’s Criteria for Recognition. These issues are summarized below and discussed in detail under the Summary of Findings section.

-- The agency must provide documentation demonstrating that decision making entities and evaluation teams consistently sign conflict of interest forms to ensure they understand the agency's conflict of interest policy.

[§602.15(a)(6)]

-- The agency must evaluate its definition of ‘deviate significantly’ to clearly communicate to institutions and programs regarding their compliance or noncompliance with the agency's standards, and for ensuring consistency in decision making. [§602.20(b)]

-- The agency does not meet the standards of this section. In addition to being unclear about how clock hours are defined for the agency, the agency should also demonstrate that they have trained reviewers for ensuring that this definition is being appropriately reviewed. [§602.24(f)(2)]



EXECUTIVE SUMMARY

 
 

PART I: GENERAL INFORMATION ABOUT THE AGENCY

 
The American Board of Funeral Service Education (ABFSE), Committee on Accreditation (COA), is a national specialized accrediting agency. Its current scope of recognition is the accreditation of institutions and programs awarding diplomas, associate degrees and bachelor’s degrees in funeral service or mortuary science. ABFSE is, therefore, both an institutional and programmatic accreditor.

ABFSE currently accredits approximately 58 programs in 38 states and the District of Columbia. ABFSE also accredits 11 single purpose institutions, two of which also have regional accreditation. However, it serves as the Title IV gatekeeper, of eight institutions enabling them to establish eligibility to participate in the Title IV student financial aid programs. As such, it must meet the separate and independent requirements as set forth in the Secretary’s Criteria for Recognition or seek a waiver. The agency has not had any complaints submitted to the Department since its last review.
 
 
Recognition History
 
At the NACIQI’s May 2007 meeting the agency petitioned for continued recognition and an expansion of its scope of recognition to include distance education. At that meeting the NACIQI recommended that the Secretary defer a decision on continued recognition for a period of one year, but did not make a specific recommendation regarding the agency's request for an expansion of its scope of recognition. The agency accepted the NACIQI’s recommendation to defer its recognition for a year. However, it appealed and requested the Secretary to grant its request to expand its current scope of recognition to include distance education courses and programs. In November 2007, the Secretary granted the agency’s appeal to have distance education included in its current scope of recognition and required the agency to submit an interim report by March 2008. addressing the following issues:

At the NACIQI's June 2008 meeting the agency presented its interim report and supporting documentation. Both the Department and the NACIQI recommended that the agency's recognition be renewed for a period of four years. The Secretary had not made a final decision prior to passage of the Higher Education Opportunity Act, which contained a number of provisions related to accrediting agency recognition that were effective upon enactment. Subsequently, new regulations were developed, effective July 1, 2010. As a consequence, the agency was required to submit an updated petition for review by staff and NACIQI. At its December 2012 meeting the NACIQI recommended to continue the agency's recognition and require it to come back in three years for it's renewal petition. The renewal of the agency's recognition is the subject of this analysis. Department Staff observed a site team visit in October 2015.








PART II: SUMMARY OF FINDINGS

 
§602.15 Administrative and fiscal responsibilities
(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

 
The agency has provided documentation of its policies related to conflict of interest (both real and perceived) in its Accreditation and Policy manual. They have provided a copy of the Conflict of Interest statement that is signed by its committee members, staff, site team members and other agency representatives. They have also provided a copy of its minutes demonstrating it application during meetings. However, no signed documents were included in this response and therefore, it is unclear to Department Staff that the reported parties have signed these statements or understand the agencies conflict of interest policy.

Analyst Remarks to Response:
In response to the draft staff analysis the agency provided documentation demonstrating its application of its conflict of interest policies and procedures. The documentation includes signed conflict of interest statements from its commission members and site evaluation team. There were no conflict of interest statements for its appeals panel members. The agency states in their narrative, they realized that as a result of this review, that the conflict of interest forms were not being utilized consistently for site team members. The agency does have a policy, paperwork for capturing the signatures, and some examples of its application included in Exhibit 75 (that does include signatures of the site visit chair and two site visitors). Department Staff interprets this to mean that while the policy and paperwork processes exist, the signing of conflict of interest forms have not always been consistently utilized by site team visitors. The agency must provide additional documentation demonstrating that on a consistent basis members of its evaluation teams read and sign conflict of interest statements indicating they understand the agency’s conflict of interest policy.
 

§602.20 Enforcement of standards
(b) If the institution or program does not bring itself into compliance within the specified period, the agency must take immediate adverse action unless the agency, for good cause, extends the period for achieving compliance.

 
The agency’s policy for enforcement actions is established in its Accreditation and Policy Manual. Specifically, the policy stipulates that when an institution or program fails to bring itself into compliance with its standards which include responding to an imposed warning, or fails to submit funds due, it will be placed on probation until such time as appropriate corrective action is taken by the program. The policy does require the agency to take immediate adverse action or allow the institution or program time to demonstrate compliance within the timelines established in 602.20 (a). The issue is the agency term "deviating significantly." Department staff is unclear regarding the meaning of this term as it relates to compliance or non-compliance with its standards.

Analyst Remarks to Response:
In response to the draft staff analysis the agency concurred with the Department that its own language may not be clear enough to make a distinction on what ‘deviate significantly’ means, in regards to an adverse action. The agency has agreed to evaluate this definition at its April 2016 meeting. However, until this term is more clearly defined the agency cannot be found in compliance at this time.


 

§602.24 Additional procedures certain institutional accreditors must have.
(2) In reviewing and evaluating an institution's policies and procedures for determining credit hour assignments, an accrediting agency may use sampling or other methods in evaluation, sufficient to comply with paragraph (f)(1)(i)(B) of this section.

 
The agency provided documentation in its Accreditation and Policy manual that addresses credit hour policies and a self-study to show that this information is included in the institution or program's regular review for accreditation. In addition, in the 2014 annual report there are questions provided that address credit hour methods used. The site team evaluates the information submitted and confirms the accuracy of the information provided. However, the Department staff is unclear if the review of this information is accordance with the Department’s definition of a clock hour.


Analyst Remarks to Response:
The agency provided additional documentation that shows a review of information related to clock hours is regularly included in the institution or program's regular review for accreditation at all stages of the comprehensive review. However, it still remains unclear if the review of this information is in accordance with the Department’s definition of a clock hour. The agency has stated that they plan to further articulate this review is based on the Department's definition. However, until this information is further articulated, the agency can not be found compliant in this section.
 
 

PART III: THIRD PARTY COMMENTS

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