U.S.Department of Education Staff Report
Senior Department Official on Recognition Compliance Issues
The Accrediting Council for Independent Colleges and Schools (ACICS) is a national institutional accreditor that was founded in 1912. The agency currently accredits approximately 900 campuses (245 main and 674 additional locations) in 47 states and Puerto Rico. The agency’s recognition enables its institutions to establish eligibility to receive Federal student assistance funding under Title IV of the Higher Education Act of 1965, as amended (Title IV). The agency serves as the Title IV gatekeeper for the vast majority of the institutions it accredits. Consequently, the agency must meet the Secretary’s separate and independent requirements.
The Secretary of Education first recognized ACICS in 1956 under the agency’s former name, the Accrediting Commission for Business Schools. Since that time, the Secretary periodically reviewed the agency and granted it continued recognition. In 1985, ACICS requested an expansion of scope to include the accreditation of master's degree programs. That request was subsequently granted by the Secretary. In 2006, ACICS requested an expansion of scope to accredit institutions that offer programs via distance education. That request was also subsequently granted by the Secretary.
The last full review of ACICS took place at the June 2011 meeting of the National Advisory Committee on Institutional Quality and Integrity (NACIQI). After that review the Department continued the current recognition of the agency, and required a compliance report in 12 months on the issues identified in the staff report. As a result of the agency’s review at the June 2013 NACIQI meeting, the compliance report was accepted and the agency’s recognition was renewed for the remaining period of three years.
In conjunction with the current review, Department staff reviewed the agency’s narrative and supporting documentation and conducted an observation of the agency’s decision meeting held in Washington, DC in April 2016. Since the agency’s last review, the Department had received three written complaints from students. After reviewing those complaints, it was found that ACICS had not violated its own written policies or the requirements of the Secretary’s Criteria for Recognition.
In connection with the agency’s current petition for continued recognition, however, the Department received approximately 40 written third-party comments. Since those comments have raised serious concerns regarding the accrediting activities of ACICS, they have been used to identify several of the issues listed in the “Issues or Problem” section of this analysis.
The agency meets the requirements of the Secretary's Criteria for Recognition.
Staff Analysis of 3rd Party Written Comments
Approximately 40 written third-party comments were received regarding this agency. The comments reflected negative views regarding the agency. Most of the comments are on behalf of individuals, but there were 4 comments on behalf of organizations or State entities. Most of the commenters did not tie their areas of alleged noncompliance to specific sections of the Secretary’s Criteria for Recognition.
The vast majority of comments submitted to the Department were associated with a group called the Debt Collective. In these 33 comments submitted by students, the overwhelming information provided is that the institution in which they attended misrepresented various aspects of the program to the students. In a number of cases, students expressed discontent with the quality of the instruction they received in terms of both faculty qualifications and curriculum, with the large costs associated with the program, and in regards to the processes used and information provided as they were recruited and/or admitted to the program.
As these comments appear to be complaints about specific institutions, the Department does not typically commence a review of an agency based on individual complaints unless and until a complainant exhausts the agency’s published complaint procedures. It is not clear that all of the issues raised in the comments would indicate noncompliance with the Secretary's Criteria for Recognition by the agency. However, there are areas within this analysis where the commenters’ concerns are parallel to those of the Department. The Department has noted in this analysis that it has questions related to the agency’s review of student achievement and recruiting and admissions practices in Section 602.16(a)(1).
A group of Veterans’ Organizations raised concerns regarding the default rates of the institutions that are accredited by ACICS, about the student outcome and recruiting standards of ACICS being weaker than other accrediting agencies, and the recruitment practices at various institutions accredited by ACICS that involve misrepresentations about cost and job availability. The Department has noted in this analysis that it has questions related to the agency’s review of student achievement and recruiting and admissions practices, in Section 602.16(a)(1), and the agency’s monitoring of institutions in Section 602.19(b).
A group of consumer organizations raised concerns regarding the poor track record of student achievement by ACICS institutions, that the agency relied too much upon institutional administrators in its work and lacked sufficient representation from other constituencies, that a large number ACICS-accredited institutions are under investigation, and that ACICS fails to acknowledge any necessary improvement, but rather it actively defends the success of its current work. The Department has noted in this analysis that it has questions related to the agency’s review of student achievement in Section 602.16(a)(1)(i), the agency’s wide acceptance in Section 602.13, the agency’s monitoring of institutions in Section 602.19(b), and the agency’s enforcement actions in Section 602.20.
A group of state attorney generals raised concerns that ACICS has failed to take action when improper job placement statistics are reported by an institution, that ACICS has an inadequate job placement verification processes, that ACICS demonstrates a lack of transparency and cooperation with investigations into student outcomes, that more action was needed as a result of the Corinthian Colleges investigations, and that ACICS failed repeatedly to take action in response to public enforcement actions by state and federal law enforcement. The Department has noted in this analysis that it has questions related to the agency’s review of student achievement in Section 602.16(a)(1)(i), the agency’s wide acceptance in Section 602.13, the agency’s monitoring of institutions in Section 602.19(b), and the agency’s enforcement actions in Section 602.20.
A memo from the Center for American Progress (CAP) raises similar questions from other commenters about ACICS’s standards for student placement rates, default rates, student outcomes, and recruitment standards. The request for additional information of the agency is reflected in the agency’s review of student achievement and recruiting and admissions practices, in Section 602.16(a)(1), and the agency’s monitoring of institutions in Section 602.19(b). CAP also raises concerns about the number of the lawsuits brought against ACICS. This information cited and in need of additional information is included in this analysis in the student achievement in Section 602.16(a)(1)(i), the agency’s wide acceptance in Section 602.13, the agency’s monitoring of institutions in Section 602.19(b), and the agency’s enforcement actions in Section 602.20. Note: Due to space limitations, not every single lawsuit was able to be named individually in those sections.
Agency Response to 3rd Party Written Comments
ACICS requested members of the community, including students, graduates, employers, the work-force development community and policy makers to express their opinions regarding the agency's value to them personally and to their organizations.
Staff Analysis of Agency Reponse to 3rd Party Written Comments
In response to the third party comments, ACICS asked for their stakeholders (including students, graduates, employers, the workforce development community and policymakers) to provide background regarding the value of attending/working with an ACICS accredited institution. The agency subdivided the responses into three exhibits: letters of support (Exhibit 150), employer letters (Exhibit 150-2), and letters from students (Exhibit 150-3). The letters of support include 54 testimonies from multiple parties on the experiences they have had in/related to programs that are accredited by ACICS at 15 colleges, with 34 of the 54 comments pertaining to a single institution. A number of these letters contain identical language, suggesting that they may have been part of a letter campaign. The employer letters capture 84 signatures of individuals attesting to the quality of education that a 16th institution, ITT Technical, has provided and the benefit the employers have received as a result of their relationship with that institution. However, ACICS put ITT on show cause on April 20, 2016, with a letter demonstrating that ACICS itself had serious concerns about “the institutions’ administrative capacity, organizational integrity, financial viability, and ability to serve students in a manner that complies w/ ACICS standards.” The final exhibit includes 64 letters from ITT Technical students who attended that institution and had positive experiences.
While the information provided demonstrates support by these individuals for ACICS-accredited institutions, it does not address the concerns that the draft staff report raised. The agency did not provide a narrative response to address the specific concerns relevant to the Secretary's Criteria including those previously mentioned about student outcomes and the falsification of that information (including verification of placement data), misleading recruitment and advertising practices, questions regarding Title IV responsibilities (including those about default rates), and those concerns related to lacking faculty qualifications and curriculum standards. The agency also did not give a clear indication if the issues that were brought forth through the 3rd party comment process have been considered and/or resolved through the agency's complaint standards and processes. The narrative did not specifically respond to address any of the comments, not those from individuals, nor the comments from the 19 attorneys general, nor the comments from the groups of consumer and veteran's organizations, nor from the Center for American Progress.
While not included in this section of the petition, the agency did provide documentation of their written response to the Attorney General’s letter under section 602.19(b).