U.S.Department of Education Staff Report
Senior Department Official on Recognition Compliance Issues
The Middle States Commission on Secondary Schools (MS-CSS) is one of three Commissions of the Middle States Association of Colleges and Schools. Primarily an accreditor of secondary education institutions, the agency also accredits postsecondary, non-degree granting vocational institutions. These postsecondary education institutions provide training in vocational/technical careers within certificated and licensed professions such as automotive technology, computer networking, cosmetology and practical nursing.
The agency’s current scope of recognition is for the accreditation of institutions with postsecondary, non-degree granting career and technology programs in Delaware, Maryland, New Jersey, New York, Pennsylvania, the Commonwealth of Puerto Rico, the District of Columbia, and the U.S. Virgin Islands, including those that offer all or part of their educational programs via distance education modalities.
The agency’s federal link is the Higher Education Act, Title IV federal student aid program. Therefore, the agency must meet the Secretary’s separate and independent requirements.
Currently, the agency accredits fifteen postsecondary non-degree-granting institutions that use its accreditation to establish eligibility for Title IV federal student aid programs.
The Middle States Commission on Secondary Schools was established in 1920. It was first recognized by the Secretary for the accreditation of public vocational-technical schools offering non-degree postsecondary education in 1988 and remained a recognized agency until July 1999 when it requested that its recognition be withdrawn.
The agency submitted a petition again for initial recognition in December 2003, and in 2004 the National Advisory Committee on Institutional Quality and Integrity recommended and the Secretary concurred that the agency be recognized for a two-year period but required it to submit an interim report at its Fall 2006 meeting demonstrating compliance with the issues identified in the staff analysis.
In December 2006, The National Advisory Committee on Institutional Quality and Integrity reviewed and recommended that the Secretary accept the agency's report.
The agency submitted a petition again for continued recognition in June 2012 and the National Advisory Committee on Institutional Quality and Integrity recommended and the Secretary concurred that the agency's recognition continue and that it demonstrate compliance with a number of the Secretary's Criteria for Recognition. The issues fell primarily in the areas of required standards and their application, and required operating policies and procedures. Most of the citations in these areas are due to the lack of documentation demonstrating the application of specific policies or procedures, which is necessary for compliance, and the agency's amendments or revisions to its policies and procedures to meet the requirements resulting from the HEA amendments in 2010.
At its June 2014 meeting, The National Advisory Committee on Institutional Quality and Integrity reviewed and recommended that the Secretary accept the agency's report.
In June 2017 the National Advisory Committee on Institutional Quality and Integrity reviewed the agency's petition for continued recognition and recommended and the Secretary concurred that the agency's recognition be continued. It also requested that the Commission submit an interim report to demonstrate compliance with issues identified in the staff analysis. That report is the subject of this analysis. .
602.15 Administrative and fiscal responsibilities
The agency must have the administrative and fiscal capability to carry out its accreditation activities in light of its requested scope of recognition. The agency meets this requirement if the agency demonstrates that--
(a) The agency has--
(1) Adequate administrative staff and financial resources to carry out its accrediting responsibilities;
During the MSACSS last review the Department staff determined that the agency must demonstrate that it has a clearly defined organizational structure and that its staffing is adequate to support its accreditation activities. The agency must also demonstrate that its operations are sustained through income generated from fees and services from accredited institutions, and that its budget and audited financial statements document its financial operations and indicate the agency's ability to conduct all of its accrediting responsibilities.
In response to the Department's request the agency provided evidence of a clearly defined organizational structure (Exhibit 1 Sec 3 Exhibit d.1 MSCSS.docx) which is attached, and documentation that defines the relative duties and reporting relationships of each of the staff ((MSA-CESS Staff Job Descriptions.doc), also attached.
The agency also provided in Section 602.15(a)(2) (Exhibits s 602.15.2a-m) CV's and supporting documentation demonstrating that each staff member and commission member is qualified to perform their specific roles and that they are trained in the agency's standards and accrediting procedures including the evaluation and accreditation of distance education.
The agency also provided exhibits (d.2) and (d.3), attached, which document the agency's income source along with its fiscal year ending in June 2016 budget and June 2016 audited financial statement (602.14(c)) (Exhibit 25 sec 3 (d.1), provided in the agency's original submission.
The agency also provided update documents (attached) of the agency's income source along with its fiscal year ending June 30, 2018 that documents an increase in net assets and unrestricted assets that should ensure the agency's ability to conduct all of its accrediting 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;
During the MSACSS last review the Department staff determined that the agency needed to provide CV's/or Resumes to evidence the competency of their representatives. The agency also needs to provide documentation to demonstrate training of its Commissioners, Appeal Panel, and Site Team members including training relative to the evaluation and accreditation of distance education.
In the agency's initial submission it provided evidence to the competence, knowledge, and qualifications of its Commission, appointed Appeals Panel, and site team members as required by this section of the criteria. Qualifications requirements and the process for selection of the members of the MSA Secondary Commission, its Appeals Panel and Site Team members are documented in (Sec 3 Exhibit (e.1-6). The agency also provided a sample training certificate for one of its site team members (Sec 3 Exhibit e.10) and materials used in the training of its appeal panel members (Sec 3 Exhibit e.9a), it also provided a list of the subjects that are covered in the training of its commission members (Sec 3 exhibit e.7). A list of Commission Members is at (Exhibit 5) which is attached.
In response to the Department's request the agency provided the CV's of its sitting Commissioners ( Exhibits designated as Commission Members) and its professional staff (Exhibits designated Staff) to demonstrate the competency of their representatives which is required by this section. CV's were also provided for staff Training Specialist (Exhibit 7) and its Commission Member who is a Distance Education Specialist (Exhibit 27)
The agency also provided amendments to its narrative (Amendments to Narrative 602.15(a)(1)(2)) which is attached that clarifies the agency's policies and protocol for training its decision making bodies and staff on its distance education standards and processes (Standards for Accreditation CT Institutions (2018) (Page 25 and 28) (EP.26 - EP.31 INDICATORS FOR INSTITUTIONS THAT DELIVER ALL OR PART OF THEIR EDUCATIONAL PROGRAM BY A DISTANCE MODALITY) also attached.
The agency also notes that their current Post-Secondary Distance Education schools in membership have been co-accredited with the DEAC, which is the Title IV gatekeeper for the program, with that agency being the "lead agency." The DEAC protocol and visitation expectations are conducted with an MSA representative assigned to the team. The MSA decision bodies, site team evaluators and staff are trained in this protocol.
The Department did not receive any written third - party comments regarding this agency.