U.S.Department of Education Staff Report

to the

Senior Department Official on Recognition Compliance Issues

Recommendation Page

  1. Agency: Southern Association Of Colleges and Schools ( 1952 / 2017)
    (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: The accreditation and preaccreditation (“Candidate for Accreditation”) of degree-granting institutions of higher education in Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia, including the accreditation of educational programs offered via distance and correspondence education within these institutions. The accreditation status of these institutions and their recognition extends to the SACSCOC Board of Trustees and the Appeals Committee of the College Delegate Assembly on cases of initial candidacy or initial accreditation and for continued accreditation or candidacy.
  4. Requested Scope of Recognition: The accreditation and preaccreditation (“Candidate for Accreditation”) of degree-granting institutions of higher education in Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia, including the accreditation of educational programs offered via distance and correspondence education within these institutions. The accreditation status of these institutions and their recognition extends to the SACSCOC Board of Trustees and the Appeals Committee of the College Delegate Assembly on cases of initial candidacy or initial accreditation and for continued accreditation or candidacy.
  5. Date of Advisory Committee Meeting: 06/20/2017
  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 does not meet the requirements of this section of the criteria. The agency must provide additional explanation and documentation for the missing resumes and Board of Trustee members on the roster. [§602.15(a)(2)]

    -- The agency does not meet the requirements of this section of the criteria. The agency needs to provide signed conflict of interest forms of appeals committee and evaluation team members (7-10 of each).
    [§602.15(a)(6)]

    -- The agency does not meet the requirements of this section of the criteria. The agency needs to provide the documents associated with the full cycle of review of the substantive change proposal provided as evidence to demonstrate compliance. The documents should include the agency review of the proposal, recommendations, and decision letters from the decision making bodies. [§602.22(a)(1)]

Executive Summary

PART I: GENERAL INFORMATION ABOUT THE AGENCY

The Southern Association of Colleges and Schools, Commission on Colleges (SACS or agency), is a regional institutional accreditor. SACS accredits or preaccredits (“Candidate for Accreditation”) 794 degree-granting institutions of higher education in Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia, including distance and correspondence education programs offered at those institutions.

Over 98% of the 794 institutions accredited by the Commission rely on the agency’s continued recognition by the U.S. Department of Education for access to Title IV, HEA programs.

During this recognition period, the Department received 3 third-party comments and 2 complaints.


Recognition History

SACS appeared on the initial list of nationally recognized accrediting agencies published by the U.S. Office of Education in 1952. The agency’s recognition has been periodically reviewed and continued recognition has been granted after each review.

The agency's last review for continued recognition was in 2012, which resulted in the agency having to submit a compliance report regarding four outstanding issues. The agency's compliance report submission was reviewed in 2014, which resulted in the agency’s continued recognition for a period of 3 years. The agency's review for continued recognition is the subject of this analysis.


PART II: SUMMARY OF FINDINGS

The agency meets the requirements of the Secretary's Criteria for Recognition.

PART III: THIRD PARTY COMMENTS

Staff Analysis of 3rd Party Written Comments

The Department has received three third-party comments pertaining to the renewal of recognition for the agency. Two of the comments raise concerns with the Secretary’s criteria (602.18(b)) and agency requirements for the consistent and adequate enforcement of standards, with respect to Everglades College and Keiser University. The Department’s Performance Data by Accreditor spreadsheet demonstrated failing financial responsibility composite scores for Everglades University prior to the agency’s renewal petition submission, which prompted the Accreditation Group to request additional information on the financial health and oversight of Everglades University. The agency provided additional information that revealed Everglades College, which is not accredited by the agency, serves as the corporate entity that owns Everglades and Keiser University, who are accredited by the agency. However, Department staff has requested additional evidence from the agency concerning adherence to the Secretary’s criteria and the agency’s policies, procedures, and standard requirements for further compliance review. In addition to the above concerns, one of the aforementioned commenters requests the recusal of the Chair of NACIQI, due to conflicts of interests associated with their professional association with Everglades College and Keiser University. However, this request is outside the confines of the scope of recognition review. This information will be forwarded to the Executive Director for the NACIQI for action.

The third commenter raises concerns regarding the agency’s standards on student outcomes, institution performance, and Board member representation under federal regulations. The concerns, are related to the following criteria: student achievement 602.16(a)(1)(i), Separate and Independent status 602.14(b), 602.15(a)(5) Public Representatives, and 602.15(a)(6) Conflict of Interest. The agency’s accreditation standards, has been reviewed by the Department and additional evidence has been requested from the agency. It should be noted that the Higher Education Act, as amended, Section 496 states “Nothing in this Act shall be construed to permit the Secretary to establish criteria for accrediting agencies or associations that are not required by this section. Nothing in this Act shall be construed to prohibit or limit any accrediting agency or association from adopting additional standards not provided for in this section. Nothing in this section shall be construed to permit the Secretary to establish any criteria that specifies, defines, or prescribes the standards that accrediting agencies or associations shall use to assess any institution’s success with respect to student achievement.” However, the Department invites the agency to respond to the third party commenters in the corresponding sections of their petition response.