Some of the demands of ACCJC, such as Measurable Student Learning Outcomes (SLOs), are not recognized as model standard practices by the majority of college educators. This is a violation of 34 CFR 602.13. This fact is illustrated by faculty resistance to the imposition of the measurable student learning outcome methodology. Despite the opposition to the busy work required under SLOs, faculty members are forced to perform them under the threat of sanction. Even so, a large number of sanctions are based on the failure of a college to fully implement SLOs. This just illustrates the lack of general acceptance of this standard.
SLO’s are written to describe what specific knowledge and skills a student should have and be able to demonstrate at the conclusion of a course, program, and/or degree. SLO’s are to be used to provide data collection to measure student academic success. The implementation of SLOs requires considerable work and effort. In addition to the normal tests given by instructors to determine how well a student is doing in a class and what grade should the student earn, SLO’s are used to determine whether the specific “outcomes” have been achieved. The data from the SLO’s is then supposed to be used to determine whether the classes are successful in terms of student success .There has, to this point, been no objective study of the use of SLOs in improving instruction.
The problem with SLO’s in the eyes of many instructors is that they do not lead to better teaching and learning and are a very big waste of time. Instead they tend to lead to a standardized curriculum that does not address the full needs of the students. Such important elements as motivation, critical thinking, interest, creativity, and the ability to learn on one’s own are difficult if not impossible to measure with SLO’s – and as a result become less important in the minds of those who would rate educational quality based on SLOs. In short, many faculty members resist doing SLOs not just because of the work involved, but also that they do not provide insights into how to improve instruction.
34 CFR 602.13 require that an accrediting agency “must be able to demonstrate that its standards, policies, and accreditation decisions are widely accepted in the United States by educators and educational institutions, licensing bodies (if appropriate), practioners, and employers of graduates for accredited institutions/programs.” The ACCJC is out of compliance with this fundamental requirement. Their approach to governance, planning, coordination, SLOs, fiscal responsibility, and research is not widely accepted either in the California community colleges or across the nation. This accounts for much of the high level of sanctions inflicted on the colleges by the ACCJC.
I have found no evidence that suggests that the ACCJC has attempted to demonstrate that its standards, policies and decisions are widely accepted. To the contrary, concerns voiced by the Academic Senate of the California Community Colleges, a host of both state and federal legislators, faculty unions, Community College Boards of Trustees, the California Community College Consultation Council, and the RP Group underlines the general opposition to their policies and practices. The lack of wide acceptance was included in the concerns of the Department of Education in their evaluation of ACCJC.
The ACCJC discourages any consideration of how the college meets state and federal requirements. This disinterest in California and federal law and practice is emphasized in the ACCJC Team Evaluator Manual. On page 23 of the August 2012 Manual it advises that “Recommendations should not be based on the standards of governmental agencies, the legislature, or organizations.”
The actual quality of the education offered is not a consideration. In addition, the ACCJC has attempted to micro-manage colleges by using accreditation as the tool to force colleges to change their budgeting and governing patterns to fit the ACCJC’s vision of how a college should operate. In the case of Northern Marianas College (Saipan North Marianas Islands), the Commission has even attempted to force change in their trustee composition.
Some of the arguments used by the Commission to support ACCJC sanctions against City College of San Francisco and several other colleges question the very mission of the community colleges in California. A goal of ACCJC’s interpretation of its standards seems to be to reduce open access to a wide variety of programs and students in the name of reduced resources. In short, the Commission is attempting to change the very mission of community colleges through ACCJC’s ability to sanction. This action is clearly in conflict with Federal Regulation 34 CFR 602.17(a)(1).
High Rate of Sanctions
From 2003 to 2008 the six United States regional accrediting bodies issued a total of 126 sanctions to community colleges in the United States. 112 of these were issued by the ACCJC under Beno’s direction. ACCJC has continued to be out of step with the other accrediting agencies. From June 2011 to June 2012 the ACCJC issued forty-eight of the seventy-five sanctions (64%) issued nationwide. The community colleges in California represent about 19% of the community colleges accredited nationally. In short, the 19% of the colleges nationwide that are under ACCJC generated 64% of the national sanctions.
In 2013 the ACCJC continued its assault on California’s community colleges when it sanctioned 10 out of 23 (43.4%) colleges before it in January of 2013 and 10 out of 21 (47.6%) colleges in June of 2013. Their action included putting College of Sequoias on SHOW CAUSE (the college must prove that it should not have its accreditation removed) and removed the accreditation from City College of San Francisco effective July 2014. This large number of sanctions is an indication that their policies and the way they apply them are out of step with what is happening in the internationally recognized outstanding community colleges of California.
Dan Walters, on February 16, 2014, wrote in the Fresno Bee that “For several years, those who run California's 100-plus community colleges have complained that the commission that makes all-important accreditation evaluations has been excessively aggressive, even nit-picking. There have even been off-the-record complaints that evaluators for the Accrediting Commission for Community and Junior Colleges, an offshoot of the Western Association of Schools and Colleges, were settling personal scores from their own days as community college faculty and administrators. The complaints arose as the commission issued highly critical reports on district after district, and as local college officials, worried about the immense financial consequences of losing accreditation but also dealing with cutbacks in state support, scrambled to respond.”
Clearly, the ACCJC has become a rogue agency.
According to the ACCJC, its accreditation process provides assurance to the public that the accredited member colleges meet their Standards and that "the education earned at the institutions is of value to the student who earned it; and employers, trade or profession-related licensing agencies, and other colleges and universities can accept a student's credential as legitimate." Contrary to this claim, the emphasis of ACCJC has not been on the value of the education to the student or to the colleges and universities that would accept the credits earned. Rather it has been on compliance with the ACCJC standards (the majority of which do not directly address the quality of education that students receive).
The California Community Colleges Student Success Scorecard tracked students for six years through 2011-12. Many of the colleges which ranked highest on the scorecard in the various categories have recently been given sanctions by the ACCJC. Other colleges with low ranking have not. One typical example is City College of San Francisco which was had its accreditation revoked in June of 2013. CCSF ranked fourth among the colleges in the state in the percentage of students who were underprepared for college but still achieved 30 units of transfer work over the six years tracked. It also ranked high in other categories. CCSF is a great college for students and the ACCJC is set on closing it. It is clear, from looking at the scores at the various colleges, that the ACCJC has not successfully developed a methodology for considering academic quality and success. The scores on the California Community College Student Success Scorecard can be found on the California Community College website.
In fact, when the colleges of Special Trustee Agrella and Temporary Chancellor Scott-Skillman (who were brought in the make CCSF right), CCSF scores higher in many categories.
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Folsom Lake College (Scott-Skillman)
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Santa Rosa College (Agrella)
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CCSF
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Full Time Equiv. Students
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5,400
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9,700
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32,600
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Persistence
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68.6%
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62.3%
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75.2%
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Completion
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45.6%
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53.1%
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55.6%
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Career Tech Ed
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49.9%
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54.5%
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49.5%
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30 units
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70.3%
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69.8%
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72.5%
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Remedial (Math/English/ESL)
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23/35/7
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15/27/12
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18/43/52
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% FT Faculty
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69.4%
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58.2%
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71.4%
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