Department of Education Staff Report on ACCJC – November 2013
ACCJC Recognition Compliance Issues
U.S. Department of Education Staff Report to the Senior Department Official on ACCJC Recognition Compliance Issues
The U.S. Department of Education Staff Report was issued in late November 2013 regarding the continued recognition of ACCJC as an accreditation agency. The report is an internal recommendation by staff within the Department of Education. The staff recommended to “Continue the agency's recognition and require the agency to come into compliance within 12 months, and submit a compliance report that demonstrates the agency's compliance with all identified issues.” In addition the recommended included extending “the agency's time for coming into compliance for the previous findings of noncompliance in Sections 602.15(a)(3), 602.18(e), and 602.20(a) within the August 13, 2013, CFT Complaint Decision letter, which expires in August 2014. To provide sufficient time for the agency to demonstrate compliance in light of the close timing between the complaint and petition review, Department staff finds good cause to extend the agency's period for coming into compliance until 12 months of the date of the decision letter on recognition.” The next step in the process is the NACIQI meeting on December 12-13, 2013. After that it the issue of ACCJC’s ability to be an accreditation agency goes back to the Department of Education and Secretary of Education Arnie Duncan for a final decision.
The report also includes a recommendation that ACCJC not be allowed to expand its scope to include baccalaureate institutions as requested by ACCJC.
The staff found that the ACCJC did not appear to meet the following sections of the Secretary of Education’s Criteria for Recognition and “the agency must:
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demonstrate that its standards are sufficient to comprehensively evaluate baccalaureate level degree programs and are comparable to commonly accepted standards for ensuring quality in baccalaureate degree programs. [§602.12(b)]
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demonstrate wide acceptance of the agency's standards, policies, procedures, and decisions to grant or deny accreditation by educators. [§602.13]
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demonstrate that academic personnel, as generally defined by the accrediting agency and wider higher education community, are represented on its evaluation teams. [§602.15(a)(3)]
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demonstrate that it evaluates the appropriateness of the measures of student achievement chosen by its institutions. [§602.16(a)(1)(I)]
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demonstrate that it evaluates an institution on its maintenance of clearly specified educational objectives that are consistent with its mission and appropriate in light of the credentials awarded, and is successful in achieving its stated objectives with specific regards to baccalaureate degree programs. [§602.17(a)]”
The staff found that the agency (ACCJC)
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does not meet the requirements of this section based on its requested scope. It must demonstrate that its standards for accreditation regarding curricula are sufficiently rigorous and comprehensive to ensure that the agency is a reliable authority regarding the quality of the baccalaureate level education provided by the institutions it accredits. The agency needs to incorporate its substantive change protocol requirements for baccalaureate degree programs into the agency's curricula standards. [§602.16(a)(1)(ii)]
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does not meet the requirements of this section based on its requested scope. It must demonstrate that its standards for accreditation regarding faculty are sufficiently rigorous and comprehensive to ensure that the agency is a reliable authority regarding the quality of the baccalaureate level education provided by the institutions it accredits. [§602.16(a)(1)(iii)]
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must provide documentation to demonstrate that it has fully implemented its revised policies to demonstrate that the agency clearly delineates between areas of non-compliance and areas for improvement. The agency must also demonstrate that it provides the institution with a detailed written report that assesses the institution's performance with respect to student achievement. [§602.17(f)]
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must provide documentation to demonstrate that it provides the institution with a detailed written report that clearly identifies any deficiencies in the institution's compliance with the agency's standards. [§602.18(e)]
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must provide information and documentation to demonstrate that it requires additional information from an institution when student achievement data, or any other key data or indicators do not meet the agency's standards. [§602.19(b)]
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must demonstrate that it consistently enforces the time period to return to compliance with the agency's standards. [§602.20(a)]
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must demonstrate that it takes immediate adverse action if an institution does not bring itself into compliance within the specified period. [§602.20(b)]
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must provide documentation that it must complete the standards revision process within a reasonable period of time. [§602.21( c)]
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must provide documentation to demonstrate that it provides written specification of any deficiencies identified at the institution examined. [§602.25(a-e)]
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must demonstrate that it provides written notice of negative decisions to the Secretary and the other entities required by this section at the same time it notifies the institution of the decision. [§602.26(b)]”
The report notes that “In late spring of 2013, the Department received a complaint from the California Federation of Teachers (CFT), as well as other interested parties, about ACCJC. The specific complaint was provided to ACCJC by the CFT at the same time as submitted to the Department. After ACCJC concluded its complaint process, the Department investigated the complaint, to include a request for additional information from ACCJC, and provided its decision in a letter dated August 13, 2013. The letter instructed ACCJC to take immediate steps to correct the areas of non-compliance identified, and to provide its response to those areas within its response to the draft staff analysis of the agency's petition for recognition.”
The report continues: “In conjunction with the current review of the agency for its continued recognition, Department staff reviewed the agency's petition and supporting documentation, and observed an on-site evaluation in October 2013. The Department also received over 100 third-party written comments in connection with the agency's petition for recognition.” All of the 100 third-party were opposed to the activities of ACCJC.
In more detail the findings were:
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