§602.13 Acceptance of the agency by others.
The staff found that “the agency has not demonstrated that it has broad acceptance of its standards, policies, procedures, and accrediting decisions from all of the entities required by the Secretary's Criteria for Recognition.
As documentation, the agency provided letters from postsecondary institutions and higher education organizations and associations. However, these letters do not demonstrate broad acceptance of its standards, policies, procedures, and accrediting decisions, as they are letters of gratitude not letters of support. In addition, four faculty senates at California institutions, three California-wide faculty organizations and one national faculty organization provided written comments that indicated their disagreement with the policies and actions of the agency, and that call into question the wide acceptance of the agency's standards, policies, procedures, and decisions to grant or deny accreditation by educators.”
Of course, the ACCJC as usual claimed “that it has broad acceptance of its standards, policies, procedures, and accrediting decisions from all of the entities required by the Secretary's Criteria for Recognition.” Counter to what ACCJC claimed the report found that “although the agency indicates that most of the letters of disagreement previously submitted are in regards to the accreditation actions taken concerning one institution, the contents of the letters are not limited to that action and raise additional areas of broad disagreement with the agency's standards, policies, and procedures. In addition, many of the previously-submitted letters of non-support were from educators, whereas only one letter in support submitted by the agency is from an educator. (The agency labeled four letters as from educators, but three of those letters are from a retired, long-term administrator; current chancellor; and current State fiscal advisor; respectively, and cannot be categorized as from ‘educators’.) The agency did not provide documentation in support of its statements (under this section or Section 602.15(a)(3)) that a large number of educators serve on its evaluation teams or participate in workshops. Under Section 602.21(a)(b), the agency did provide some documentation of the involvement of educators in the standards review process. Furthermore, in its response, the agency only commented on two areas of concern included (in the letter from the State Academic Senate and the national association), but did not address the additional areas of concern raised by the other faculty organizations at the institutional, State, and national level except to argue that, as faculty unions, these organizations are supporting the CCSF's cause. Therefore, the agency has not demonstrated wide acceptance of the agency's standards, policies, procedures, and decisions to grant or deny accreditation by educators.”
This despite the attempts by Beno and Kinsella to enlist the help of the community college CEOs and CBOs to convince the Department of Education that they did have wide acceptance.
§602.15 Administrative and fiscal responsibilities
The Staff Report indicated that: “Although the current commission roster states that it meets the composition requirements of the bylaws, the agency has not provided a policy or other guidance as to what would qualify a person to be identified as either primarily an academic, or primarily an administrator, nor did the agency provide any biographical information of the current commissioners to demonstrate that those individuals meet the qualifications for the category noted.”
The Report noted that “To meet the requirements of this regulation, the Department does not require the use of any one definition for an academic, but does expect that the agency's definition be comparable with the generally accepted policies and practices within the accrediting agency and wider higher education community. Department staff note that the inclusion of student services staff as academic representatives does not meet the generally accepted definition of such representation within the accrediting agency community, nor the spirit of the regulation. The agency's definition states that academic representatives may include deans, department chairs, or other related administrative roles as long as those individuals have a ‘primary responsibility for instruction or instructional support.’”
“Noting the agency's definition, the use of the term academic for individuals whose primary responsibilities are administrative and who are not directly engaged in a significant manner in postsecondary teaching and/or research misrepresents the experience expected for an individual in this role. Department staff also note that the inclusion of individuals whose principal activities are administrative limits the number of individuals whose primary activity is classroom instruction as academic representatives and may affect the evaluation team's ability to adequately review an institution in the related areas of the agency's standards.”
“Department staff observed an on-site evaluation in October 2013, and noted that the agency listed five team members as academics, out of a team of 10. Through individual interviews and reviews of biographical information provided to the institution, Department staff noted that two members of the team were faculty in the classroom, one was an interim academic dean with no teaching responsibilities for the past few years, one was an academic dean that had not taught in over 10 years, and one was a vice chancellor for student affairs who had never taught. (Department staff noted that the team assistant was also listed as an academic, but generally the team assistant is not considered a member of the evaluation team by the agency. For this review, the team assistant had to fill-in for an absent team member, but the role he was filling was administrative, which he was able to do as an academic dean.)”
§602.16 Accreditation and preaccreditation standards
The report notes that “the evaluation reports provided in this section do not demonstrate that the evaluation teams made a judgment about the appropriateness of the measures of student achievement chosen by the institution nor rigor of the goals” and “the self-studies and evaluation team reports include a review of job placement rates and State licensing examination pass rates, they do not include assessment of that data.” “The evaluation reports also include a review of institutionally-established measures of student achievement, but do not include an assessment by the evaluation team of such measures. Therefore, the agency has not demonstrated that it makes a judgment about the appropriateness of the measures of student achievement chosen by an institution.”
§602.17 Application of standards in reaching an accrediting decision.
The report indicates that although the ACCJC makes certain claims about its review and evaluation process that, in fact, “the examples provided verify the agency's review and evaluation of the mission and objectives of institutions and determination if they are successful in achieving those objectives, but do not demonstrate that it adequately assesses qualitative and quantitative program effectiveness and student outcomes measures” and “what is not clear is that an institution must evaluate its performance as an institution with respect to those objectives.” In short, the report concludes that the ACCJC “has not demonstrated 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.”
“The agency states that it utilizes both the evaluation team report and the commission action letter to clearly communicate the assessment of an institution's compliance with the agency's standards, to include performance with respect to student achievement. The examples provided (in this section and throughout the petition) document the use of the evaluation team report and the commission action letter to communicate areas of compliance and non-compliance, however it is not clear that the reports clearly delineate between areas of non-compliance and areas for improvement, as discussed in Section 602.18(e). In addition, the reports are deficient in providing a detailed assessment of the institution's performance with respect to student achievement, as detailed in Section 602.16(a)(1)(i).”
The ACCJC responded by stating that it “had revised its evaluation team report and commission action letter structure to delineate between areas of non-compliance and areas for improvement for separating those elements in different sections.” These revisions were not approved by the Commission members (the Commission had not met since June 2013) but rather developed by Beno and her staff and have not yet been applied. The DOE report concluded that “Although the agency has made changes to its policies and procedures and provided an example evaluation team report (attached), it did not provide documentation of complete implementation, to include an example commission action letter to an institution, to demonstrate that the agency clearly delineates between areas of non-compliance and areas for improvement. Although the evaluation team report (attached) includes an assessment of the institution's performance with respect to student achievement, the majority of reports provided (in this section and in Section 602.16(a)(1)(i)) still do not demonstrate a detailed assessment of the institution's performance with respect to student achievement.” Of course no one has seen such reports as the Commission will not issue letters until January of 2014. At that point we will see if they continue to confuse districts as to what is required and what is merely suggested. This finding alone should convince the ACCJC to reverse its findings on CCSF and other districts and begin a new and proper procedure.
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