Review of CCSF Removal of Accreditation Decision

Letter from Saginor to Agrella

On March 4, 2014 Karen Saginor (an active Academic Senate member and Librarian at CCSF) wrote a letter to Special Trustee Robert Agrella and CCSF Chancellor Arthur Tyler requesting that the appeal document “you submit for this purpose on behalf of City College of San Francisco will fully address the four appeal criteria relating to errors, bias, or lack of evidence on the part of ACCJC.” She noted that the review request by Agrella had mostly likely left out many important issues that had been brought up by the CFT and others suing the ACCJC as Agrella had indicated that he would follow the advice offered on August 16, 2013 by Dr. Beno: “The rights of CCSF under ACCJC’s standards and policies, including the institution’s rights under the pending review and appeal process, and also its rights under the attendant USDE [U.S. Department of Education] regulations, cannot be adopted by or transferred to third parties. While the Union is free to submit complaints about the ACCJC, just as any other third party, the Union is not a representative or agent of the institution, and has no authority to represent the institution in its dealings with the Commission and USDE. Nor should a third party’s complaints be treated or handled in the process of review requested by a member institution of ACCJC, in this case CCSF. The public’s and USDE’s response to the Union’s complaints give the appearance that these clear boundaries are not being respected.”

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  The March 2012 Visiting Team and the April 2013 Show Cause Visiting Team lacked a sufficient number of faculty, a violation of ACCJC policy.
  
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  The March 2012 Visiting Team included Peter Crabtree, husband of Dr. Barbara Beno.
  
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  The Commission incorrectly asserted that City College had been found deficient prior to 2012, basing this error on a mischaracterization of recommendations for improvement that accompanied the 2006 decision stating that City College met all standards.
  
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  The Commission placed City College on Show Cause without giving it a lesser sanction first. This was out of line with ACCJC practices in sanctioning other colleges – disparate treatment that demonstrates bias.
  
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  In accordance with ACCJC policy, The Show Cause Visiting Team Report was shared in draft form with College leadership so that the College might have an opportunity to submit corrections for errors of fact in it before the Commission considered it. However, with the Commission decision in 2013 came notification that ACCJC was adding many more standards to those identified as deficient in the Show Cause Visiting Team Report. Contrary to ACCJC policy (and USDE regulation) the ACCJC did not identify what the deficiencies were for these standards. (For example, Standard II.A.6 concerning information provided to students about courses, program, policies, etc. – the Show Cause Visiting Team Report noted that City College met this standard, the decision letter from the Commission listed this as a standard not met, but did not identify the deficiency.)
  
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  In addition to not identifying the added deficiencies, ACCJC gave no opportunity to City College to submit corrections for errors of fact, and these improperly noticed, unidentified deficiencies were part of the basis for the Commission’s 2013 decision to withdraw accreditation.
  
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  ACCJC characterized City College as deficient for its level of prefunding of Other Post Employment Benefits (OPEB) although ACCJC standards did not include requirements for prefunding of OPEB. Also, ACCJC did not label the same or lower levels of OPEB funding as deficient at many other colleges.
  
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  The March 2012 Visiting Team and the April 2013 inappropriately included persons with conflicts of interest in regards to OPEB prefunding, an ACCJC Vice President, and persons who lobbied for provisions of the Student Success Task Force that City College strongly opposed.
  
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  The 2013 Show Cause Visiting Team identified Recommendations and standards that City College met partially or did not meet because, while the College had established appropriate practices and made acceptable progress, there had not been time (in the eight months since the Show Cause sanction) to complete the cycle of work. The Commission decided to withdraw accreditation rather than provide even a small amount of additional time for City College to complete the work and demonstrate progress. This illogical decision demonstrates bias.
  
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  The Commission found that City College did not meet several standards concerning Student Learning Outcomes based on evidence submitted by the college in Spring, 2013. However, the same evidence was submitted to ACCJC for a feedback report prepared by ACCJC staff. When ACCJC staff compared colleges, scoring them numerically using a rubric, City College was scored as meeting requirements. This inconsistency in assessing evidence demonstrates errors and bias on the part of the Commission.”