Accjc gone wild
January 2014 Revised Standards
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- Hittelman Statement to the ACCJC on Standards Revision
January 2014 Revised StandardsIn January of 2014 the ACCJC presented for First Reading a revised set of Accreditation Standards. The document was not available to the public until well after the approval at First Reading. The Second and final Reading will be approved at the June 2014 meeting of the Commission. The standards continue to address a requirement for “continuous” evaluation, integration of planning, and other item for improvement. The term “continuous improvement” is an overused phrase with little real meaning. Anyone familiar with the phenomenon of improvement is aware that change is never continuous. Change is often stop and go with plateaus along the way. It is also not always positive particularly when funding is lacking. The idea of “continuous improvement” does not represent physical reality. Of course what “continuous” applications would mean is not laid out in the policy - it is left vague to be interpreted later. But it is time to move away from vagueness. It is time for different language to be introduced into the Standards. In fact, in some places the phrase "regularly" is used instead of “continuously.” This is perhaps what is meant by the term "continuous" but "regularly" is still overly broad. Perhaps approaching the issue in terms of how often a college should return to the same issues for reevaluation is the proper path. At least with this approach, institutions will understand what is really expected of them. Another vague term used in the standards is the word “integrity.” When the word is used it should include what would constitute “integrity” in that provision. Most of the Accreditation Standards are vague and thus not very instructive. Until interpreted by directions given to Visiting Teams and the Commission the standards themselves provide little in the way of explanation of what is actually required. Not only are the standards of less use to institutions but the vagueness of the language makes it difficult to discuss changes during the revision process. Although all of the standards need to be addressed in terms of their actual application, some of the standards present problems on their face. Here are a few that I believe should raise red flags: “II.a.1. All instructional programs are offered in fields of study consistent with the institution’s mission, are appropriate to higher education, and culminate in student attainment of identified programmatic student learning outcomes, and degrees, certificates, employment, or transfer to other higher education programs.” The first question concerns how “appropriate to higher education” is determined. Depending on how it is later interpreted, the resulting evaluation could depend on one narrow version of appropriateness. Attainment of “student learning outcomes” (SLOs) is not enough to determine whether the breadth of the course knowledge has been acquired by a student leaving a class. They are not comprehensive enough. Grades are better indicators of whether the required knowledge and skills have been attained. SLOs are not robust enough to play the role suggested in this standard. “II.A.5. If the institution offers pre-collegiate level curriculum, it distinguishes that curriculum from college level curriculum and directly supports students in learning the knowledge and skills necessary to succeed in college level curriculum.” Is this an attempt to change the California Master Plan? The California Master Plan allows non-credit courses to be offered for their own value - not exclusively to lead to success in college level work. This is a very serious problem if the goal of the ACCJC is to drive out non-credit education that is based on the needs of the students who enroll. “II.A.7. The institution schedules courses in a manner that allows students to complete certificate and degree programs within a period of time consistent with established expectations in higher education.” First, there is no “generally recognized” expectation of completion of programs in community colleges. Given the up and down funding of community colleges, it is very difficult to schedule all of a college’s classes in such a manner that all needs are met within some period of time. The other problem with this Standard is that the period of time required is not spelled out but rather left without any direction to the colleges as to what is actually being demanded. “II.A.10 The institution awards course credit, degrees and certificates based on student attainment of learning outcomes.” Again, SLOs are much too narrow to base the awarding of course credit and the rest on. Learning outcomes, as defined in the procedures, are just not appropriate or up to the level of what a student should achieve in a class. “Standard III. Resources. The institution effectively uses its human, physical, technology, and financial resources to achieve its mission and to improve academic quality and institutional effectiveness. Accredited colleges in multi-college systems may be organized so that responsibility for resources, allocation of resources and planning rests with the district/system. In such cases, the district/system is evaluated against the Standards and its performance is reflected in the accredited status of the institution(s).” What is the measure of “effective use” of resources? The move to evaluating colleges based on district action needs to be looked at carefully. This is important for districts. Does the policy mean that a “deficit” at a college is not considered as a problem for the college so long as the district has a respectable reserve - or that somehow the district loses accreditation if does not provide for colleges with necessary resources? Is a fail by the district office a fail for all of the colleges - independent of the academic quality of the programs? “III.A.7. The institution maintains a sufficient number of qualified faculty, both full-time and part-time, to assure the fulfillment of faculty responsibilities essential to the quality of educational programs and services to achieve institutional mission and purposes.” What is a “sufficient number” of full-time faculty? Will the ACCJC ever look at the college from the point of view that there are not enough full-time faculty to provide for faculty chairs in each department or that there are not enough full-time faculty to do the necessary work on curriculum? Or not enough full-time faculty to provide students with the office hours they deserve? “III.D.12. The institution plans for and allocates appropriate resources for the payment of liabilities and future obligations, including Other Post-Employment Benefits (OPEB), compensated absences, and other employee related obligations. The actuarial plan to determine Other Post-Employment Benefits (OPEB) is current and prepared as required by appropriate accounting standards.” Will this mean that if the district satisfies their legal reporting requirement, then they have satisfied the ACCJC standards? Or will the ACCJC continue to attempt to force districts into putting funds aside to offset the accounting liability (even when doing so is a waste of limited financial resources)? The liabilities are long range and change dramatically over time. At what point should a college put money aside? In fact, some colleges have met their obligations for over fifty years on a pay-as-you-go basis. “III.D.13. On an annual basis, the institution assesses and allocates resources for the repayment of any locally incurred debt instruments that can affect the financial condition of the institution.” “Can” is not an appropriate measure. The measure needs to be much more compelling. The “allocates resources” appears to mean that the district must put funds aside to address the actuarial liability? If so, that is contrary to the California Community Colleges requirement. “IV.C.2. The governing board acts as a collective entity. Once the board reaches a decision, all board members act in support of the decision.” I have heard that this is a national requirement. If so, this must be changed at the national level. If not true, ACCJC should remove this requirement as in contradicts the basic rights of elected officials as demonstrated in governing boards, city councils, and the like all across the country. As Kurt Vonnegut once wrote to a college president that was burning his books: “Have somebody read the First Amendment to the United States Constitution out loud to you, you God damned fool.” “IV.C.13. The governing board delegates full responsibility and authority to the CEO to implement and administer board policies without board interference and holds the CEO accountable for the operation of the district/system or college, respectively.” What constitutes “full responsibility and authority?” Does it mean that the governing board is forbidden to step in and tell the CEO to follow the faculty or staff collective bargaining agreement or do something else that the board sees is not being done correctly? Boards should be concerned with this provision. It strictly limits their ability to govern. “IV.D.1. In multi-college districts or systems, the district/system CEO provides primary leadership in setting and communicating expectations of educational excellence and integrity throughout the district/system and assures support for the effective operation of the colleges. Working with the colleges, the district/system CEO establishes clearly defined roles, authority and responsibility between the colleges and the district/system.” Shouldn’t this be a basic responsibility of the governing board? “IV.D.3. The district/system has a policy for allocation and reallocation of resources that are adequate to support the effective operations and sustainability of the colleges and district/system. The district/system CEO ensures effective control of expenditures.” What if one of the colleges is not receiving adequate funding? Does this mean that the college will be dinged because the district did not properly distribute funding? How will this be decided? In addition, the distribution of funds should be a responsibility of the governing board. “IV.D.4. The CEO of the district or system delegates full responsibility and authority to the CEOs of the colleges to implement and administer delegated district/system policies without interference and holds College CEO's accountable for the operation of the colleges.” So now college presidents will not be under the direction of the governing board or the district office? Is the governing board not supposed to be watching what is happening on campus? Is a District Chancellor not allowed to tell a college president to change what he or she has done? Are they not supposed to act when one of the college president’s is not following board policy or violating collective bargaining agreements? This standard should cause concern for governing boards. The problem with all of the standards is that they are too vague. They are open to many interpretations. Since the interpretations of the standards do not come until after the Commission approves the standards, real input on the standards is difficult. Input from colleges and faculty and staff means little if no input can be made with respect to how the standards will be interpreted - and they all need much interpretation. Not only do that, but the interpretations of the standards not go through any public process. As a result, the real meat of the issues is never open to full discussion. No wonder there is so much discontent with the behavior of the ACCJC. Hittelman Statement to the ACCJC on Standards RevisionOn April 22, 2014 I submitted a list of suggested changes with the following summary to the ACCJC with regard to their Standards: The Standards are often too vague. Words and phrases such as “integrity,” “act responsibly,” “are appropriate to higher education,” “established expectations,” “assure the effectiveness,” and “realistic assessment” are not precise enough to allow judgments to be made. This allows for variations in interpretation to be made by Visiting Teams and by the Commission itself. The Standards should not contain arguments for the standard such as “In order to assure institutional and academic integrity,” “in pursuit of continuous improvement,” “in order to assure institutional and academic integrity,” and “supports student learning and achievement by providing.” The Standards should not require institutions to violate state and federal regulations and policies. The Standards should not intrude on collective bargaining law, the rights of elected governing board members, and impose financial requirements beyond those required by the college system and law. The Standards should not be impossible to fulfill such as “continuous” improvement. Improvement can only physically occur sporadically. Standards should not require institutions to improve beyond the level of satisfaction of the standard. Such policy results in different institutions being held to different levels of success. It also results in a movement of the goal line and a different goal line for different colleges. 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