Accjc gone wild
May 20, 2014 letter from BOG to ACCJC - the Smoking Gun?
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- May 27, 2014 Rejection of Reconsideration of CCSF Sanction
May 20, 2014 letter from BOG to ACCJC - the Smoking Gun?On May 20, 2014 Manual Baca, Chair of the California Community College Board of Governors (BOG), wrote a revealing letter to Dr. Sherrill Amador, Chair of The Accrediting Commission for Community and Junior Colleges (ACCJC). The letter is interesting in that it not only asks that ACCJC remove the termination of City College of San Francisco (CCSF) but also that it reveals that the ACCJC and the BOG were working in cooperation on the sanction against CCSF. Many observers believed that some deal had been worked out between the BOG and the ACCJC but only circumstantial evidence was available. Events had also led followers to believe that the agreement between the ACCJC and the BOG had been broken by the ACCJC. Here is what Baca wrote: “Dear Dr. Amador: I am writing today on behalf of the Board of Governors (BOG) to respectfully request that the Accrediting Commission for Community and Junior Colleges (ACCJC) rescind their termination of accreditation of City College of San Francisco. We make this request based on our belief that the college is now in substantial compliance with the accreditation standards, and we encourage the Commission to send a visiting team to the college to document that progress.” “You will recall that the BOG originally placed a special trustee in the college in November of 2012, and elevated that trustee to replace the elected board in July of last year. We took both these actions in consultation with ACCJC and in support of the Commission's growing concerns about the college. At the time we intervened to elevate the trustee and remove the authority of the locally elected board, we did so with the strong encouragement of ACCJC and with the Commission's assurances that there was a pathway to restoration of the accreditation of the college. The BOG certainly knew that dramatic and substantial changes were needed in the college, but we would never have undertaken the job if there were no chance of fully restoring accreditation.” Baca then went on to describe the “progress” in financial and other areas that had been made at CCSF: “College and Chancellor's Office staff, under the direction of the BOG, are now ten months into the recovery process and tremendous progress has been made. The college's finances are sound and sustainable, student learning outcomes are in place for all courses, the management team is completely new and there are no longer interim leaders, collective bargaining agreements have been reached with all unions, program planning and evaluation is operational, and enrollment is stabilizing. During the past year the college has also improved the governance of the institution, taken control of the various costs related to its centers, and enhanced its outreach and support in the community. Most recently, the climate in the college has become much more positive and some of the public controversy that marked the early part of our involvement has subsided. Frankly, the amount of improvement in the institution in less than one year is remarkable.” Baca continued with his view of what more needed to be done “There are still changes the college must complete. The time necessary for a full cycle of planning, implementation, evaluation and revision will take several more months. The finalization of the management and governance changes needs to be completed and the institution will ultimately be turned back to a renewed locally elected Board of Trustees.” Baca notes his belief that the action of the ACCJC was a “catalyst” for the changes and the desired results have occurred. And thus “it is now time for the college to be removed from the threat of loss of accreditation so that it can complete the restoration process.” In short, the reign of terror imposed on CCSF had been successful in changing the college to one that was more acceptable based on the values of the ACCJC. Finally Baca notes that the ACCJC has stated that it cannot reverse its decision due to fears concerning possible actions by the US Department of Education (USDOE). This claim by ACCJC that it cannot reverse course is clearly false by evidence of, as Baca notes, “and in our direct conversations with the USDOE they continue to suggest that the Commission has the power to make this decision without it negatively impacting their relationship with the department.” In a letter from the USDOE to the Honorable Nancy Pelosi dated May 19, 2014, Lynn B. Mahafie (Senior Director, Policy Coordination, Development and Accreditation Service) stated that “the ACCJC has the authority to reconsider or rescind its termination decision so as to provide the institution with additional time to come into compliance within the two-year time frame, if such period has not run out, or to provide an extension for good cause. While the Department cannot comment on specific actions an accrediting agency may or may not take in the future, in general, an agency may, as permitted by its established policies and procedures, correct any errors it has made, respond to an improvement in institutional performance, and adopt or change its policies with regard to its oversight of the institutions it accredits.” The Los Angeles Times on May 20, 2014 reported a statement by Pelosi that “For the ACCJC to refuse to allow good-cause extension - even after this clarification from the Department of Education, even after all the monumental progress City College has made - would be destructive, irresponsible, and could be viewed as a political act.” May 27, 2014 Rejection of Reconsideration of CCSF SanctionOn May 27, 2014 the ACCJC Terrible Three (President Beno, Chair Amador, and Vice Chair Kinsella) wrote a letter to Congresswoman Pelosi and posted a statement on the ACCJC website that made clear that the ACCJC would not rescind its decision to revoke the accreditation of the City College of San Francisco (CCSF). The public statement began by addressing what the Three labeled “Significant controversy—and misunderstanding—has characterized much of the media coverage of this decision. Although ACCJC typically does not release information of the kind contained in this statement, we believe it is vital to set the record straight with our member institutions.” Clearly the Three were on the defensive due to the overwhelming outcries against their action by the press, state and national legislators, community college chancellor’s, and faculty groups. The Three went on to describe, from their point of view, their action with regard to CCSF. Their description, as is usual in such dispatches from the ACCJC, self-promoting, misleading and inaccurate. They lay out how an accreditation agency should work - “we work every day to provide assurance to the public that the colleges we accredit meet our standards; that the education students receive at these colleges is valuable to them; and that employers and other workforce entities can justifiably rely on students' credentials from these colleges as meaningful. In short, accreditation reflects a process designed to assure college quality and accountability for students and for taxpayers that support accredited institutions.” This is not a description of how ACCJC works. Their standards and the way they are applied tell nothing about the education that the students actually receive. They do say a lot concerning what ACCJC considers education to be. They go on to claim that “ACCJC's standards, against which CCSF and all California community colleges are reviewed, are the product of a public and open process. Community college educators and experts develop the standards, informed by the effective practices of member institutions. Colleges are reviewed against these standards by trained teams of academics and administrators and by the 19 ACCJC Commissioners who are elected by ACCJC-member college leaders and who represent the interests of the public and of member institutions.” This contradicts the secret and closed processes that ACCJC uses to develop and approve its standards. There is no open forum for discussion of various suggestions made by those in the field and they are voted on in secret. They also fail to note that many of the sanctions imposed by the Commission are not in agreement with those recommended by the teams that visit the colleges. CCSF is one example where the Commission issued a SHOW CAUSE against the recommendation of the visiting team. The Terrible Three go on to list actions by ACCJC prior to the decision to issue a SHOW CAUSE but do not disclose that the SHOW CAUSE was their first sanction against CCSF. They do not disclose that the U.S. Department of Education faulted the ACCJC for not distinguishing between a suggested change and a required change. This was one of the issues with regard to CCSF - with no prior sanction there could not have been a prior demand to change as the ACCJC continues to contend. Despite the ruling by the U.S. Department of Education, the Three still contend that “Despite its nearly decade-long awareness of these issues, CCSF failed to comply with multiple eligibility requirements and over 50 compliance standards related to academic quality and resources, financial stability, and coherent governance of an institution.” It is clear that none of these so-called “compliance standards related to academic quality and resources” have affected the quality of education at CCSF. CCSF has consistently been one of the best performing community colleges in California based on the Student Success Scorecard. This may be one of the reasons why CCSF has become such a target of the Terrible Three - that they show that the nit-picking standards of the ACCJC do not predict academic quality of instruction. The Terrible Three go on to claim “Consistent with federal law and ACCJC's published policies, which are binding on the Commission, ACCJC was obligated to withdraw CCSF's accreditation. Beno, et. al. continued to suggest that “ACCJC has suggested exploration of an arrangement whereby CCSF could revert to candidacy status. That would hold CCSF accountable for its deficiencies by recognizing that CCSF does not fully comply with accreditation standards. At the same time, it would enable the college to continue to work toward full compliance while its students remain eligible to access federal student financial aid. CCSF leadership to date has not expressed an interest in pursuing this option.” This option had already been rejected by the appointed leadership at CCSF. In the letter to Pelosi, Beno and the others make the same claim. Pelosi, Congresswoman Jackie Speier and Congresswoman Anna Eshoo then released a statement in response to the “continuing refusal to acknowledge the ability to extend City College of San Francisco (CCSF) a good-cause extension of accreditation, even after an official statement from the U.S. Department of Education confirmed the ACCJC's legal flexibility to do so.” Pelosi, Speier, and Eshoo went on to state that "It is outrageous that the ACCJC continues with its incorrect interpretation of Department of Education policy, even in the face of a clear, unambiguous statement from the Department that clearly confirms that the ACCJC has the legal flexibility to offer a good-cause extension.” "As the Department stated, '...ACCJC has the authority to reconsider or rescind its termination decision so as to provide the institution with additional time to come into compliance within the two year time frame, if such time has not run out, or to provide an extension for good cause.' Yet the ACCJC believes that it knows the Department of Education's regulations better than the Department of Education itself - and refuses to provide City College the good cause extension it has earned.” The Press release concluded with "ACCJC's faulty reliance on outdated analysis of the health of City College, and its pursuit of an unworkable policy that ends state and federal funding to CCSF and puts the students and faculty in academic limbo is professionally crippling and destructive. The commission's letter raises serious questions about its ability to properly execute the law and make informed decisions based in ensuring high-quality institutions of learning that benefit our students, our community and our state. Should this failure of leadership persist, new leadership is needed at ACCJC. The Department of Education should also consider whether to recertify ACCJC as an accrediting body." The statement by Beno, Amador, and Kinsella also laid out what they considered “CCSF's Undisputed, Long-standing Noncompliance with Accreditation Standards Reflects Systemic Problems in Academic Quality, Financial Management, and Leadership.” I am not sure what they mean by “undisputed.” Several lawsuits, legislative concerns and proposed legislation, as well as numerous complaints against the action by the ACCJC (including this paper’s documentation of their wrongdoing) have been lodged. 100 individuals and groups wrote to the U.S. Department of Education opposing the ability of ACCJC to continue to accredit colleges. This is hardly “undisputed” noncompliance. In any case, how serious are the charges from ACCJC? The statement by Beno, Amador, and Kinsella list “a small subset of significant evidence leading to the withdrawal decision of ACCJC.” They claim that “CCSF's claims of academic excellence were contradicted by the school's failure to track the progress of the vast majority of its students and to provide student support services required by accreditation standards. CCSF had not monitored and collected data on the vast majority of its students to know whether they were on track and completing their programs of study on time.” This has nothing to do with academic excellence. It is bookkeeping - not a measure of the quality of education. “CCSF also had failed to identify intended learning outcomes for its courses and programs and lacked student assessments to evaluate what students learn. Only a fraction of programs had completed assessments and improvement processes based on the assessments. And student support services — including those related to information technology, libraries, and counseling — were demonstrably inadequate, with some campuses offering full programs of study with no library or resource facility at all, and sparse onsite academic counseling.” The ACCJC claims that it is interested in outcomes. These are not measures of academic quality outcomes. These are inputs. If the claims are true concerning CCSF’s lack of satisfying these paperwork requirements, they only point out that despite not seeming to satisfy these requirements, the college still has great student outcomes. “CCSF's history of serious financial mismanagement, verified by independent reviewers, fundamentally undermined the quality of the institution. Over the course of many years, CCSF leadership failed to plan for financial developments and address CCSF's needs. [For example, CCSF had no plans to pay for future liabilities, like post-employment medical benefits and worker compensation.]” While CCSF did have some problems with poor management of resources, it was never in the red. Currently it appears to be in good financial shape. The ACCJC has no recent updates on the CCSF financial position. Before closing the college, the ACCJC should look at the current financial condition of CCSF and judge the college on the same basis as they would any other college. “Substantial evidence spanning many years illustrates that CCSF has had unclear and dysfunctional governance processes. In recent years, many CCSF administrative leadership positions, including Chancellor, were filled by temporary employees, and there was frequent turnover of senior staff responsible for serving students. The current Chancellor recently confirmed that, at the time of ACCJC's review, CCSF had a "missing infrastructure of policies and procedures that should have been created years ago." The California Community Colleges Board of Governors in July 2013 installed a Special Trustee to supersede the decision authority of the CCSF Board of Trustees, based on a concern that CCSF was being mismanaged, further confirming that CCSF's problems were extensive and extraordinary.” And what is the situation now? The ACCJC should see before closing the college. 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