Accjc gone wild
Oct. 31, 2014 ACCJC: WHAT’S EDUCATION GOT TO DO WITH IT?! By Alvin Ja
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- IN WHOSE INTERESTS: PUBLIC, OR ACCREDITING COMMUNITY
- QUALITY OF EDUCATION NOT RELEVANT TO ACCREDITATION STANDARDS
- UNFAIRNESS OF COMMISSIONER SELECTION/ELECTION
- THE CONCEPT OF TEST VALIDITY
- ABUSE OF THE PUBLIC TRUST
- FEDERAL REGULATIONS: KEYS TO THE KINGDOM WITH A LICENSE TO KILL
Oct. 31, 2014 ACCJC: WHAT’S EDUCATION GOT TO DO WITH IT?! By Alvin JaACCJC should be judged in relation to the overarching purpose of accreditation set forth in ACCJC Bylaws and 34 CFR 602.1: ACCJC Bylaws Article I Section 2 states that its purpose is “improving and validating the quality of…education…through the creation and application of standards of accreditation and related policies…” 34 CFR 602.1: Why does the Secretary recognize accrediting agencies? (a) The Secretary recognizes accrediting agencies to ensure that these agencies are, for the purposes of the Higher Education Act of 1965,as amended (HEA), or for other Federal purposes, reliable authorities regarding the quality of education or training offered by the institutions or programs they accredit. IN WHOSE INTERESTS: PUBLIC, OR ACCREDITING COMMUNITY?ACCJC is incorporated as a public benefit organization. However, In a Press Release dated /23/2014, ACCJC revealed that their true purpose was the preservation of its above-the-law unaccountable power. ACCJC was concerned about “great harm to the accrediting community”; it was not concerned with the much greater harm that has been, and continues to be, inflicted on our community and its students. Current ACCJC Chair Steven Kinsella wrote an impassioned 10/24/2013 e-mail to CCC CEO’s last year asking for support for ACCJC’s Petition for Renewal of Recognition. His letter showed no concern for the public/student/community interest. It revealed only interest in protecting the “system” [of accreditation]. QUALITY OF EDUCATION NOT RELEVANT TO ACCREDITATION STANDARDSTo paraphrase Tina Turner: What's education got to do with it?! What's education but a second-hand tool to power? Who needs education when you can rule an empire? The City Attorney filed a Declaration citing the positive results of CCSF’s CCCCO Student Success Scorecard. ACCJC opposed the Declaration arguing: “This information [Student Success Scorecard results] is submitted to support the position that the college provides a quality education, which is not relevant to whether the college met the accreditations standards…” State Chancellor Brice Harris testified on the first day of the trial regarding CCSF's positive performance as measured by the Chancellor's Office's Student Success Scorecard. The ACCJC attorney asked the State Chancellor to cite the ACCJC Accreditation Standard to which the Student Success Scorecard measures pertained. The ACCJC lawyer was smug and triumphant when Chancellor Harris was unable to connect the Scorecard results with Accreditation Standards. In winning this skirmish with the Chancellor, ACCJC let the State Chancellor, the Judge, and the community know: "WHAT’S EDUCATION GOT TO DO WITH IT?!" UNFAIRNESS OF COMMISSIONER SELECTION/ELECTIONState Chancellor Jack Scott complained in 2010 to Dept. of Education about Commissioners being hand-picked. ACCJC subsequently instituted changes in their Bylaws as a result of the complaint to USDE. Despite the change, member institutions' role remains very limited. The selection of Commissioners remain controlled by a small group of people. The Commission is a peer membership body in name, but true power resides in a small Power Elite of President and Executive Committee. The Commissioners--except for one Commissioner elected recently via an at-large nomination—are pre-selected by an 8-member Nominating Committee appointed by a 3-person Executive Committee. The Nominating Committee then chooses candidates to populate a SLATE on the basis of ONE candidate per vacancy (in other words, if there are two vacancies, the Nominating Committee chooses 2 people to be on the Slate. Finally, institutions (represented by Chancellors/CEO's/Presidents) then get the privilege of voting YES/NO for the SLATE. A new At-large candidate procedure is overwhelmed by the Slate procedure. Bottom-line: The procedure for Commissioner selection is, for all practical purposes, still hand-picked. THE CONCEPT OF TEST VALIDITYA basic concept in the educational field is the concept of test validity: Does a test measure what it purports to measure? Similarly, the creation and application of standards and policies should be weighed against how much they contribute to “improving and validating the quality of education.” Are policies, eligibility requirements, accreditation standards valid measures of the quality of education? Policies, eligibility requirements, accreditation standards that do not contribute towards improving or validating the quality of education and that only have a function of enforcing discipline and obedience over its member institutions should be seen as unfair and contrary to the purpose of accreditation. Contrary to its own stated purpose in ACCJC Bylaws, ACCJC’s current leadership has exposed that its true purpose has been the preservation and expansion of its above-the-law unaccountable power. The creation and application of ACCJC requirements, standards and policies has been more about power projection, enforcement of discipline and obedience, and the building of a powerful and unaccountable agency than the improvement and validation of educational quality. ABUSE OF THE PUBLIC TRUSTAccrediting agencies are awarded the public trust by Dept of Education to be gatekeepers to federal funds to validate “quality of education or training.” Recognized accrediting agencies are given great freedom in setting standards and policies. However ACCJC has taken advantage of this freedom to abuse their power. The incommensurate sanctions on CCSF has caused substantial harm to students and community. FEDERAL REGULATIONS: KEYS TO THE KINGDOM WITH A LICENSE TO KILL34 CFR § 602.16 (e) Accreditation and preaccreditation standards. (e) An agency that has established and applies the standards in paragraph (a) of this section may establish any additional accreditation standards it deems appropriate. 34 CFR § 602.23 (f) Operating procedures all agencies must have. The agency may establish any additional operating procedures it deems appropriate. ACCJC has taken advantage of the apparent license and unrestrained authority given by § 602.16 (e) and 602.23 (f) to gain the keys to the kingdom. These two Sections give a “license to kill” (more politely, BROAD LATTITUDE) to unscrupulous agencies. ACCJC is an unscrupulous agency. It has set up criteria, procedures and processes that are intrusive, prescriptive, costly, granular, and-–most importantly—unrelated to quality of education for institutions. 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