Accjc gone wild
June 28, 2013 Response from ACCJC
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- July 25, 2013 ACCJC Reply to Hittelman Complaint and Hittelman analysis
June 28, 2013 Response from ACCJCIn a letter dated June 28, 2013 I received a letter from Cheri Sixby, Executive Assistant to the President of the ACCJC saying that they have received my complaint of June 26, 2013 and that Barbara Beno had delegated a review of my complaint to Krista Johns, Vice President for Policy and Research. My “complaint of June 26” was actually just a reiteration of my complaint of April 20, 2013. In any case, Krista Johns was assigned to contact me with any questions and “a response or notification will come within 30 days of receipt of the complaint.” The Commission never responded to my original complaint/comment of April 30, 2013. July 25, 2013 ACCJC Reply to Hittelman Complaint and Hittelman analysisIn a letter signed by Krista Johns, Vice President for Policy and Research, the “Commission” decided that “Upon review of specific portions of the documents you identified and of our standards, policies and their application in accreditation practices, organizational structure, procedures, and other items referred to, no Commission violations were found.” This decision came as no surprise to me given the past responses of the ACCJC to complaints against the way they operate. On a side point, I am not sure how the “Commission” could have approved the letter since it has not met between the time that the ACCJC decided to address my issues and the issuance of the letter. The letter begins by declaring that the RP Group study was flawed. They did not contest that the findings did represent factual accounts of the persons interviewed. Ms. Johns noted the RP Group desire to have colleges and the Commission work more in harmony but the letter only addressed the college need to cooperate with the Commission. No discussion was offered regarding the ACCJC’s reliance on compliance. The letter also noted that “The ACCJC is currently engaged in an extensive review of its Accreditation Standards. This process will result in improved and changed processes. However institutional quality assurance to the public will always be at the foundation of any actions taken by the Commission.” I am not sure why a need to change is required when the ACCJC claims that it is perfect in the execution of its Visiting Teams and the performance of the Commission itself. They once again state that they did not understand that my April 30 e-mail did not include a complaint although anyone reading it would understand that. One of the continuing themes of the letter involved the need for colleges to correct deficiencies within two years of their appearance – even if they are not noted in any Visiting Team report or actual ACCJC action. One of my continued questions involves whether a suggestion made by a Visiting Team represents a demand by the Commission to address it completely. What makes the answer to this question even more puzzling is when Ms. John writes such statements as: “Evaluation teams complete a confidential recommendation regarding institutions prior to the completion of their on-site visit. It is made clear to evaluation teams that this is a recommendation only, from team to Commission; it does not carry any decisional weight. The decision on the accredited status of a college is made by the Commission.” Does this mean that the Visiting Team report has no official recommendation status unless that recommendation is given a stamp of approval by the Commission? If so, why was CCSF held to a recommendation of a 2006 Visiting Team when no sanctions had ever been issued by the Commission? According to the Johns letter “Regulations require that if an institution is found to not be in compliance with any standard, the accrediting agency must immediately initiate adverse action against the institution or require the institution to come into compliance within a period not to exceed two years. 34 C.F.R. § 602.20.” “Adverse action” means the removal of accreditation. The problem with all of this is that almost every college has some “deficiency” noted in its Visiting Team report and yet not every college has been given a SHOW CAUSE sanction based on the two year rule. Another basic question arises: Is it good public policy to remove the accreditation of a college for anything other than the low quality of its academic program or the cost of the classes to the student versus the reward from the credits? I am sure that the Department of Education and the federal standards do not expect accreditation agencies from removing accreditation for “failure to meet standards” that have little to do with the actual quality of the instruction offered. The Johns letter questions whether the data presented in ACCJC Gone Wild demonstrates ACCJC being out of step with the other regional bodies. They did not present alternative data nor did they state that my data was incorrect – only that various agencies have different ways of reporting sanctions. Their actually being out of step was never addressed. In terms of the ACCJC’s insistence that colleges reduce their offerings in order to meet the new realities, Ms. Johns writes: “The earlier ability of institutions to hold multiple missions of equal priority in terms of commitment, resource allocation, effectiveness and quality, is another area which has been altered by external forces in today's fiscal, governmental, and political environment.” She fails to address the fact that the California Master Plan is still the law in California. Attempts by the Commission to force colleges and districts to limit their scope of offerings would cause districts to be out of step with California law. Of course that is not problem for the Commission given their lack of respect for other California laws and regulations regarding such issues as governance, role of governing boards, collective bargaining, financial requirements, and GASB 45. The appearance of a conflict of interest when Kinsella and Gornick hold positions both with the ACCJC and with the CCLC JPA was not addressed in the letter. I now understand why I have heard that Visiting Team reports have been altered by the team chair after meeting with a member of the ACCJC staff and after the Team completed its work. The letter from Johns explained that “Responsibility for completing the team report falls to the team chair. After the team chair completes an initial draft evaluation report, the chair will share the report with an ACCJC staff member. This review is done to ensure that reports are clear, address all essential and required components for team reports, and are grammatically correct and consistent with Commission requirements.” A typical statement in the Johns letter is “ACCJC's objectives are clearly set forth in its standards, including Eligibility Requirements, Accreditation Standards, and Commission policies.” This despite all the evidence presented that proves that this statement is just not true. The fact that no one can predict what sanction the Commission will come up with –not even the Visiting Team – is one example of the lack of clarity. The recognition in the letter that different teams may come up with different recommendations is another example of lack of clarity. Another example of the kind of answer the ACCJC in reply to complaints is “Institutional evaluations are conducted by peer evaluators who are professionals in the field. They apply standards consistently and fairly to all institutions.” Do they all act professionally and apply standards consistently across the colleges? Has the ACCJC ever investigated and compared the Visiting Team reports in a systematic way in order to determine if inconsistencies exist? Despite the ACCJC manner of answering complaints, saying something is true doesn’t make it true. Finally, the question of lack of transparency on the part of the ACCJC is never addressed in the letter. Perhaps this is an issue that should be addressed at the national level by Congress. The private workings of the ACCJC combined with the agreement by Visiting Team members, Commissioners, and members of the staff not to disclose any of the proceedings of the ACCJC only contribute to the distrust of the Commission and the validity of their actions. 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