Understanding Federal Compliance Expectations for the Periodic Review Report

1. Understanding Federal Compliance Expectations for the Periodic Review Report Debra G. Klinman, PhD Ellie A. Fogarty, EdD Lisa Marie McCauley, EdD, CPA

2. Overview • Accreditation and Federal Compliance • Past, Present, and Future (Emerging Issues) • Current Expectations • Certification Statement • Areas of Review • Additional Resources • Procedures for Submission and Review Middle States Commission on Higher Education

3. Accreditation and Federal Compliance Middle States Commission on Higher Education

4. Past • Accreditation developed and evolved throughout the early 20th century to promote mission-centered, continuous quality improvement through self-appraisal and peer review Middle States Commission on Higher Education

5. Past • HEA 1965 (with subsequent re-authorizations, including 2008) directed accreditors to serve as gatekeepers for institutional access to federal financial aid (Title IV) • Verification of compliance with federal regulations became an ever-increasing part of the accreditation process Middle States Commission on Higher Education

6. Present • Federal financing has ballooned alongside rising institutional costs and cutbacks in state and local funding • Accreditors continue to focus on quality improvement; the Department of Education sees the primary purpose of accreditation as safeguarding federal funds and ensuring institutional accountability Middle States Commission on Higher Education

7. Present • HEOA 2008 formalized compliance verification by accreditors in four specific areas (distance & correspondence education, transfer of credit, credit hours, and cohort default rate) • MSCHE verification procedures are now part of all accreditation reviews (Self-Study and PRR) Middle States Commission on Higher Education

8. Future (Emerging Issues) • Next HEOA re-authorization is likely to be postponed until 2014 - 2015 • National voices include NACIQI (October 2011), ACE National Task Force on Institutional Accreditation (June 2012), Obama administration (State of the Union, February 2013) Middle States Commission on Higher Education

9. Future (Emerging Issues) • Ideas that have been discussed include: • Eliminating or modifying the link between accreditors and institutional eligibility for Title IV • Instituting ‘baseline’ quantitative performance measures to be monitored by the federal government • Differentiating accreditation procedures by mission (sector, profit vs. non-profit) and ‘risk’ (prior history of performance and stability) Middle States Commission on Higher Education

10. Future (Emerging Issues) • Ideas that have been discussed include: • Emphasizing measures of ‘value, affordability, and student outcomes’ in determining access to federal aid (value = students’ ability to get jobs and pay off student loans) • Developing an ‘alternative pathway’ for access to federal financial aid for innovative models of higher education (i.e., competency-based learning, MOOCS) • The national dialog will continue in the months and years to come. Middle States Commission on Higher Education

11. Current Expectations Middle States Commission on Higher Education

12. Certification Statement • Institutions affirm compliance with federal Title IV requirements including: • Distance and correspondence education (student identity verification) • Transfer of credit • Title IV cohort default rate • Assignment of credit hours • Signed by CEO and Board Chair • Documentation reviewed by peer compliance reviewers Middle States Commission on Higher Education

14. Distance and Correspondence Education • Distance Education • Instruction delivered via technology • Regular student/faculty interaction • Correspondence Education • Instructional materials delivered, mail or email • Student initiated interaction as needed Middle States Commission on Higher Education 14

15. Student Identity Verification • HEOA 2008: How do institutions verify student identity in distance or correspondence education courses? • Secure username and password • Proctored exams • New technologies • Protection of student privacy • Notification of student fees at registration Middle States Commission on Higher Education 15

16. Verification of Compliance Institutions submit the following along with their Periodic Review Reports: Distance or Correspondence Education Methods used to consistently verify student identity, protect student privacy, and notify students about cost Middle States Commission on Higher Education

17. Transfer of Credit • HEOA 2008: How do institutions publicly provide the following to students? • Criteria for Transfer Decisions • List of Articulation Agreements Middle States Commission on Higher Education 17

18. Verification of Compliance Institutions submit the following along with their Periodic Review Reports: Transfer of Credit Publicly disclosed policies and procedures for the transfer of credit and a list of all articulation agreements Middle States Commission on Higher Education

19. Credit Hours • Measurement of academic work AND economic metric • Federal definition is consistent with the Carnegie Unit • State credit hour regulations, consistent with the federal credit hour definition, may be sufficient evidence of compliance Middle States Commission on Higher Education 19

20. Credit Hours • HEOA 2008: How does the institution ensure that its credit hour policies align with federal criteria? Does the institution’s assignment of credit hours conform to commonly accepted practice in higher education? Middle States Commission on Higher Education 20

21. Verification of Compliance Institutions submit the following along with their Periodic Review Reports: Assignment of Credit Hours • Policies and procedures for assigning credit hours to all types of courses & programs • Evidence that credit hours are accurately and reliably assigned • A list of the courses & programs that differ from the federal definition of ‘credit hour’ with evidence that they conform to commonly accepted practice in higher education Middle States Commission on Higher Education

22. Title IV Cohort Default Rate • The percentage of students in a given fiscal year who cannot repay federal loans • Each year, the US Department of Education calculates and publishes the average rate • HEOA 2008: Is the institution’s 3-year cohort default rate within the federal limit? Middle States Commission on Higher Education 22

23. Verification of Compliance Institutions submit the following along with their Periodic Review Reports: Title IV Cohort Default Rate Documentation from USDE of the institution’s cohort default rate, audits of federal programs (A-133) for the past 3 years, relevant correspondence and institutional responses Middle States Commission on Higher Education

24. Resources US Dept. of Education http://www2.ed.gov/about/offices/list/ope/policy.html http://www2.ed.gov/policy/highered/leg/hea08/index.html Official Cohort Default Rates for Schools http://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.html MSCHE Verification of Compliance with Accreditation-Relevant Federal Regulations: Initial Implementation for Spring 2013 http://www.msche.org/documents/ComplianceCriteriaSpring2013.pdf Middle States Commission on Higher Education

25. Procedures for Submission and Review Middle States Commission on Higher Education

26. Institutions • The Compliance Documents should be contained in one PDF file that is indexed / bookmarked by each of the four compliance areas. • PRR Institutions will upload documents to: www.MSCHE.org/MyCHE • Submission upload is required by June 1st - same as PRR. Middle States Commission on Higher Education 26

27. Peer Compliance Reviewers • Peer Compliance Reviewers will use the information to prepare their report on the institution’s compliance. • Peer Compliance Reviewers will upload their report of compliance verification by July 15th. Middle States Commission on Higher Education 27

28. Institutions & PRR Reviewers • The institution can review and respond to any non-compliance issues noted, by August 15th. • The PRR Reviewers will consider any additional response from the institution in the preparation of the Confidential Brief to the Commission. Middle States Commission on Higher Education 28

29. Questions? • dklinman@msche.org • efogarty@msche.org • lmmccauley@msche.org Middle States Commission on Higher Education