Implementing the Accreditation Provisions in the Higher Education Opportunity Act 2008 – Part I

1. Implementing the Accreditation Provisions in the Higher Education Opportunity Act 2008 – Part I Ellie A. Fogarty – Vice President Barbara Samuel Loftus – Vice President Debra G. Klinman – Vice President MSCHE 2010 Annual Conference Middle States Commission on Higher Education 1

2. Overview • Part I • Context and History • HEOA 2008 Accreditation Provisions Implemented July 1, 2010 • Part II • Substantive Change • HEOA 2008 Accreditation Provisions to be Implemented July 1, 2011 Middle States Commission on Higher Education 2

3. Context and History • Accreditation developed and evolved to promote mission-centered, continuous quality improvement through peer evaluation. • HEA 1965 (with subsequent re-authorizations, including 2008) named accreditors as gatekeepers for institutional access to federal funding. Various regulations have ensued. Middle States Commission on Higher Education 3

4. Context and History Today, while accreditors continue to focus on quality improvement, USDE sees the primary purpose of accreditation as safeguarding federal funds. How can Middle States work with our member institutions to reconcile these perspectives? Middle States Commission on Higher Education 4

5. July 1, 2010 Provisions • Distance Education • Transfer of Credit Policy • Student Achievement • Teach-out Plans • Additional Accreditation Provisions • Direct Assessment • Due Process Procedures • Responsibility to report Title IV fraud Middle States Commission on Higher Education 5

6. Distance 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 6

7. Distance Education Programs • MSCHE-approved Distance Education Programs • 50 percent or more of the program’s credits are approved for electronic delivery • Approved via Substantive Change process • Listed on Statement of Accreditation Status • Designated reviewer added to evaluation teams • New distance education guidelines from MSCHE Middle States Commission on Higher Education 7

8. Student Identity Verification Policy • Applies to Distance and Correspondence Education Courses and Programs • Institutions document their processes through which student identity is verified • Secure username and password • Proctored exams • New technologies • Protection of student privacy • Notification of student fees at registration • Evaluators review compliance Middle States Commission on Higher Education 8

9. Transfer of Credit Policy • Publicly Disclosed Policy • Students and the public • Identify Criteria for Transfer Decisions • List Articulation Agreements • Institution’s certify compliance when submitting Self Study and PRR materials • Evaluators review compliance Middle States Commission on Higher Education 9

10. Student Achievement • “Success with respect to student achievement in relation to the institution's mission, which may include different standards for different institutions or programs, as established by the institution, including, as appropriate, consideration of • State licensing examinations, • course completion, and • job placement rates.” Middle States Commission on Higher Education 10

11. Student Achievement in MSCHE Standards • Standard 14 • Assessment of program, general education, & institutional learning goals, including direct evidence of student learning • Standard 11 • Educational offerings conducted at levels of appropriate rigor for the programs or degrees offered • Standard 8 • Ongoing assessment of student success including retention through the pursuit of the student’s educational goals Middle States Commission on Higher Education

12. Teach-out Plan “…means a written plan developed by an institution that provides for the equitable treatment of students if an institution, or an institutional location that provides 100% of at least one program, ceases to operate before all students have completed their programs of study, and may include, if required by the institution’s accrediting agency, a teach-out agreement between institutions.” Middle States Commission on Higher Education

13. Teach-Out Plans • Accreditors evaluate and approve plans if: • USDE notifies MSCHE that a teach-out plan is required following an action against the institution • MSCHE withdraws, terminates, or suspends an institution’s accreditation • An institution notifies MSCHE that it intends to cease operations entirely or close a location that provides 100% of at least one program • A State agency notifies MSCHE that an institution’s license has been or will be revoked Middle States Commission on Higher Education 13

14. Teach-out Plans • Accreditors look for • Equitable treatment of students • Notification to students of additional charges, if any • If a program is accredited by another accrediting agency, MSCHE notifies that agency of its approval of the teach-out plan • MSCHE may require a teach-out agreement as part of the institution’s teach-out plan Middle States Commission on Higher Education

15. Questions? Middle States Commission on Higher Education 15

16. Implementing the Accreditation Provisions in the Higher Education Opportunity Act 2008 – Part II Ellie A. Fogarty – Vice President Barbara Samuel Loftus – Vice President Debra G. Klinman – Vice President MSCHE 2010 Annual Conference Middle States Commission on Higher Education 16

17. Recap & Overview • Part I • Context and History • HEOA 2008 Accreditation Provisions Implemented July 1, 2010 • Part II • Substantive Change • HEOA 2008 Accreditation Provisions to be Implemented July 1, 2011 Middle States Commission on Higher Education 17

18. Substantive Change Overview • Definition of Substantive Change • Prior Approval for Changes Required • Relationship between Regional Accreditors and US Department of Education Middle States Commission on Higher Education

19. Substantive Change Categories • Change in mission or objectives • Change of legal status, control, or ownership • Courses or programs representing a significant departure from existing offerings • Programs at a new degree or credential level • Change from clock to credit hours • Substantial increase or decrease in the number of clock or credit hours awarded for successful completion of a program Middle States Commission on Higher Education 19

20. Substantive Change Categories • Initiation or expansion of distance or correspondence education wherein 50% or more credits in a program offered through alternative delivery • Establishment of a branch campus • Establishment of domestic and international additional locations, including an additional location acquired from another institution, or established to provide a teach-out for students Middle States Commission on Higher Education 20

21. Substantive Change Categories • Planned closure or relocation of additional location or branch campus, or a change in category • Institutional closure requiring a teach-out plan • Initiation of contractual agreement with 25% or more of an educational program provided by an unaccredited entity Middle States Commission on Higher Education

22. July 1, 2011 Provisions • State authorization  • Misrepresentation • Incentive compensation • Gainful employment (in progress) • Credit hours Middle States Commission on Higher Education 22

23. State Authorization • States must authorize Title IV eligibility • Accreditation may serve as proxy • States must act on complaints Middle States Commission on Higher Education 23

24. Misrepresentation • Institutions and their representatives must NOT make “false or misleading” statements to: • Students/prospective students • Public • Accreditors • State • USDE • Includes marketing, advertising, recruiting, admissions Middle States Commission on Higher Education 24

25. Incentive Compensation • No incentives to anyone based on securing enrollments or awarding financial aid • Includes recruiters, admissions staff, presidents, athletic staff • No “safe harbors” Middle States Commission on Higher Education 25

26. Gainful Employment (in progress*) “educational program that prepares students for gainful employment in a recognized occupation” *Eligibility for student aid – Final regulations in progress, to be implemented July 1, 2012 Disclose information on website, including Graduation rates Placement rates Median loan debt • New programs – USDE notification/approval • Need and wage analysis • How developed • Accreditation and State approval Middle States Commission on Higher Education 26

27. Credit Hours • Unit of measurement of academic work • Federal definition consistent with Carnegie Unit • “reasonable equivalencies” -- verifiable student learning outcomes • Accreditors evaluate reliability & accuracy • Accreditors must address deficiencies, report “systematic noncompliance” to USDE Middle States Commission on Higher Education 27

28. HEOA 2008 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 Council for Higher Education Accreditation http://www.chea.org/Government/index.asp#FedUpdate Middle States Commission on Higher Education http://www.msche.org/ Middle States Commission on Higher Education 28

29. Questions? Middle States Commission on Higher Education 29