Insights on Accreditation Rulemaking and Standards Implementation

Accreditation webinar #1 Department of Education January 22, 2020

2 Other Accreditation Webinars January 30: January 23: Teach-outs School Closures Additional Locations State Authorization for Distance Education Substantive Change Compliance Timeframes Alternate Standards Student Outcomes January

3 Accreditation Regulations Today s Topics Accreditation Rulemaking New Recognition Process Accreditation Standards Implementation Timeline

4 Accreditation Abbreviations Code of Federal Regulations (CFR) Department of Education (ED) Higher Education Act (HEA) Institution of Higher Education (IHE) Section ( ) Title IV of the HEA (Title IV or TIV)

5 Accreditation Rulemaking

6 Accreditation Rulemaking Public Hearings: 1) 9/6/2018 - Washington, DC 2) 9/11/2018 - New Orleans, LA 3) 9/13/2018 - Sturtevant, WI

7 Accreditation Rulemaking Website: www2.ed.gov Search: rulemaking Subject: 2018-2019 Rulemaking Contains: rulemaking public hearing and session documents, negotiator list, links to Federal Register Notices, etc.

8 Accreditation Rulemaking Website: www.regulations.gov Contains: public comments Docket ID: ED-2018-OPE-0076 Website: www.federalregister.gov Contains: Federal Register Notices and related documents (official) with various search and filter options

9 Accreditation Rulemaking 4 sessions in 2019: 1) January 15-16 (14th weather cancellation) 2) February 19-22 3) March 25-28 (extended hours) 4) April 1-3 (additional session and extended hours) Topics grouped into 3 buckets Consensus reached on all

10 Accreditation Rulemaking Main Committee: Accreditation and Subcommittee Topics Subcommittees: 1) Distance Education 2) TEACH Grants 3) Faith-Based Initiatives

11 Accreditation Rulemaking Notable Dates: 6/12/2019 NPRM published 7/12/2019 30-day comment period ended ~200 substantive public comments received & reviewed 11/1/2019 regulations published 7/1/2020 most regulations effective 7/1/2021 remaining provisions effective

12 New Recognition Process

13 Scope of Recognition - Definition Scope of recognition (scope): the range of accrediting activities for which ED recognizes an agency ED may limit an agency's scope for Title IV, HEA purposes ED s scope designation defines recognition granted based on coverage of 1) Types of degrees and certificates 2) Types of institutions and programs 3) Types of preaccreditation status, if any 4) Accrediting activities related to distance education 5) Accrediting activities related to correspondence courses

14 New Recognition Process Accrediting experience ( 602.12) Prior to submitting an initial recognition application, an agency must demonstrate that it has granted accreditation or preaccreditation to at least 1 institution (for an institutional accrediting agency) 1 program (for a programmatic accrediting agency) must cover the range of the specific degrees, certificates, institutions, and programs for which it seeks recognition must be in the geographic area for which it seeks recognition must have conducted accrediting activities for at least 2 years prior to application includes decisions on granting or denying accreditation/preaccreditation Exception: if the agency seeking initial recognition is affiliated with or a division of a recognized agency

15 New Recognition Process Accrediting experience ( 602.12) A recognized agency seeking an expansion of scope: must follow the requirements of 602.31 and 602.32 must have engaged and show support for expansion from relevant constituencies must show that it has policies in place to meet the recognition criteria includes covering the range of the specific degrees, certificates, institutions, and programs for which it seeks the expansion of scope A change to an agency's geographic area of accrediting activities does not constitute an expansion of the agency's scope of recognition must notify ED of this change must publicly disclose it on its website

16 New Recognition Process Accrediting experience ( 602.12) If an agency cannot demonstrate experience in making accreditation/ preaccreditation decisions under the expanded scope at the time of its application or review, we may limit the number of institutions or programs* for which an agency may grant accreditation under the expanded scope for a designated time period (*as applicable - institutional or programmatic accrediting agency) require a monitoring report regarding accreditation decisions made under the expanded scope

17 New Recognition Process Purpose and organization ( 602.14) 4 categories of ED-recognized accrediting agencies: 1) A State agency that accredits IHEs, higher education programs, or both as its principal purpose has been listed by ED as a nationally recognized accrediting agency on or before 10/1/1991.

18 New Recognition Process Purpose and organization ( 602.14) 4 categories of ED-recognized accrediting agencies: 2) An agency that Has a voluntary membership of IHEs Has as a principal purpose the accrediting of IHEs and uses that accreditation to provide a link to Federal HEA programs -and- Satisfies the separate and independent requirements

19 New Recognition Process Purpose and organization ( 602.14) 4 categories of ED-recognized accrediting agencies: 3) An agency that Has a voluntary membership; and Has accreditation of IHEs or programs as its principal purpose, and the accreditation it offers is used to provide a link to non-HEA Federal programs in accordance with 602.10.

20 New Recognition Process Purpose and organization ( 602.14) 4 categories of ED-recognized accrediting agencies: 4) An agency that, for determination of Title IV, HEA program eligibility has voluntary membership of individuals participating in a profession or- accredits programs within institutions that are accredited by another nationally recognized accrediting agency as its principal purpose and- Satisfies separate and independent requirements or obtains a waiver of those requirements

21 Accreditation Standards

22 Accreditation Standards Accreditation and preaccreditation standards ( 602.16) The agency must demonstrate that it has standards for accreditation (and preaccreditation, if offered) standards must be rigorous enough to ensure that the agency is a reliable authority regarding the educational quality provided by institutions or programs it accredits includes various requirements

23 Accreditation Standards Requirement: Agencies must establish clear expectations for accredited institutions/programs: with respect to student achievement relates to the institution's mission may include different standards for different institutions/programs, as established by the institution

24 Accreditation Standards Examples of factors to consider: State licensing examination scores Course completion Job placement rates Curricula Faculty Facilities, equipment, and supplies Fiscal and administrative capacity Student support services Recruiting and admissions practices Academic calendars, catalogs, publications, grading, and advertising Measures of program length and objectives of the credentials offered Record of student complaints received by, or available to, the agency Record of HEA Title IV compliance with the institution s program responsibilities o student loan cohort default rate data provided by ED o audit or program review results o other information that ED provides to the agency

25 Accreditation Standards 602.16 Accreditation and preaccreditation standards. Preaccreditation standards must-- Be appropriately related to the agency's accreditation standards; and Not permit the institution or program to hold preaccreditation status for more than 5 years before a final accrediting action is made Agencies may exempt institutions that do not participate in Title IV, HEA programs from standards described in paragraph (a)(1)(x). If an institution is not participating in Title IV programs, there would not need a review of compliance for Title IV responsibilities. Under such circumstance, the accreditation or preaccreditation must specify that the institution s requested that its accreditation not include Title IV, HEA program participation.

26 Accreditation Standards 602.16 Accreditation and preaccreditation standards If an agency only accredits programs and is not an institutional accrediting agency for any of those programs, its accreditation standards must address the type and level of the program rather than the institution. The agency s standards must effectively address (and it must evaluate) the quality of an institution's distance education, correspondence courses, or direct assessment education in the applicable areas.

27 Accreditation Standards Other noteworthy information: An agency is not required to have separate standards, procedures, or policies for the evaluation of distance education or correspondence courses. If not an institutional accrediting agency, an agency would not be required to prescribe to standards that are relevant to Title IV, such as (a)(1)(viii) and (a)(1)(x). An agency may establish additional accreditation standards.

28 Accreditation Standards Agencies may: involve members in setting standards for institutions/programs seeking agency review apply accreditation standards to institutions/programs that seek agency review allow an institution to develop and use institutional standards to show success with student achievement, which achievement may be considered as part of any accreditation review have separate standards for instructors teaching dual enrollment, concurrent enrollment, or career and technical education courses, if the agency determines that the instructors qualify based on education or work experience have separate standards for curriculum approval to more effectively meet the recommendations of-- o Widely recognized industry standards and organizations o Credentialing or other occupational registration or licensure o Industry advisory boards that include employers who hire program graduates o Employers in a field or occupation, in making hiring decisions

29 Recognition Criteria

30 Recognition Criteria Agencies will respond to criteria that are relevant for the type of agency that they are (institutional, programmatic). Guidance will be provided through memo from the Director of the Accreditation Group. Direct specific questions to your analyst.

31 Implementation

32 Implementation Items to note: Agencies that submit petitions before July 1, 2020 will submit under the current focus review and regulations. Once implemented, agencies may petition ED staff to review under new regulations if the review would provide a more favorable compliance outcome. The June 30, 2020 final analysis publication date for the Summer 2020 NACIQI meeting allows agencies currently working toward initial recognition to be reviewed under the current regulations, instead of starting over in demonstrating compliance with the new regulations. ED will review an agency seeking initial recognition that would be reviewed at a meeting after that time under the new regulations.

33 Implementation Items to note: ED will delay the 180-day agency response period in regulation at 602.32(g)(3) for implementation until January 1, 2021. ED will delay staff observation activities at 602.32(d)(1)(i-iii) until July 1, 2021.

34 Implementation Items to note: ED will modify the e-Recognition system to accommodate the new regulations and processes The first petition the system could accept under the new regulations and processes would be Sept. 2020.

35 Implementation Items to note: ED established Sept. 2020 as the due date for the agencies scheduled for review at the Summer 2022 meeting. ED staff will notify an agency of a significant deficiency when found and would not wait for the draft staff analysis.

36 Accreditation Regulations

37 Accreditation Regulations Encourage institutions to fairly evaluate the merit of transfer credits and prior learning assessment reduce the need for students to take/pay for classes twice Allow for different methods of monitoring institutional success, based on the institution s mission and the goals of its students Provide flexibility for agencies to support innovation, recognizing risk, and monitoring the innovation carefully to intervene when student success is at risk

38 Accreditation Regulations Engage employers more directly in the program quality evaluation Allow for institutional decision-making models that give employers a more prominent role in recommending program or curriculum updates Provide opportunities for agencies to increase accountability standards Provide appropriate time for institutions to make changes to meet accountability standards

39 Accreditation Regulations Allow agencies to take earlier action: require struggling institutions to submit teach-out plans of permit teach-out agreements before a school announces a closure Reduce credential inflation, especially in programs that lead to State license, to allow low-income students an opportunity to pursue those occupations Ensure that the cost of qualifying for work does not exceed likely earnings Reduce the time and complexity for approving an agency s initial or renewal recognition application

40 Questions? Recognition of Accrediting Agencies: Herman Bounds: Elizabeth Daggett: State Authorization: Scott Filter: Sophia McArdle: Other Provisions: Barbara Hoblitzell: Annmarie Weisman: annmarie.weisman@ed.gov or (202) 453-6712 herman.bounds@ed.gov or (202) 453-7615 elizabeth.daggett@ed.gov or (202) 453-6190 scott.filter@ed.gov or (202) 453-7249 sophia.mcardle@ed.gov or (202) 453-6318 barbara.hoblitzell@ed.gov or (202) 453-7583 *TDD/TTY: (800) 877-8339