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

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Implementing the Accreditation Provisions in the Higher Education

Opportunity Act 2008 – Part I

Ellie A. Fogarty – Vice PresidentBarbara Samuel Loftus – Vice President

Debra G. Klinman – Vice PresidentMSCHE 2010 Annual Conference

Middle States Commission on Higher Education 1

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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


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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.


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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?


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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


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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


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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


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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 complianceMiddle States Commission on Higher Education 8

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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


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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.”


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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

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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.”


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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


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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


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Questions?


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Implementing the Accreditation Provisions in the Higher Education

Opportunity Act 2008 – Part II

Ellie A. Fogarty – Vice PresidentBarbara Samuel Loftus – Vice President

Debra G. Klinman – Vice PresidentMSCHE 2010 Annual Conference


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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


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Substantive Change Overview

• Definition of Substantive Change

• Prior Approval for Changes Required

• Relationship between Regional Accreditors and US Department of Education


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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


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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


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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


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July 1, 2011 Provisions

• State authorization • Misrepresentation• Incentive compensation• Gainful employment (in progress) • Credit hours


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State Authorization

• States must authorize Title IV eligibility

• Accreditation may serve as proxy

• States must act on complaints


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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


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Incentive Compensation

• No incentives to anyone based on securing enrollments or awarding financial aid

• Includes recruiters, admissions staff, presidents, athletic staff

• No “safe harbors”


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Gainful Employment (in progress*)

“educational program that prepares students for gainful employment in a recognized occupation”

• New programs – USDE notification/approval– Need and wage analysis– How developed– Accreditation and State

approval

• Disclose information on website, including– Graduation rates– Placement rates– Median loan debt


*Eligibility for student aid – Final regulations in progress, to be implemented July 1, 2012

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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 USDEMiddle States Commission on Higher Education 27

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HEOA 2008 ResourcesUS Dept of Education

http://www2.ed.gov/about/offices/list/ope/policy.htmlhttp://www2.ed.gov/policy/highered/leg/hea08/index.html

Council for Higher Education Accreditation

http://www.chea.org/Government/index.asp#FedUpdate


http://www.msche.org/


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Questions?


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