Letter to Membership

September 15, 2016 

Dear ACICS Colleagues:

I am composing this note to you all in my sixth week as Interim President here at ACICS, with some regret for not having written something earlier, along with an encouraging observation, both mine and others, that we are pushing forward with an aggressive review, renewal and reinvention agenda for a markedly strengthened accreditation process. We of course, stand at a critical juncture staring at a potentially devastating set of decisions by the Department of Education, currently approaching the expected deadline for the Senior Department Official (SDO), on or about September 20th, on the denial of continued recognition recommended by the National Advisory Committee for Institutional Quality and Integrity (NACIQI).  At the conclusion of an exhaustive 11 hour meeting on June 23rd, it appeared evident that the decision was pivoting on whether or not a majority of the committee could find the necessary level of confidence that the agency could and would be able to bring itself into compliance with the 21 recognition criteria issues cited in the staff report’s recommendation for denial. The decision did not favor confidence in that outcome. Now we await the judgement of the SDO and if unfavorable, will lead to our appeal to the Secretary.  

These decisions carry forth enormous and complicated implications for this agency and its 300 plus ACICS accredited main campuses with an additional 410 branch campuses and hundreds of thousands of students, many of whom will be impacted in ways large, small and unpredictable with the loss of their school’s status with a USDE recognized accreditor. I cannot offer any sound much less reassuring prediction on whether we will be given a reprieve to offer us the opportunity to demonstrate the work well underway to renew and reestablish ACICS as worthy of recognition; and while I did not seek or readily agree to accept the role I currently hold, I am here, and I intend to do all I can with what I have learned from 25 years of experience. Working with a strong team of capable and committed individuals on the Council and staff has reinforced my belief that when we all keep our focus on student achievement, we can more readily find and accept new ideas and better ways to achieve the high standards for quality and integrity central to our responsibilities as an accrediting agency. With those thoughts in mind here are some of the major changes marking our progress to date: 

ACICS Staff and Council
: ACICS has substantially revamped its senior leadership. Since April 2016, six out of the seven members—the President and five Vice Presidents—of the senior leadership team are no longer with the organization. In addition, ACICS will increase its representation of public individuals and plans to have in place 6 public members on the Council, compared with the three minimum required in the bylaws, effective on January 1, 2017.

: ACICS revised its bylaws to better align electoral influence with the membership’s composition. Specifically, the Council determined that each institution (defined as a main campus) will have a single vote in elections for Council members. This change resulted in a significant decrease in the number of votes allotted to the 15 largest institutions, i.e. from 56 percent of the votes to 23 percent.

Placement Verification Program
: ACICS has moved quickly to a process whereby we confirm every placement, every month for every campus. Our previous practice had been to sample placement information on each on-site evaluation visit. For the August review cycle, we included a Data Integrity Reviewer (DIR) and increased the requirement to attempt confirmation for all placements on an on-site evaluation visit. For the upcoming December 2016 review cycle, we have directed the use of more recent placement information and are verifying the information through the Placement Verification Program (PVP) and by the DIR while on-site. In addition, for the 2017 CAR period (which began on July 1, 2016), we are requiring that all placements are confirmed via ACICS’ PVP system.

Campus Accountability Report
: In addition to the enhanced placement verification process, ACICS is also requiring institutions to submit information that will allow ACICS to calculate a program and campus graduation rate based on the ‘scheduled to graduate cohort.’ ACICS is also requiring all programs with licensure examination pass rates to upload documentation from the oversight agency to verify their rates both in preparation for on-site evaluation visits and for review at the Council to determine whether they meet current standards. 

Admissions/Recruitment Practices
: ACICS has initiated a number of different strategies to strengthen the review of admissions and recruiting practices at institutions: 1) an enhanced Call for Comment Survey that is sent to students prior to the visit with specific questions about admission practices; 2) an enhanced policy in which ACICS reviews the institution’s policy and implementation for monitoring recruitment practices; and 3) the recent utilization of third-party secret shoppers to investigate and provide a report on institutions which the Council has reason to believe are engaged in misrepresentation in its admissions and recruiting practices.

At-Risk Institution Group
: ACICS routinely reviews complaints and external (adverse) information, financial data, student achievement outcomes, extensive enrollment growth and substantive changes, previous visits, and other at-risk measures to determine whether further investigation is necessary. ACICS has conducted 22 on-site special visits since April 2016 (a large majority of which have been unannounced visits) as a result of reviews undertaken by ARIG and has 10 visits currently scheduled over the next two months. ACICS has taken a number of actions as a result of the reviews including show-cause directives and compliance warnings.

Council Action Process:
ACICS has proposed in its current Memo-to-the Field and Call for Comment a simplified and streamlined council action process, so that non-compliant or adverse actions will be taken in a timely manner. Specifically, ACICS has proposed clarification of its actions related to student achievement standards whereby the Council will take an immediate adverse action if a campus or program is significantly out of compliance with little or no chance of coming into compliance in a reasonable period of time. In addition, the Council will issue a probation order if a campus or program is materially below the Council standard (below 50%).

Training: ACICS has revamped the review and selection process for identifying potential evaluators, review board panel members, and commissioners.  In addition, ACICS has implemented a program of re-training all of these individuals on ACICS’ new requirements, initiatives, and conflict of interest policy with respect to their role at the organization. 

Expanded Visit Process and Reports: ACICS has incorporated at-risk information, expanded student and staff surveys, a financial aid checklist, and an expanded DIR process into on-site evaluation visits. In addition, ACICS has revised its report templates to strengthen the focus and substance of its reports in line with these new initiatives in order to provide essential information for the Council’s review.

Initial Applicants:
Prior to the NACIQI meeting, ACICS decided to cease accepting all new Initial Applications in order to focus its compliance initiatives and activities on its currently accredited institutions.

Beginning with the outcomes from the recently completed August 2016 Council meeting, ACICS has posted all denial and show-cause actions on its website along with a copy of the Council’s action letter. 

There is a working partnership in all of this and we all own it. The errors of the past whether intentional or circumstantial, have left their mark and only time and the determination to move forward will carry us through this period; there are no shortcuts. When you make your students’ lives markedly better than they were when they came to your door, you will have demonstrated the difference between a job and a calling. Best wishes.  

Roger J. Williams
Interim President