September 24, 2015
Dear CEOs and ALOs:
I am sending this email in response to a few questions about this year’s Annual Report and related letters received by some member institutions. If you still have questions, please do not hesitate to contact me. Several individuals and groups from individual colleges have already phoned in to clear up questions in an expeditious manner; they have reported the phone call was helpful in their process.
Q: We did not get a letter about our Annual Report. Should we be expecting one?
A: No, all the letters to institutions pertaining to the 2015 Annual Report have been sent. Most of the colleges did not receive a letter, as their Annual Report did not trigger an early alert (see below).
Q: Were those letters about the Annual Report considered Commission action letters?
A: They were not. These letters fall under the accreditation practice of periodic monitoring. Federally recognized accreditors are expected to monitor institutional performance in areas that include enrollments, finance, and student success, among others. The annual monitoring does not include all subjects contained in ACCJC standards—only those areas included in the Annual Report (AR) and Annual Fiscal Report (AFR) questions. The ACCJC does not require monitoring letters to be posted by the institution as part of the public accreditation record. The letters are intended for use by the institution.
Q: What is the purpose of the monitoring?
A: ACCJC’s monitoring through the AR and AFR has several purposes, including to:
Inform institutions of the kinds of information being monitored on a regular basis. Provide early alert to an institution (and appropriate parties at the institution) when data reported raises concerns about continuing to meet standards in an identified area. Allow the ACCJC to compile certain data from across the region over multiple years for information to the Commission.
Give comprehensive evaluation teams multi-year data previously submitted to the ACCJC over the evaluation period in question.
Meet federal monitoring requirements for institutions to participate in federal student aid and other linked programs.
Assemble information for use by the institution when preparing self evaluation reports. [More recently:] Be used in reports available to the membership about practices across the region.
Q. Why did letters go out for the Annual Report this year?
A. Letters are sent to colleges about the Annual Report in every year. Some brief background information might be helpful: The AR and AFR have existed as separate reports submitted annually to the ACCJC for about 10 years. Since annual reporting by member institutions began, the ACCJC staff has sent letters to institutions if questions arose from the report responses (or if requested information was not provided). On average, fewer than 10 letters have gone out about the Annual Report each year.
With the Higher Education Act reauthorization in 2008, and subsequent regulatory changes in 2010 and 2011, the U.S. Department of Education has gotten more definitive about how it expects accreditors to monitor member institutions ongoing, and for that monitoring to result in Commission action, if needed. This may affect the number of monitoring letters sent. One of our sister regional accrediting agencies reported that their just-completed monitoring identified more than 10% of member institutions in need of AR-related follow-up.
Q. What determined if an institution got a monitoring letter this year?
A. Over the past three years, the ACCJC has monitored Annual Fiscal Reports using a rubric. Based upon the potential risk factors identified, an institution might be notified of enhanced monitoring, might have their financial materials reviewed by the Financial Review Group, or might be asked to submit additional information. The primary purpose of this notification is to help colleges know that the college financial information they provided in certain areas identified a need for further attention at the institution. Should these circumstances continue, the ACCJC might need to request further information from the institution.
In 2015, letters went to colleges on the basis of Annual Report responses in limited areas: a) if ongoing assessment in courses and/or programs was reported at below 67% of total, or b) if the variation between institution-set standard for job placement rates or examination pass rates and the actual reported rates was greater than 30%. [These numbers were selected after analyzing the composite performance levels reported by all member institutions, and after presentation to the Commission and announcement in public session.] In situations where an institution’s responses met those criteria, the college CEO was presented with the information in a letter that included suggestions for how to further evaluate that information at the institution, along with reasons why these were important areas for an institution to examine. The CEO was informed that under enhanced monitoring, should these circumstances continue, the ACCJC might need to request further information from the institution. Other letters went to institutions about more college-specific questions, or if certain information was not provided by the institution in its AR. For example, institutions which did not provide their institution-set standards for job placement rates or examination pass rates were asked to provide that information by October 15, 2015.
Q. What does enhanced monitoring mean?
A. The term means that the ACCJC staff will be following the institution’s reporting of data in the identified areas. If the conditions that triggered the letter remain unchanged, then the ACCJC staff may ask the institution to provide more information. ACCJC staff work with the college to help resolve any inaccuracies or omissions in the AR or AFR.
The monitoring function doesn’t “catch everything:” the AR and AFR don’t query every aspect of financial, SLO, student achievement or other practices. In addition, the staff use a process for identifying certain levels or information points which will warrant communication to the institution. The identified levels or information points carry no accreditation weight. They are used to give an early alert to institutions that may need such notice (without any Commission action), without contacting every institution.
Q: If we got a letter requesting missing information, will our response go to the Commission?
A: If you were asked for missing information, then your response providing the requested information will make the college’s Annual Report complete. In some instances, additional contextual information was requested, along with the previously missing information. A complete response does not ordinarily go to the Commission for review. However, the response content may trigger a further monitoring notice, and the information provided does become part of the college’s Annual Report data that is provided to comprehensive evaluation teams.
I trust this information is helpful. Please do not hesitate to call if you have any other questions.
Krista Johns, J.D.
Vice President for Policy and Research
Accrediting Commission for Community And Junior Colleges (ACCJC)