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Introduction

In June of 2016, one week before the annual National Advisory Committee on Institutional Quality and Integrity (NACIQI) meeting in Washington, DC, staffers in the US Department of Education submitted a “staff report” to the “senior department official on recognition and compliance” recommending that the Department withdraw recognition for the Accrediting Commission of Independent Colleges and Schools (ACICS). One week later, the NACIQI committee members voted 10 to 3 to also recommend that recognition be withdrawn for ACICS. Based on the protocol established for such situations, the NACIQI recommendation triggered a 90-day period, by the end of which, the Department must make a decision on ACICS’ recognition…

Summary

While one can debate the merits of the internal DOE staff and NACIQI recommendations relative to withdrawing recognition for ACICS, the fact that both recommendations are now in play, in a highly politicized environment in which ACICS has many detractors and few advocates, it is likely that the Department will act on those recommendations to deny ACICS’ petition for re-recognition while simultaneously withdrawing its existing recognition. Similarly, the political context in which both the Department and NACIQI made their recommendations is the same context in which other accreditors are currently operating. As a result, there is very little incentive for any accrediting commission to assert itself, even in the interest of helping innocent students, let alone educational institutions, that find themselves at risk of losing accreditation. As such, combined with the “mad rush” of potentially hundreds of institutions jockeying for a place in line, the process of switching accreditors will likely be significantly more difficult and time consuming now than in would have been in the past.

As noted earlier in this paper, a key factor in the present situation facing ACICS and its accredited institutions is the unprecedented nature of the situation combined with the lack of any mechanism to support the scale of the necessary migration of institutions to other accreditors in any identified time frame, let alone 18 months. Similarly, there is no systemic way for addressing the potentially profound impact on innocent students vis-à-vis teach outs, credit transfers, and financial aid…

Relatedly, the Department has previously demonstrated its willingness to allow substantial “collateral damage” to institutions and their students in pursuit of what it articulates as its responsibility to hold what it defines as “bad actors” accountable. If that continues to be the case, it is unlikely that the Department will play any kind of support role during the process of sunsetting ACICS, if in fact, that is the outcome of the Department staff and NACIQI recommendations.

As such, it is likely that the following will occur:

• The Education Department will act to withdraw recognition of ACICS.
• Current ACICS institutions will have to find a new accreditor regardless of a likely ACICS appeal and/or litigation due to the unknown outcome and lengthy application process with another accreditor.
• Some material number of institutions currently accredited by ACICS will not be able to successfully complete the application process with a new accreditor within the 18-month time line (and likely much longer).
• Some material number of institutions currently accredited by ACICS will cease operations due to the negative impact on retention and enrollment, the organizational stress of attempting to find a new accreditor, and/or the ultimate loss of accreditation and Title IV financial aid.
• Some material number of students will be caught in the cross-fire and will be materially harmed as a result of attending a college or university that loses its accreditation and its attendant financial aid and related approvals.

In short, should the Department choose to withdraw recognition for ACICS, in the absence of a thoughtful transition plan that would either allow more than 18 months for institutions to find a new accreditor and/or that provides some sort of transfer of accreditation mechanism for currently accredited institutions that preserves access to Title IV and ancillary approvals by “means of accreditation,” the damage to institutions and potentially hundreds of thousands of students will likely be severe.

In the interim, ACICS accredited institutions should be as proactive and urgent as possible as it relates to pursuing new accreditors, and importantly, as it relates to protecting students with formal teach out and credit transfer agreements should that become necessary. To be clear, these recommendations have nothing to do with the merits, or lack thereof, of the two recent recommendations to withdraw recognition for ACICS. For its part, ACICS strongly believes that it can address and ameliorate identified deficiencies by the middle of 2017. The recommendations stated here are simply based on the realities as they currently present themselves and the concomitant risks to institutions currently accredited by ACICS. Even in the case that ACICS were to prevail in the current crisis, the long-term viability of the organization, as well as the “guilt by association” for some member schools, may be untenable.

Get the full Accreditation White Paper here.

Contact Information

For institutions seeking guidance in addressing the current accreditation challenge, free consultations are available at http://sandgconsult.com/

Phone: 813-874-0110 or (407) 257-8568

Email: msantoro@sandgconsult.com or g@sandgconsult.com