Understanding Federal Compliance Expectations for the Periodic

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Understanding Federal Compliance Expectations for the Periodic Review Report

Debra G. Klinman, PhD Ellie A. Fogarty, EdD Lisa Marie McCauley, EdD, CPA 1

Overview

• Accreditation and Federal Compliance – Past, Present, and Future (Emerging Issues) • Current Expectations – Certification Statement – Areas of Review – Additional Resources • Procedures for Submission and Review Middle States Commission on Higher Education 2

Accreditation and Federal Compliance

Middle States Commission on Higher Education 3

Past

• Accreditation developed and evolved throughout the early 20 th century to promote mission-centered, continuous quality improvement through self-appraisal and peer review Middle States Commission on Higher Education 4

Past

• HEA 1965 (with subsequent re-authorizations, including 2008) directed accreditors to serve as gatekeepers for institutional access to federal financial aid (Title IV) • Verification of compliance with federal regulations became an ever-increasing part of the accreditation process Middle States Commission on Higher Education 5

Present

• Federal financing has ballooned alongside rising institutional costs and cutbacks in state and local funding • Accreditors continue to focus on quality improvement; the Department of Education sees the primary purpose of accreditation as safeguarding federal funds and ensuring institutional accountability Middle States Commission on Higher Education 6

Present

• HEOA 2008 formalized compliance verification by accreditors in four specific areas (distance & correspondence education, transfer of credit, credit hours, and cohort default rate) • MSCHE verification procedures are now part of all accreditation reviews (Self-Study and PRR) Middle States Commission on Higher Education 7

Future (Emerging Issues)

• Next HEOA re-authorization is likely to be postponed until 2014 - 2015 • National voices include NACIQI (October 2011), ACE National Task Force on Institutional Accreditation (June 2012), Obama administration (State of the Union, February 2013) Middle States Commission on Higher Education 8

Future (Emerging Issues)

• Ideas that have been discussed include: – Eliminating or modifying the link between accreditors and institutional eligibility for Title IV – Instituting ‘baseline’ quantitative performance measures to be monitored by the federal government – Differentiating accreditation procedures by mission (sector, profit vs. non-profit) and ‘risk’ (prior history of performance and stability) Middle States Commission on Higher Education 9

Future (Emerging Issues)

• • Ideas that have been discussed include: – Emphasizing measures of ‘value, affordability, and student outcomes’ in determining access to federal aid (value = students’ ability to get jobs and pay off student loans) – Developing an ‘alternative pathway’ for access to federal financial aid for innovative models of higher education (i.e., competency-based learning, MOOCS) The national dialog will continue in the months and years to come.

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Current Expectations

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Certification Statement

• • • Institutions affirm compliance with federal Title IV requirements including: – Distance and correspondence education (student identity verification) – Transfer of credit – Title IV cohort default rate – Assignment of credit hours Signed by CEO and Board Chair Documentation reviewed by peer compliance reviewers Middle States Commission on Higher Education 12

Middle States Commission on Higher Education 3624 Market Street, Philadelphia, PA 19104-2680 Phone: 267-284-5000 Fax: 215-662-5501 www.msche.org Certification Statement: Compliance with MSCHE Requirements of Affiliation and Federal Title IV Requirements Effective October 19, 2012

____________________________________________________________________________ (Name of Institution) is seeking

(Check one)

: ___ Initial Accreditation ___ Reaffirmation of Accreditation through Self Study ___ Reaffirmation of Accreditation through Periodic Review An institution seeking

initial accreditation

or

reaffirmation of accreditation

must affirm that it meets or continues to meet established MSCHE Requirements of Affiliation and federal requirements relating to Title IV program participation, including the following relevant requirements under the Higher Education Opportunity Act of 2008:     Distance education and correspondence education (student identity verification) Transfer of credit Assignment of credit hours Title IV cohort default rate

This signed certification statement must be attached to the executive summary of the institution’s self study or periodic review report.

The undersigned hereby certify that the institution meets all established Requirements of Affiliation of the Middle States Commission on Higher Education and federal requirements relating to Title IV program participation as detailed on this certification statement. If it is not possible to certify compliance with all requirements specified herein, the institution must attach specific details in a separate memorandum. ___ Exceptions are noted in the attached memorandum

(Check if applicable)

__________________________________________ (Chief Executive Officer) __________________________________________ (Chair, Board of Trustees or Directors) _______________________ (Date) _______________________ (Date) 13

Distance and Correspondence Education

• Distance Education – Instruction delivered via technology – Regular student/faculty interaction • Correspondence Education – Instructional materials delivered, mail or email – Student initiated interaction as needed Middle States Commission on Higher Education

Student Identity Verification

• HEOA 2008: How do institutions verify student identity in distance or correspondence education courses?

– – – – – Secure username and password Proctored exams New technologies Protection of student privacy Notification of student fees at registration Middle States Commission on Higher Education

Verification of Compliance

Institutions submit the following along with their Periodic Review Reports: Distance or Correspondence Education Methods used to consistently verify student identity, protect student privacy, and notify students about cost Middle States Commission on Higher Education 16

Transfer of Credit

• HEOA 2008: How do institutions publicly provide the following to students?

– Criteria for Transfer Decisions – List of Articulation Agreements Middle States Commission on Higher Education

Verification of Compliance

Institutions submit the following along with their Periodic Review Reports: Transfer of Credit Publicly disclosed policies and procedures for the transfer of credit and a list of all articulation agreements Middle States Commission on Higher Education 18

Credit Hours

• • • Measurement of academic work AND economic metric Federal definition is consistent with the Carnegie Unit State credit hour regulations, consistent with the federal credit hour definition, may be sufficient evidence of compliance Middle States Commission on Higher Education

Credit Hours

• HEOA 2008: How does the institution ensure that its credit hour policies align with federal criteria? Does the institution’s assignment of credit hours conform to commonly accepted practice in higher education? Middle States Commission on Higher Education

Verification of Compliance

Institutions submit the following along with their Periodic Review Reports: • • • Assignment of Credit Hours Policies and procedures for assigning credit hours to all types of courses & programs Evidence that credit hours are accurately and reliably assigned A list of the courses & programs that differ from the federal definition of ‘credit hour’ with evidence that they conform to commonly accepted practice in higher education Middle States Commission on Higher Education 21

Title IV Cohort Default Rate

• • • The percentage of students in a given fiscal year who cannot repay federal loans Each year, the US Department of Education calculates and publishes the average rate HEOA 2008: Is the institution’s 3-year cohort default rate within the federal limit?

Middle States Commission on Higher Education

Verification of Compliance

Institutions submit the following along with their Periodic Review Reports: Title IV Cohort Default Rate Documentation from USDE of the institution’s cohort default rate, audits of federal programs (A-133) for the past 3 years, relevant correspondence and institutional responses Middle States Commission on Higher Education 23

Resources

US Dept. of Education http://www2.ed.gov/about/offices/list/ope/policy.html

http://www2.ed.gov/policy/highered/leg/hea08/index.html Official Cohort Default Rates for Schools http://www2.ed.gov/offices/OSFAP/defaultmanagement/cdr.html

MSCHE Verification of Compliance with Accreditation Relevant Federal Regulations: Initial Implementation for Spring 2013 http://www.msche.org/documents/ComplianceCriteriaSpring2013.pdf Middle States Commission on Higher Education 24

Procedures for Submission and Review

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Institutions

• • The Compliance Documents should be contained in one PDF file that is indexed / bookmarked by each of the four compliance areas.

PRR Institutions will upload documents to: www.MSCHE.org/MyCHE • Submission upload is required by June 1 st same as PRR.

Middle States Commission on Higher Education

Peer Compliance Reviewers

• Peer Compliance Reviewers will use the information to prepare their report on the institution’s compliance.

• Peer Compliance Reviewers will upload their report of compliance verification by July 15th.

Middle States Commission on Higher Education

Institutions & PRR Reviewers

• The institution can review and respond to any non-compliance issues noted, by August 15 th .

• The PRR Reviewers will consider any additional response from the institution in the preparation of the Confidential Brief to the Commission. Middle States Commission on Higher Education

Questions?

• • • [email protected]

[email protected]

[email protected]

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