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
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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
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Accreditation
and
Federal Compliance
Middle States Commission on Higher Education
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Past
• Accreditation developed and evolved
throughout the early 20th century to promote
mission-centered, continuous quality
improvement through self-appraisal and peer
review
Middle States Commission on Higher Education
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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
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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
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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
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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
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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
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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.
Middle States Commission on Higher Education
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Current Expectations
Middle States Commission on Higher Education
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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
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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 selfstudy 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)
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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 AccreditationRelevant Federal Regulations: Initial Implementation for
Spring 2013
http://www.msche.org/documents/ComplianceCriteriaSpring2013.pdf
Middle States Commission on Higher Education
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Procedures for Submission
and Review
Middle States Commission on Higher Education
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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 1st same as PRR.
Middle States Commission on Higher Education
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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
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Institutions & PRR Reviewers
• The institution can review and respond to any
non-compliance issues noted, by August 15th.
• 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
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Questions?
• [email protected][email protected][email protected]
Middle States Commission on Higher Education
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