Understanding Federal
Compliance Expectations for the
Periodic Review Report
Ellie A. Fogarty – Vice President
Debra G. Klinman – Vice President
Middle States Commission on Higher Education
1
Overview
• National Context
• Certification Statement
– Distance Education (Student Identity Verification)
– Transfer of Credit
– Credit Hours
– Title IV Cohort Default Rate
• Resources for Additional Information
Middle States Commission on Higher Education
2
National Context
• Accreditation developed and evolved to promote
mission-centered, continuous quality improvement
through peer evaluation.
• HEA 1965 (with subsequent re-authorizations,
including 2008) named accreditors as gatekeepers
for institutional access to federal funding. Various
regulations have ensued.
• Today, while accreditors continue to focus on
quality improvement, USDE sees the primary
purpose of accreditation as safeguarding federal
funds.
Certification Statement
• Signed by CEO and Board Chair
• Attached to the executive summary of the
Periodic Review Report
• Affirms compliance with
– MSCHE Requirements of Affiliation
– Accreditation-relevant federal requirements
• Student Achievement is documented
through compliance with Standards 8, 11,
12, and 14
Middle States Commission on Higher
Education
5
Distance 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: Institutions must document
how student identity is verified
– Secure username and password
– Proctored exams
– New technologies
– Protection of student privacy
– Notification of student fees at registration
• Peer reviewers evaluate compliance
Middle States Commission on Higher Education
7
Transfer of Credit
• Generally addressed under Standards 8
and 11
• HEOA 2008: Institutions must publicly
document
– Criteria for Transfer Decisions
– List of Articulation Agreements
• Peer reviewers evaluate compliance
Middle States Commission on Higher Education
8
Credit Hours
• Unit of measurement of academic work
• Federal definition consistent with
Carnegie Unit
• HEOA 2008: Institutions must document
that any “reasonable equivalencies” to
federal definition can be verified through
student learning outcomes
• Peer reviewers evaluate compliance
Middle States Commission on Higher Education
9
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
• Institutions must document where they stand
in relation to averages
• Typically the responsibility of the financial aid
office or CFO
• Peer reviewers evaluate compliance
Middle States Commission on Higher Education
10
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
Middle States Commission on Higher Education
http://www.msche.org/
Middle States Commission on Higher Education
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Questions?
Middle States Commission on Higher Education
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