Higher Education Opportunity
Act: Implications for the PRR
Ellie A. Fogarty – Vice President
Barbara Samuel Loftus – Vice President
MSCHE PRR Workshop
Middle States Commission on Higher Education
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Overview
• Context and History
• Certification Statement
• HEOA 2008 Accreditation Provisions
Implemented July 1, 2010
• Substantive Change Issues
• HEOA 2008 Accreditation Provisions to be
Implemented July 1, 2011
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Context and History
• 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.
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Context and History
• Today, while accreditors continue to focus on
quality improvement, USDE sees the primary
purpose of accreditation as safeguarding
federal funds.
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Certification Statement
• http://www.msche.org/
– Publications/Forms On-line
• “An institution seeking initial accreditation or
reaffirmation of accreditation must affirm by
completing this certification statement that it meets
or continues to meet established MSCHE
requirements of affiliation and federal requirements
relating to Title IV program participation, including
relevant requirements under the Higher Education
Opportunity Act of 2008 such as those on distance
education and transfer of credit.”
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July 1, 2010 Provisions
• Distance Education
• Transfer of Credit Policy
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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
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Distance Education Programs
• MSCHE-approved Distance Education Programs
– 50 percent or more of the program’s credits are
approved for electronic delivery
– Approved via Substantive Change process
– Listed on Statement of Accreditation Status
– Designated reviewer added to evaluation teams
– New distance education guidelines from MSCHE
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Student Identity Verification Policy
• Applies to Distance and Correspondence
Education Courses and Programs
• Institutions document their processes through
which student identity is verified
– Secure username and password
– Proctored exams
– New technologies
– Protection of student privacy
– Notification of student fees at registration
• Evaluators review compliance
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Transfer of Credit Policy
• Publicly Disclosed Policy
– Students and the public
• Identify Criteria for Transfer Decisions
• List Articulation Agreements
• Institutions certify compliance when
submitting Self Study and PRR materials
• Evaluators review compliance
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Substantive Change Overview
• Definition of Substantive Change
• Prior Approval for Changes Required
• Relationship between Regional Accreditors
and US Department of Education
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Substantive Change Categories
• Change in mission or objectives
• Change of legal status, control, or ownership
• Courses or programs representing a significant
departure from existing offerings
• Programs at a new degree or credential level
• Change from clock to credit hours
• Substantial increase or decrease in the number
of clock or credit hours awarded for successful
completion of a program
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Substantive Change Categories
• Initiation or expansion of distance or
correspondence education wherein 50% or
more credits in a program offered through
alternative delivery
• Establishment of a branch campus
• Establishment of domestic and international
additional locations, including an additional
location acquired from another institution, or
established to provide a teach-out for students
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Substantive Change Categories
• Planned closure or relocation of additional
location or branch campus, or a change in
category
• Institutional closure requiring a teach-out plan
• Initiation of contractual agreement with 25%
or more of an educational program provided
by an unaccredited entity
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July 1, 2011 Provisions
• Final, In Progress, or Pending?
• State authorization
• Gainful employment
• Credit hours
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State Authorization
• States must authorize Title IV eligibility
• Accreditation may serve as proxy
• States must act on complaints
• ACE concerns submitted to US
Department of Education, 3-2-11
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Gainful Employment (in progress*)
“educational program that prepares students for
gainful employment in a recognized occupation”
• New programs – USDE
notification/approval
– Need and wage analysis
– How developed
– Accreditation and State
approval
• Disclose information on
website, including
– Graduation rates
– Placement rates
– Median loan debt
*Final regulations in progress, to be implemented July 1, 2011, if finalized.
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Credit Hours
• Unit of measurement of academic work
• Federal definition consistent with Carnegie
Unit
• “reasonable equivalencies” -- verifiable student
learning outcomes
• Accreditors evaluate reliability & accuracy
• Accreditors must address deficiencies, report
“systematic noncompliance” to USDE
• ACE concerns submitted to USDE, 2-16-11
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HEOA 2008 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
Council for Higher Education Accreditation
http://www.chea.org/Government/index.asp#FedUpdate
Middle States Commission on Higher Education
http://www.msche.org/
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Questions?
• Dear Colleague Letters
– State Authorization
– Credit Hour
http://ifap.ed.gov/ifap/whatsnew.jsp
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