1 THE ANATOMY OF A COMPLIANCE CERTIFICATION AT A TRACK B INSTITUTION ALLAN AYCOCK JAN WHEELER www.oap.uga.edu SACSCOC Annual Meeting 2012, Dallas, TX 2 Planning for Compliance Expected Outcomes 3 Participants will take away Critical approach for making strategic decisions about the SACSCOC Compliance Certification process Sample forms, processes, and policies to support those decisions Opportunities for networking with colleagues Outside scope of presentation Preparation for on-site visit QEP development We will address if time allows at end 4 About UGA as a Track B Institution 17 academic schools/colleges; 35,000 students; 10,000 employees; 1700 FT faculty; 400 degree programs; four extended campuses; and . . . proudly decentralized. At your tables . . . 5 Introduce yourselves, including current position and SACSCOC responsibilities Introduce your institution, including date you will submit your Compliance Certification Discuss and report a) b) How many years prior to submission should you start the Compliance Certification process? One? Two? Three? Four? Five? What are the significant considerations for determining when to start? UGA Timeline 6 Spring 2008 Spring 2006 Plan to meet compliance challenges Late spring Su08 2008 Compliance Audit Fall08 Sp09 Su09 Fall09 Sp10 Narrative drafting, editing/system development Assemble teams/ chairs: Compliance Charge Teams Leadership QEP Su10 Sept 2010 Final drafts/approvals Data snapshots Submit CC! SACSCOC orientation of leaders Key Strategic Decisions 7 1. 2. 3. 4. 5. Adopt organizational structure and budget/technical support plan Design work plan for your Compliance Team Envision your final work product Decide on a consistent message Identify specific compliance challenges Please stand up . . . 8 How will you develop your system for Compliance Certification? You will use a vendor solution (e.g., Compliance Assist) You have not decided on a vendor solution or an internally built system You will use internal resources to build your system Strategic Decision #1 – Organizational Structure/Budget/Technical Support 9 Adopt a plan to provide day-to-day oversight of the compliance and QEP processes over a 2 to 3-year period Existing office or a special office dedicated to the process? What budget is available to provide this support? Who will provide the extensive technical support required to produce the Compliance Certification and organize supporting electronic documentation? Organizational Structure 10 UGA Approach Existing Office of Academic Planning managed the process Estimates of time allocated over two years: Associate Provost – 40% Director of Assessment and Accreditation – 50% Associate Director of Accreditation – 100% Assistant to the Associate Provost – 40% Editor for the SACSCOC Reaffirmation Process – all of half-time assignment Two graduate assistants – 50% of half-time assignments Office of Institutional Research made reaffirmation a top priority over two years Technical Support 11 UGA Approach Enterprise Information Technology Services dedicated a team to reaffirmation and added resources as needed Implemented commercial solution to store and manage faculty activity data Designed internal credentialing system to integrate key faculty and course data Designed internal system to manage planning and assessment data Designed internal system to develop the Compliance Certification 12 Two-year budget for the compliance process UGA approach In addition to significant internal allocations of effort from the Office of Academic Planning, the Office of Institutional Research, and the Office of Enterprise Information Technology Services, the following were needed: Half-time editor Printing Supplies Professional meeting expense Software to build Faculty Activity Repository At your tables . . . 13 Given: Compliance Certification requires long-term cooperation and significant labor from senior administrators, faculty, staff, and students? Discuss and report: Who at your campus is best able to lead this effort? a) Senior dean b) Senior faculty member c) Senior administrator d) SACSCOC liaison e) Other 14 Strategic Decision #2 – Your Work Plan Design a detailed work plan that fits the specific needs and culture of your campus Who will lead your teams? How will you structure the teams? How will you manage the work flow? How will the final work product be approved before submission to SACSCOC? Work Plan 15 UGA Approach Expertise—Compliance Team Large group of campus experts in the specific areas addressed by the Principles (n=38) Chaired by former law school dean currently active in university governance Reported to small SACSCOC Leadership Team (chaired by the president) Working groups for areas needing focused attention Time—Team formation and orientation Formal charge to team two years prior to due date of Compliance Certification Work plan—working groups 16 Faculty Credentialing Institutional Effectiveness Advising International Programs Distance Education Extended Campuses Substantive Change Document Review Panel Work Plan—Process 17 Developing compliance narratives Compliance audit (documentation assembly) Drafting process (more documentation) Expert in area or working group Resources and consultation with OAP staff Review process (more documentation) OAP staff, editor, Document Review Panel, Liaison, Leadership Team Final formatting Testing/quality assurance/“slamming the doors” At your tables . . . 18 Possible format(s) for submitting your Compliance Certification: Print only Print and Online Online only Print and USB/CD USB/CD only Online and USB/CD Print, Online, and USB/CD Discuss and report: What does SACSCOC require? (consensus answer, no smart phone use) What will your institution submit? Strategic Decision #3 – Format of your Compliance Certification 19 Begin the process with a design guide for the Compliance Certification What format(s) will it be? What will it look like? How will it function? How will it be transmitted? Goal in all: communicate authority, transparency, thoroughness . . . compliance Compliance Certification—Format 20 UGA approach=everything Submitted a printed, bound, multi-color Compliance Certification USB drive with Compliance Certification and all supporting documents (except Faculty Roster) Online, password-protected access to Compliance Certification and all supporting documents and selected live web sites 21 Compliance Certification—Key Design Elements UGA Approach pdf format for supporting documentation highlighted relevant portion of each supporting document Footnotes Linked in text with hover feature directly to relevant page of document Searchable document Document library Style guide Transmittal? 22 FedEx? UPS? United States Postal Service? Please stand up . . . 23 Proposition: The SACSCOC reaffirmation process brings about substantial, positive changes to the learning environment at institutions. Do you agree? Do most people on your campus agree? Strategic Decision # 4 – Communicating with the University Community 24 Adopt a communication strategy to ensure that your campus views the Compliance Certification process as one that will improve the learning environment. Communicating with campus 25 UGA approach Focused first on improving the learning environment – compliance with the principles will flow from this Highlighted the specific improvements made to policy and practice having long-term benefits, for example Faculty Activity Repository Academic Planning System Online syllabi availability Instructor credentialing process—study abroad faculty, GTAs/GLAs Archive of useful documentation At your tables . . . 26 Discuss and report a) b) What three to five Principles are most challenging to documenting compliance on your campus? What makes them challenging? Strategic Decision #5 – Your approach to the most challenging compliance issues 27 Determine your strategic approach to documenting compliance with Principles known to be stumbling blocks in the reaffirmation process Principles that present unique challenges to your institution 28 Major Compliance Issues: Full time Faculty (2.8) There is no formula for adequacy. How will you make your unique case? What ratios and comparisons will you use? How will you disaggregate the data? UGA approach • • • • • Definition of full-time faculty and categories of faculty Allocation of responsibilities for teaching, research, and service to individual faculty Support structures for faculty activities Case for adequacy to carry out teaching, research, and service at the institutional level • Comparisons of student/faculty ratio with peers • Comparison of class size with peers • Processes to ensure ongoing adequacy (various review processes) Then data at the college level, the department level, and for each extended campus 29 Major Compliance Issues: Full time Faculty (2.8)—continued New Challenge Documenting adequacy at the program level How will you define “program?” Major Compliance Issues: Faculty Credentials for Teaching Activity (3.7.1) 30 How will you establish that every course taught within the relevant time period was taught by faculty qualified to teach that specific course? UGA approach • Established a comprehensive instructor of record policy • Established required credentials policy for instructors of record • Created a credentialing system for ongoing compliance with policies • Created a faculty activity repository using commercial software • Prepared an electronic faculty roster with electronic access to: • Faculty CV • Detailed justification when needed • Official course description and syllabus • Transcript or other evidence of academic qualifications were not available electronically Faculty & Course databases for rank info, list of all courses taught. UGA Bulletin for detailed course info, master syllabus, & individual syllabus Final Product—UGA Faculty Roster 15 FAR—Linked CVs for all faculty Credentialing System—entered by associate dean; also linked to CV Text added directly into Roster by associate dean (cut & paste from CV) Major Compliance Issues: Substantive Change (3.12.1) 32 How will you document that all substantive changes have been identified and reported to SACSCOC? UGA approach • Adopted and communicated internal policy about identifying and reporting substantive changes • Maintained record documenting decision-making process for each potential substantive change • Maintained record of all substantive changes reported to SACSCOC • Presented the policy, the decision making process, and the record in the Compliance Certification Major Compliance Issues: Institutional Effectiveness—Educational Programs (3.3.1.1) 33 Will you use a commercial product or an internally developed solution? Will your Compliance Certification present a representative sample of degree/certificate programs or present all programs? UGA approach • Created Academic Planning System internally • Presented full evidence from a representative sample of programs (assessment plans, student learning outcomes, assessment results, and changes implemented for each program) • Defined “representative” • Plus provided full online access to Academic Planning System (all programs) Resources 34 Additional sample forms and process documents are available at: http://oap.uga.edu/about_oap/anatomy_2012 UGA’s Compliance Certification is open and online at: https://sacs.uga.edu/ (also in the SACSCOC Resource Room) Also consider: Colleagues you have met today Your track cohort Thank you! . . . and good luck! Allan Aycock aaycock@uga.edu Jan Wheeler jwheeler@uga.edu