[[Additional support for this comes from:  

Joe Daniel Walters, Indicators of Quality Obtained from an Analysis of Southern Association Accreditation Team Visits to Selected Public Junior Colleges (University of Florida, 1970, unpublished dissertation).

Based on 191 Southern Association accreditation reports covering 126 public junior colleges over 1960-1969, Walters found the “Academic preparation” requirements for faculty to have “the greatest frequency for any single recommendation.”

Significantly, “The qualifications of faculty members received the greatest emphasis in total recommendations.” Specifically, compliance with the following minimum quantitative standard was lacking: “Faculty members must have a graduate major – at least 18 hours – in academic teaching areas.” (page 78, Table 7 on page 79)

It is, therefore, not inaccurate to state that, to the extent that others have inquired into the levels of academic preparation for junior or community college faculty, they have *all* found that formal compliance with the ‘best practices’ faculty standard to be a major problem, if not the *biggest* compliance problem confronting those institutions accredited by the Southern Association. ]]

Quite recently, the state of Florida was surprised to learn that it has significant faculty credentialing problems that threaten its ambitious plans to accelerate the accumulation of college credits by students. A statewide survey of postsecondary adult vocational programs (PSAV) that was completed Summer 2005 gave details on more than 250 local and regional articulation agreements that allow "students with school district career education certificates to receive [college] credit in associate degree programs." The survey also showed that "each of the 28 community college regions [in Florida] has a locally determined Tech Prep agreement that allows high school students to gain credit at the community colleges in a planned sequence of courses." There is, as well, the Applied Technology Diploma (ATD) program which is "intended to guarantee transfer between PSAV programs and associate degrees."

However, even though the ATD program has been underway for 5 or 6 years, "[t]he building blocks for PSAV to associate degree articulation are not all in place. ... Probably the most challenging issue facing articulation at all levels is accreditation and the associated faculty credentialing required by SACS. Individual colleges are responsible for ensuring that faculty from the sending institution [i.e., vocational or tech school] are credentialed at the same level as the college faculty for that program level. For articulation into associate degrees, the PSAV faculty must have a bachelor's degree in [the teaching] field or an AAS/AS in field with associated work experience. Because of the limited availability of PSAV instructors with these credentials, the school districts are usually unable to meet this requirement."

“To further complicate the issue,” the report noted, “AS degrees that articulate into BS degrees require faculty credentialed at the university transfer level of a master’s degree with 18 graduate hours in the field.” The report concluded by saying that "more formal discussions with SACS will be required to better address the faculty credentialing challenge."

This lack of effectiveness of the SACS faculty guideline is also reflected in the following provision of the Florida Administrative Code for ATD college credit transfer program [FAC 6A-10.024(7)(c)]: “All faculty providing instruction must have at least an associate degree in the specific instructional program area or meet the criteria for ‘exceptional cases’ as defined by the Southern Association of Schools and Colleges [sic].” There are, of course, no “exceptional cases” mentioned in SACS’ Principles of Accreditation.

FHEAP's own study of Florida's "accelerated degree" programs reveals similar widespread faculty credentialing problems.[5] “Articulation Agreements” typically govern faculty compliance issues for community college / district public school system “dual enrollment” programs. Our preliminary review of these contracts shows that they generally fail to explicitly state faculty preparation requirements, and this should be of concern to both the Secretary and SACS, given the rapid growth of participation in these programs. According to the Florida Department of Education, the number of dual enrollment courses taken by public school students has increased 49.18 percent from 1998-1999 to 2002-2003 (71,843 in 1998-1999 to 107,174 in 2002-2003).

In addition, an analysis of dual enrollment courses at Panama City public schools was conducted in 2004 and showed that nearly 50% of the faculty were non-compliant with the putative standard. This comprehensive study, which is believed to be the first of its kind, matched complete dual enrollment rosters with faculty transcripts in order to give an accurate overall picture of dual enrollment faculty preparation deficiencies.

Nor is Florida alone with these problems. Kentucky’s Council on Postsecondary Education has indicated similar problems in that state regarding dual enrollment: “Another problem is … accreditation requirements. … If high school teachers offer these courses, they may not possess the advanced degrees that the Southern Association for Colleges and Schools [sic] requires for faculty in accredited institutions.”

In all these cases, the same pattern of faculty non-compliance is evident. Thus, the data at the community college level regarding the academic preparation of faculty points overwhelmingly to a lack of compliance, and the generalized ineffectiveness of SACS’ so-called faculty “guidelines.”

Sources: Van D. Miller, The Specific Criteria Cited Most Often by Visiting Committees to Level I. Institutions (Baylor University Doctorate Dissertation, December 2000); Florida DOE, Standing Committee on Postsecondary Transition, Articulating Coordinating Committee, October 19, 2005 Meeting, Item 13, Discussion of PSAV to AAS/AS Articulation Process, pages 23-27; Florida Administrative Code [FAC 6A-10.024(7)(c)]; FHEAP, March 26, 2004 “Sec. 602 Complaint” submitted to US DOE/OPE. Kentucky CPE, P-16 Council Agenda Item E-3, Dec 11, 2001, page 6, last sentence.

Finding # 4

34 CFR 602.16(a)(1)(viii) specifies standards accrediting agencies are to have in order to be recognized by the Secretary that pertain to measures of program length.

Regarding its findings concerning SACS’ measures of program length, the Office of the Inspector General had this to say:

We found that neither regional agency had a definition of a credit hour that it required its institutions to follow. The standards these regional agencies applied to program length were vague and without definition, effectively allowing institutions to establish their own standards.[6]

Standards of program length are especially important because, according to Carter, they are “the basis on which students receive student financial aid.”

Especially troublesome is the OIG’s finding that SACS was “effectively allowing the institutions to establish their own standards” for measures of program length, since the regulations clearly state that this is the responsibility of the accrediting agency [34 CFR 602.16(a)], and not the participating institutions.

According to DOE/OIG, SACS' informal standard for a three-credit semester course is three one-hour classes each week for a full semester, between 20 to 22 weeks long. Assuming a 50 minute instructional hour, this standard gives a range of 50 to 55 hours per three-credit semester long course.

But this is not consistent with the requirements of the Florida Administrative Code (FAC) 6A-10.033(1)(a), which defines a postsecondary credit to be "the equivalent of fifteen (15) fifty-minute periods of classroom instruction," or 12.5 hours per credit. For a three-credit course, this would be 37.5 hours. Needless to say, this calculation indicates that community colleges in the Florida system are only providing between 68% and 75% of SACS informal measurement of program length standard, and this may also mean that the Federal government is only getting close to 70% of what it is actually paying for under HEA Title IV, Part A.

As a result of their findings, the Office of the Inspector General made recommendations to SACS about improving the guidance provided institutions regarding measures of program length (ED-OIG/A09-C0018, page 6).

Sources: “Southern Association of Colleges and Schools, Commission on Colleges’ Accreditation Standards for Student Achievement and Program Length,” ED-OIG/A09-C0018; January 17, 2003, pages 1-16. Florida Administrative Code [FAC] 6A-10.033(1)(a).

Finding # 5

34 CFR 602.18(a) states that accrediting agencies "must consistently apply and enforce its standards … [and] meets this requirement if the agency (a) Has effective controls against the inconsistent application of the agencies standards …”

Given the evidence presented in Finding #3, it should be clear that SACS’ faculty requirements are not being consistently applied in the administration of Florida’s PSAV and dual enrollment programs. Similarly, consistent application of faculty standards has been haphazard at best in SACS’ Level I. Institutions in the South.

Likewise, since (by definition) faculty preparation requirements vary according to the institution and the individual faculty member, the consistent application and enforcement requirement cannot be guaranteed.

There are similar problems due to the deficiencies noted in Finding #1 (pertaining to student achievement standards) and Finding #4 (measures of program length) that effectively allow the institutions to establish their own standards, as was noted by the OIG, and further indicates the lack of required “effective controls” against the inconsistent application of agency standards.

Documentation: Florida DOE, Standing Committee on Postsecondary Transition, Articulating Coordinating Committee, October 19, 2005 Meeting, Item 13, Discussion of PSAV to AAS/AS Articulation Process, pages 23-27. Van D. Miller, The Specific Criteria Cited Most Often by Visiting Committees to Level I. Institutions (Baylor University Doctorate Dissertation, December 2000). Credential Guidelines of the Faculty subsection, Section III of the Comprehensive Standards, Principles of Accreditation (SACS December 2001), pages 8 and 25.

Finding # 6

34 CFR 602.18(b) states that "The agency must consistently apply and enforce its standards to ensure that the education or training offered ... is of sufficient quality ... The agency meets this requirement if the agency .... (b) Bases decisions regarding accreditation and preaccreditation on the agency's published standards."

In terms of faculty preparation requirements (see Finding #2), decisions regarding accreditation cannot be based on the published standards because SACS delegates this responsibility to the individual institution. Thus, the requirement that the agency base its decisions on "published standards" is not met.

Furthermore, according to the OIG (see Finding #4), SACS lacks quantitative measures for program length. Consequently, accrediting decisions about measures of program length cannot be based on "published standards," since none are specified in the Principles of Accreditation. The same deficiency pertains to the student achievement standard, since, as the OIG noted (see Finding #1), SACS allows this standard to be established by the individual institution.

Documentation: SACS Letter of August 8, 2004, and OIG report ED-OIG/A09-C0018.

Finding # 7

34 CFR 602.18(c) states that accrediting agencies "must consistently apply and enforce its standards … [and] meets this requirement if the agency … (c) Has a reasonable basis for determining that the information the agency relies on for making accrediting decision is accurate.”

Given the widespread deficiencies in Florida’s dual enrollment and PSAV programs, and its Level I. Institutions, presented in Finding #3, as well as the related problems with the Florida Administrative Code, it is clear that the information upon which the agency relies for making its accrediting decisions is insufficient or otherwise incomplete.

Documentation: Florida DOE, Standing Committee on Postsecondary Transition, Articulating Coordinating Committee, October 19, 2005 Meeting, Item 13, Discussion of PSAV to AAS/AS Articulation Process, pages 23-27. Van D. Miller, The Specific Criteria Cited Most Often by Visiting Committees to Level I Institutions (Baylor University Doctorate Dissertation, December 2000). FAC 6A-10.024(7)(c) and FAC 6A-10.033.

Finding # 8

34 CFR 602.21(b)(1) states that "the agency must ensure that its program of review (1) is comprehensive.”

In the preceding Findings, deficiencies were found in meeting the standards requirements (602.16), as well as their application (602.18) in the areas of student achievement, faculty preparation requirements, and measures of program length. As a consequential matter, these deficiencies not only problematize consistent application requirements, but institutional monitoring (602.19), and enforcement (602.20) as well, since subsequent enforcement responsibility has been relinquished to the individual institution. Further, as a result of these deficiencies, according to the OIG, “SACS may have limited ability to take enforcement action when institutions’ programs have not demonstrated student achievement or when the program length is questionable.” This situation is suggestive of deeper organizational problems within SACS, especially in the area of standard review. In the very least, the evidence that has been presented here indicates that the requirement that SACS’ standards review be “comprehensive” is not met.

Similar conclusions can be drawn from the recommendations made by the Office of the Inspector General for consideration as part of SACS’ standards review process in the future. The implication here, of course, is that a truly “comprehensive” standards review process would have already addressed the deficiencies indicated.

Documentation: “Southern Association of Colleges and Schools, Commission on Colleges’ Accreditation Standards for Student Achievement and Program Length,” ED-OIG/A09-C0018; January 17, 2003, page 2.

Finding # 9

34 CFR 602.23(c)(1) states that "The accrediting agency must -- (1) review in a timely, fair, and equitable manner any complaint it receives against an accredited institution or program that is related to the agency's standards or procedures."

However, this is not always the case. In a letter to SACS, John Barth of the Office of Postsecondary Education/DOE, wrote that SACS' response to our initial complaints about an institution, "simply dismissed the complaint ... [but] did not provide any evidence that SACS had evaluated whether the institution in question was actually in violation of SACS standards or not," reminded SACS of its responsibilities, and requested a "full and documented response to the complaintant's allegations."

Therefore, based on our experience, SACS is averse to the "timely, fair and equitable" review of complaints against institutions, and must be prompted by the department to fulfill its regulatory obligations.

Documentation: John Barth, letter to SACS, dated July 15, 2004.

Finding # 10

34 CFR 602.25 specifies the "due process" provisions necessary for recognition as an accrediting agency by the Secretary. In the past, SACS has had problems consistently applying its due process policies and procedures, resulting in significant legal challenges in Federal District Court (Georgia).

In the lawsuit brought against SACS by Auburn University, the Federal Judge sided with the university, citing SACS' failure to abide by its due process procedures to provide "for meaningful notice and opportunity to be heard." The Federal Judge also limited the scope of SACS investigative activities to legitimate accrediting issues, referring to "the appearance of partisan inclinations that might be inferred from the beginning of the investigation."

Problems of this nature are of especial concern, insofar as they may be indicative of generalized organizational weakness, such as staffing and training problems, or problems with the due process procedures themselves. Needless to say, this unfortunate episode should not have occurred in the first place, and raises the question of what the judge called SACS' "partisan inclinations," or lack of impartiality, and how this might be avoided in the future.

Documentation: Auburn University v. Southern Association of Schools and Colleges (Civ. No. 1:01-CV-2069-JOF, January 14, 2002).

This concludes the presentation of our comments regarding the petition of the Southern Association of Schools and Colleges (SACS/COC) for renewal of recognition by the Secretary as an accrediting agency. We want to close by taking a moment to thank Ms. LeBold and the Advisory Committee for the opportunity to participate in maintaining the overall integrity of Higher Education Act, Title IV, Federal student assistance and loan programs.

Sincerely,

Glen S. McGhee, Dir.,

FHEAP