1 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 1

2 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 Middle States Commission on Higher Education 2

3 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. Middle States Commission on Higher Education 3

4 Context and History Today, while accreditors continue to focus on quality improvement, USDE sees the primary purpose of accreditation as safeguarding federal funds. Middle States Commission on Higher Education4

5 Certification Statement – 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.

6 July 1, 2010 Provisions Distance Education Transfer of Credit Policy Middle States Commission on Higher Education 6

7 Distance Education – Instruction delivered via technology – Regular student/faculty interaction Correspondence Education – Instructional materials delivered, mail or – Student initiated interaction as needed Middle States Commission on Higher Education 7

8 Distance Education Programs MSCHE-approved Distance Education Programs – 50 percent or more of the programs 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 Middle States Commission on Higher Education 8

9 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 Middle States Commission on Higher Education 9

10 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 Middle States Commission on Higher Education 10

11 Substantive Change Overview Definition of Substantive Change Prior Approval for Changes Required Relationship between Regional Accreditors and US Department of Education Middle States Commission on Higher Education

12 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 Middle States Commission on Higher Education 12

13 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 Middle States Commission on Higher Education 13

14 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 Middle States Commission on Higher Education

15 July 1, 2011 Provisions Final, In Progress, or Pending? State authorization Gainful employment Credit hours Middle States Commission on Higher Education 15

16 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, Middle States Commission on Higher Education 16

17 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 Middle States Commission on Higher Education 17 *Final regulations in progress, to be implemented July 1, 2011, if finalized.

18 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, Middle States Commission on Higher Education 18

19 HEOA 2008 Resources US Dept of Education Council for Higher Education Accreditation Middle States Commission on Higher Education Middle States Commission on Higher Education 19

20 Questions? Dear Colleague Letters – State Authorization – Credit Hour Middle States Commission on Higher Education 20