1. Academic Affairs Committee Contingency Plan for Continuing Authorization of ACICS Institutions Dr. Joseph G. DeFilippo September 19, 2016 Academic Affairs

2. SCHEV Academic Affairs Players: –National Advisory Committee on Institutional Quality and Integrity (NACIQI) –U.S. Department of Education (USED) –Accrediting Council of Independent Colleges and Schools (ACICS) –State Council of Higher Education for Virginia (SCHEV) –15 institutions (see addendum) 2

3. SCHEV Academic Affairs Recognition “The Secretary of Education is required by law to publish a list of nationally recognized accrediting agencies that the Secretary determines to be reliable authorities as to the quality of education or training provided by the institutions of higher education and the higher education programs they accredit.” (http://ope.ed.gov/accreditation/)http://ope.ed.gov/accreditation/ Title IV Title IV funds are federal student aid programs administered by USED. They include Direct Subsidized/Unsubsidized Loan, Direct Graduate PLUS Loan, Direct PLUS Loan, Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (SEOG), and Federal Perkins Loan. 3

4. SCHEV Academic Affairs NACIQI, June 23, 2016 Voted 10-3 to accept USED recommendation to remove ACICS’ recognition. Also: –Followed staff recommendation to renew the ABA’s recognition, “but added two additional findings of non-compliance [and] further added a limitation to the agency’s scope of recognition to exclude the accreditation of any new institutions and programs.” –“NACIQI commissioners on Wednesday peppered representatives from the American Psychological Association, a programmatic accreditor, about graduates' debt and repayment levels, which the association does not require its members to submit” (IHE, June 24, 2016) 4

5. SCHEV Academic Affairs Undersecretary of Education Ted Mitchell: The unfortunate reality is that not all institutions have students’ best interests at heart or are investing their resources in ways that maximize student success. Accreditors should be the failsafe in these instances. But too often they have been asleep at the switch. To be clear: I’m not painting all accreditors with same brush. The majority of agencies are working hard to evaluate the quality of their institutions, to celebrate successful schools, to help struggling institutions improve, and where necessary, remove accreditation from institutions that systematically fail their students. However, we know that some are not. The presence of poor players taints the reputation of all accreditors and raises questions about the value of accreditation as a whole – that should be as troubling to the accreditation community as it is to us. And it is why we have a responsibility to act. 5

6. SCHEV Academic Affairs Practical Implications –In Virginia, accreditation by a recognized accreditor is a legal requirement for authorization. – According to USED Title IV regulation, state authorization is a requirement for Title IV eligibility. –Therefore when ACICS’ recognition is withdrawn, institutions will immediately be deemed unaccredited for purposes of both Virginia law and federal regulation. If institutions have state authorization, USED will extend their Title IV eligibility for 18 months. If institutions do not have state authorization, USED will pull their Title IV eligibility immediately. –Final administrative decision about recognition will lie with the US Secretary of Education. This could be rendered virtually any time after September 21 (most likely to occur between November and January 20, 2017). 6

7. SCHEV Academic Affairs The example of ITT Tech Timeline: –August 25: USED imposes stringent new conditions, including posting a $250M letter of credit, and not enrolling new students needing federal aid. –September 6: ITT Tech announces it is shutting down. –September 16: ITT Educational Services files for bankruptcy. Governor and SCHEV responses –Governor’s portal for ITT students: http://governor.virginia.gov/ITT http://governor.virginia.gov/ITT –SCHEV portal: http://www.schev.edu/index/students-and- parents/explore/virginia-institutions/current-advisorieshttp://www.schev.edu/index/students-and- parents/explore/virginia-institutions/current-advisories 7

8. SCHEV Academic Affairs SCHEV Contingency Plan Purpose: to provide institutions with continuing authorization and avoid abrupt and simultaneous loss of Title IV eligibility for multiple institutions. Approach: –Out of State and In-state Certified Institutions: mirror USED 18 month grace period. SCHEV Director has some leeway to extend period of authorization. –Institutions not required to certify: six month initial period during which the executive director will determine precise requirements for getting through the entire 18 month period. 8

9. SCHEV Academic Affairs Questions/Feedback? 9