Accreditation of community colleges in California (plus Hawaii and South Pacific Territories) is by the Accrediting Commission for Community and Junior Colleges (ACCJC). ACCJC is part of the Western Association of Schools and Colleges (WASC).

For the past ten years, ACCJC has issued an extraordinarily high number of sanctions. As documented in the publication "ACCJC Gone Wild" from 2003 to 2008 ACCJC issued 112 sanctions compared to 14 sanctions issued by all the other U.S. accrediting agencies. In 2012 ACCJC performed the once-every-six-years review of 21 colleges, resulting in ten sanctions for a 47% sanction rate. Of the 10 sanctions, the harshest was "show cause" issued against City College of San Francisco (CCSF).


NACIQI PROPOSALS REGARDING ACCREDITATION

There are six regional college accrediting agencies recognized by the US Dept of Education and reviewed by the National Advisory Committee on Institutional Quality and Integrity (NACIQI). In April 2012 NACIQI submitted a report titled "Accreditation Policy Recommendations" to the US Secretary of Education. The proposals will be considered in preparation for the next Higher Education Act, expected in 2014.

The major proposals by the National Advisory Committee on Institutional Quality and Integrity can be summarized as follows:
* continue the link between accreditation and federal financial eligibility
* provide greater accountability and public involvement
* reconsider the regional foundations - should we continue to have six separate regional accreditors?
* encourage more flexibility in review process, distinguishing between strong and weak institutions
* consider having more gradations in status/sanctions
* consider whether there is too much data collection, where the cost outweighs the benefit
* develop consistent and common standardized definitions and metrics
* increase the number of knowledgeable members of the public in accreditation decision making.

The committee considered but voted down (7 to 4) an alternate report which called the accreditation system "broken" and which recommended scrapping it and creating a "consumer friendly expedited alternative".

Given the potential importance of the NACIQI report and the controversy around college accreditation, I wish to convey the experience of one California community college along with some questions and observations.


CASE STUDY: CITY COLLEGE OF SAN FRANCISCO (CCSF)

CCSF was established in 1935. It is the largest community college in California and one of the largest in the US. A few years ago total student enrollment including part-time and non-credit students was about 100,000. Students who transfer into major universities and graduates of CCSF's many technical training programs have a high success rate. CCSF has never previously been sanctioned. The last accreditation review in 2006 resulted in recommendations for improvement but no sanction. In 2007 CCSF was one of a select few featured in a New York Times article on model community colleges.

Along with other colleges in California, CCSF has been hit hard by the recession. With an annual budget approaching $200M, CCSF state funding has been reduced by $53 Million over the last few years.

Beginning in 2008, long time CCSF teacher and psychology department chair, Dr. Don Griffin became the Chancellor. Under his leadership the decision was made to keep cutbacks away from the classroom as much as possible. With greatly reduced state funding, several highly paid administrative posts were not filled after 2010 retirements, some classes were cut and faculty and administration agreed to salary reductions. That was still not sufficient to balance the budget and the college used some of the financial reserves which each college is required to maintain. Still, CCSF financial reserves did not fall below the state mandated minimum reserve.

In March 2012 CCSF was visited by the ACCJC evaluation team. The resulting 66 page Evaluation Report included positive observations, along with criticisms and fourteen recommendations. In July 2012 the Accrediting Commission issued its sanction on CCSF: "City College of San Francisco must show cause why its accreditation should not be withdrawn ...... The burden of proof rests on the institution to demonstrate why its accreditation should be continued."

Given its size and long history in the city, CCSF carries extraordinary local importance. Media coverage on the ACCJC ruling was immediate and sensational. The San Francisco Chronicle reported "City College on the brink of Closure"; major TV news broadcasts were similar.

The ACCJC ruling was not questioned in the mainstream media or by college administration. With no previous sanction, an overwhelmingly positive record and substantial esteem within the San Francisco area, it is a measure of ACCJC's aura that nobody asked whether the "show cause" sanction was appropriate. If a sanction was necessary, should it not be a Warning or at most Probation? "Show Cause" is much more onerous, damaging and likely to lead to public confusion. In the case of CCSF, after the media explosion, tens of thousands of current and potential students were suddenly having to consider whether they needed to find another college or give up the idea of taking classes at CCSF.

The absence of a challenge may have resulted from the changing nature of leadership at the college. In April 2012 the highly regarded Chancellor Griffin was diagnosed to have a brain tumor requiring immediate surgery. The CCSF Trustees appointed an interim Chancellor but she was temporary, from outside and without deep commitment to the college. Several other top administrative positions were still vacant due to cutbacks.

Following the ACCJC ruling, the newly appointed college leadership worked with faculty and campus groups to quickly organize teams tasked with responding to each of the fourteen ACCJC "recommendations".

Over Summer and Fall 2012, media stories about CCSF continued to be negative. The new college leadership did not speak with any confidence about the college's future and did not correct false reports in the media. Enrollment was falling, compounding the financial challenges. It was left to the faculty union, students and members of the public to speak in strong support of the college, to question the actions of ACCJC and to expose false and misleading reports. One of the most damaging reports falsely claimed that faculty had received a 25% salary increase when in fact there had been no raises since 2007 and instead faculty had agreed to salary reductions.

The first interim Chancellor finished her contract and departed. Another outside interim chancellor was hired by the College Trustees. A special trustee with extraordinary authority was appointed. With the college in a condition near shock, coupled with public confusion, major changes were imposed, seeming to abrogate contract agreements. Faculty salaries were cut by 8.8% for the Winter-Spring 2013 semester. The administration seeks to impose a more hierarchical top-down governing structure.

The big news in November 2012 was the city and state election. At state level, Governor Brown's Prop 30 providing more money for education, passed. Meanwhile in San Francisco, supporters of CCSF had Proposition A on the ballot. To support CCSF and its mission, there would be a $79 tax on all property parcels for the next eight years. It passed with 73% voting yes, giving evidence to what the ACCJC Review Team said in its report: "the college has done a superb job of bringing the community college to the varying communities throughout the City and County of San Francisco".

As of this writing, there is contention with the special trustee and interim chancellor seeking to use a significant amount of the money generated by Prop A to replenish the reserve fund rather than the programs specified in the ballot measure.

On March 15, after thousands of hours work and enormous cost, the CCSF teams addressed each of the fourteen ACCJC "recommendations" and delivered the required Show Cause and Closure Report .

ACCJC will make a decision regarding the status of CCSF at its June 2013 meeting.


QUESTIONS & OBSERVATIONS

Following are questions regarding the California accrediting agency.

1. Why does ACCJC issue an abnormally high number of sanctions? What are the costs vs benefits of the harsh public sanctions?

ACCJC claims they are forced to act with harshness by the Dept of Education. For example in December 2012 a story appeared with the headline "Accrediting agency under pressure to be tougher on community colleges". In an earlier press release ACCJC asserted "Under U.S. Department of Education regulations, institutions are expected to resolve noted deficiencies within a two year period or the ACCJC must take action to terminate accreditation."

However, ACCJC claims about federal pressure appear to be exaggerated or untrue. One obvious question is: If the Federal Dept of Education is requiring this kind of harsh accreditation regime, why don't we see the other five US accreditation agencies issuing large numbers of negative sanctions like ACCJC?

One possibility is that California community colleges are significantly inferior to those elsewhere in the country. However that seems unlikely. Much more likely is the possibility that the accrediting agency has established a unique regime .

Implementing changes usually takes time or money or both. The fact that "good cause" was not seriously considered in the case of CCSF and the many other colleges they have sanctioned in the past three years, when community colleges have been under heavy duress due to the huge state funding reductions, speaks volumes to the attitude and priorities of ACCJC. Unlike the UC and CSU university systems, which have substantial portions of their revenue coming from research grants, tuition and other sources, community colleges are almost totally reliant on state funding.

Instead of working with colleges and respecting the challenges resulting from huge budget cuts, ACCJC continues to require time consuming and costly reports before, during and after their visits.

The NACIQI report recommends a careful review of the cost and benefits of data collection. It seems there needs to also be a review of the cost vs benefits of the current ACCJC policy of harsh public sanctions. The costs include time, resources and money spent responding to the "recommendations" of the ACCJC plus damage to college reputation following the negative sanction and often erroneous media reports.

The ACCJC policy of heavy negative sanctions does not have the concurrence of major portions of the California Community College system. In 2010 the ACCJC and ACCJC President Beno received an overwhelming vote of "No Confidence" from one of the major faculty organizations, just as ACCJC Chairperson Sherrill Amador received a vote of No Confidence before she left Palomar College to join the ACCJC. In short, management at ACCJC is by leaders who have a history of confrontation and adversarial relations with people who should be collaborators not opponents.

2. Are ACCJC evaluations in accordance with what the public understands and expects?

I believe the answer is "No". The public generally expects the accrediting agency to evaluate the quality of instruction, quality of curriculum, and the overall success of a college in preparing students for a vocational skill or transfer to a major university. This is in conformity with the Dept of Education's overview statement: "The goal of accreditation is to ensure that education provided by institutions of higher education meets acceptable levels of quality."

In their evaluation report, the ACCJC review team acknowledged the high level of instruction and teacher dedication at CCSF. Instead, the criticisms were regarding mission statement, planning process, implementation of student learning outcomes, governance and financial management. These are important aspects of college administration, but the purpose of the college is education not model management.

3. Is CCSF's negative experience with ACCJC unique?

The answer is clearly "No". A teacher from Diablo Valley College in Contra Costa County (SF Bay Area) commented as follows in the "public comments" section following a media article on ACCJC.....

"Several years ago Diablo Valley College was placed on the Show Cause list by the ACCJC. On the following accreditation visit when our fate was to be decided I met with the leader of the accreditation team where I asked a simple question. How could it be that DVC was at risk of closure when we remained the most successful transfer college to UC Berkeley, the # 1 public university in the world? Her answer was simple and very troubling as she explained that our accreditation sanctions had little to do with what was going on in the classroom and that DVC remained a fine educational institution with a strong history of academic excellence.

For those of us are concerned about real student access and success, it is hard to fathom the real mission of Barbara Beno and the Accreditation commission."


- gappell
Prof of Music at DVC
President of the United Faculty of the Contra Costa Community College District

The teacher's comments are confirmed in the ACCJC Follow Up Report.

4. Who is determining ACCJC accreditation standards and priorities?

According to Dept of Education policy, "The accrediting agency, in collaboration with educational institutions, establishes standards." Instead of collaboration and consultation, there is substantial contention. For example, the previous Chancellor for California Community Colleges, Dr. Jack Scott, sent a letter to ACCJC with suggestions that were the outcome of a task force composed of representatives of faculty, administrators, staff, students, and trustees.

One of the seven suggestions was to "work more cooperatively to have accreditation result in improvement rather than compliance". Another recommendation was to broaden the composition of the accreditation review team. A third recommendation was to "scale accreditation expectations" to those of other accreditors, presumably referring to the abnormal sanction rates. In their response, the ACCJC President and Chairperson dismissed each recommendation as irrelevant or inappropriate or unnecessary. The letter from ACCJC brilliantly illustrates the need and current lack of cooperative spirit.

In contrast, private foundations seem to be warmly received at ACCJC. In recent years ACCJC and its parent organization WASC have received substantial grants from private foundations. In 2011, Lumina Foundation gave a $1.5 Million grant to the ACCJC parent organization to "further the work to redesign its accreditation process". In 2012 ACCJC received a $450K grant from Lumina to explore the use of "Degree Qualifications Profile (DQP) and Tuning". These are substantial grants considering the total annual revenue of WASC/ACCJC was $10M in 2010. ACCJC's obsession with "Student Learning Outcomes" is demonstrated in the fact they are mentioned or referred to over seventy times in their report on CCSF.

Given the increasing grants and influence of Lumina, it is relevant to consider the history of this foundation. In 2000 USA Group merged with Student Loan Marketing Association. The latter, sometimes known as "Sally Mae", is a 'for profit' corporation sold on the stock market as SLM with Goldman Sachs one of the prime shareholders. A byproduct of the merger was the creation of the Lumina Foundation with assets of $1 Billion. Since then the foundation has been active in funding education organizations and education reform projects. In 2011 Lumina had an investment profit of $79 million while giving grants worth $49 million with operating expenses of $29 million.

Lumina grants may be supporting many good and worthy projects and organizations. However I suggest it is naive to think that this private foundation does not have a donation strategy aligned with the interests of the student loan industry. As such, Lumina grants need to be looked at carefully. Many people were fooled at the sweet sounding name Fanny Mae and the attractive sounding goal of increasing house ownership.

ACCJC policies, standards and priorities are apparently influenced by a private foundation. The foundation is even determining a priority on "redesigning the accreditation process".. Given that ACCJC and WASC staff and leaders are highly compensated and dependent on this private revenue, there is the appearance of a conflicting interest.


5. Is ACCJC sufficiently inclusive and open to the public?

According to their own bylaws, the nineteen person Accrediting Commission is supposed to have three "members of the public" in addition to administrators, faculty and regional / organizational representatives. Of the current "members of the public", two are retired college administrators and another is an acting faculty member. This seems to violate the spirit if not the letter of the law.

Of the seventeen review team members who visited CCSF, thirteen were active or retired college administrators, three were faculty and one was a trustee.

In short, ACCJC appears to be heavily dominated by active or retired college administrators. While that expertise and experience is important, there needs to be a broader perspective with more inclusion of faculty and the public.


SUMMARY

There is a strong need to review the accreditation system. Many of the NACIQI proposals address real problems in the current system. The broad nature of some of the proposals, including the suggestion to review the regional accreditation system, underscores the urgent need for more discussion and debate.

There is an even greater need to review the policies and actions of the accrediting agency ACCJC. The organization seems to be hurting much more than it is helping. Rather than developing standards and policies in collaboration with the community college communities, it is imposing a regime of compliance or punishment with policies influenced by grants and donations from private foundations. While ACCJC insists on making its negative sanctions and evaluations of community colleges public, it operates in the highest secrecy and with no significant input by the faculty and concerned public who should be an integral part of the process.