The Changing Context for Accreditation

A hallmark of U.S. higher education in the 21st century is the enormous diversity of its institutions, their missions, and the students they serve. Common across this diversity, however, is a widespread understanding that higher education represents both a public good and a private benefit. According to this understanding, higher education fosters individual development and serves the broader needs of the society and nation. Higher education has created the conditions for improving quality of life, solving problems, and enabling hope, which are essential to supporting economic prosperity and sustaining democracy in the United States. Accreditation is committed to the application of standards of performance, while affirming that high-quality education, irrespective of the different purposes of individual institutions, is in itself a contribution to the public good.

Accreditation has changed in form and substance as it has adapted to continuous social changes, increased global interdependence, and dramatic developments in information and communication technologies. The revisions to the Standards and institutional review process (IRP) described in this 2013 Handbook have occurred within the context of these factors and reflect accreditation’s responsibility to assure the public that institutions act with integrity, yield high-quality educational outcomes, and are committed to continuous improvement. Like earlier editions, the 2013 Handbook is the culmination of years of exploration and commitment on the part of institutions and stakeholders from across the WSCUC region.

The 2001 Handbook represented a significant break with the past, updating the formula for the review process and yielding a more engaged and creative endeavor. In doing so, it was a product of its times. The late 1990s was a period in which higher education embraced many important innovations—active and student-centered pedagogies, an explosion of educational technology, new roles for faculty, and new organizational forms. The approach to accreditation represented by the 2001 Handbook and the 2008 Handbook revisions reflected these conditions by creating a set of standards and an institutional review process that put teaching and learning at the center through the core commitment to educational effectiveness. At the same time, institutions were encouraged to harness accreditation as a means to advance their own goals and priorities.

The 2013 Handbook preserves and incorporates these values, even as additional factors in the operating environment for higher education demand attention. Students and their success continue to stand at the center of concerns about higher education accreditation. Thus accreditation seeks to establish standards and measurements of quality that ensure that students earn degrees in a timely manner, and that those degrees have demonstrable meaning and currency within the society at large. That meaning should also extend to graduates’ ability to be engaged citizens and to obtain productive employment.

A new context for higher education has formed the backdrop for the 2013 Handbook. Colleges and universities have been under increasing pressure to become more accountable for student academic achievement; to be more transparent in reporting the results of accreditation; and to demonstrate their contribution to the public good. Accounting for quality is a matter of public trust, given the billions of dollars government provides higher education through direct investment in institutions, federal and state financial aid for students, and tax exemptions for public and non-profit institutions. These factors lie behind the Commission’s decision to rebalance the dual role of accreditation to support both public accountability and institutional improvement.

Another critical factor is the deteriorating fiscal environment within which colleges and universities must operate. Diminishing public funding for higher education and escalating operating costs have put pressure on public and private institutions alike. The 2013 Handbook responds to financial concerns by establishing a more focused review process that shortens the time required for reaccreditation, while still providing adaptability in the review process.

With these revisions, the Commission calls upon institutions to take the next step on the assessment journey: moving from a focus on creating assessment infrastructure and processes to a focus on results and the findings about the quality of learning that assessment generates. Institutions are also asked to move from productive internal conversations about improving learning to engaging more deeply with other institutions and higher education organizations.

The Purposes of WSCUC Accreditation

The overriding purpose of WSCUC accreditation is to assure stakeholders that a WSCUC accredited institution has been rigorously evaluated and that it meets or exceeds the criteria required to maintain accreditation. In addition, the accreditation process is designed to build a culture of evidence, promote a commitment to institutional improvement, validate institutional integrity, and provide feedback that improves the accreditation process itself.

WSCUC is one of seven regional institutional accrediting agencies formerly known as “regional” accreditors. Institutional accreditation serves to assure the educational community, parents, students, employers, policymakers, and the public that an accredited institution has met high standards of quality and effectiveness. Students attending accredited institutions may be eligible to apply for U.S. federal financial aid. Accreditation also helps ensure that credits and degrees are generally recognized for purposes of transfer, admission to other institutions, and employment.

In many countries, the maintenance of educational standards is a governmental function; in the U.S., by contrast, accreditation is peer-driven and accrediting associations are funded by the dues of member institutions. Peer review teams comprising experts and representatives from similar institutions evaluate an institution for initial or reaffirmation of accreditation. No institution in the U.S. is required to seek accreditation, but because of the recognized benefits of the process, most eligible institutions have sought to become accredited.

Commission Code of Good Practice and Ethical Conduct

In carrying out its functions, the WASC Senior College and University Commission has established a code of good practice and ethical conduct that guides its relations with the institutions it serves and with its internal organization and procedures. The Commission maintains a commitment to:

1. Apply with good faith effort its procedures and standards as fairly and consistently as possible.
2. Provide means by which institutions and others can comment on the effectiveness of the accreditation review process, standards, and policies, and to conduct ongoing and regular reviews to make necessary changes.
3. Provide institutions and the general public with access to non-confidential information regarding Commission actions and opportunities to make informed comment in the development of commission policies (see Public Access to the Commission Policy).
4. Encourage continuing communication between the Commission and institutions through the accreditation liaison officer position at each institution.
5. Maintain and implement a conflict of interest policy for members of review teams, members of the Commission, and Commission staff to ensure fairness and avoid bias.
6. Value the wide diversity of institutions it accredits and consider an institution’s purpose and character when applying the Standards.
7. Assist and stimulate improvement in its institutions’ educational effectiveness.
8. Provide institutions a reasonable period of time to comply with Commission requests for information and documents.
9. Endeavor to protect the confidentiality of an institution’s proprietary information.
10. With respect to the accreditation review process:
    • Emphasize the value and importance of institutional self-evaluation and the development of appropriate evidence to support the accreditation review process.
    • Conduct reviews using qualified peers under conditions that promote impartial and objective judgment and avoid conflicts of interest.
    • Provide institutions an opportunity to object, for cause, to the assignment of a person to the institution’s review team.
    • Arrange for interviews with administration, faculty, students, and governing board members during the accreditation review process.
11. With respect to Commission decisions on an institution’s accreditation, provide opportunity for the institution to:
    • Respond in writing to draft team reports in order to correct errors of fact and propose redaction of proprietary information.
    • Respond in writing to final team reports on issues of substance.
    • Appear before the Commission when reports are considered.
    • Receive written notice from Commission staff as soon as reasonably possible after Commission decisions are made.
    • Appeal Commission actions according to published procedures.
    • Request a written response from an institution or refer a matter to the next review team when the Commission finds that an institution may be in violation of the Standards or policies. If the Commission requests the institution to respond and the Commission deems such response inadequate, Commission staff may request supplemental information or schedule a fact-finding visit to the institution. The institution will bear the expense of such a visit.
    • Permit withdrawal of a request for initial accreditation at any time prior to final action by the Commission.
    • Withdraw accreditation or candidacy as provided in the Accreditation Handbook.

The Status of Accreditation

The status of accreditation indicates that an institution has fulfilled the requirements for accreditation established by this Handbook. This means that the institution has:

1. Demonstrated that it meets the Core Commitments.
2. Conducted a self-review under the Standards, developed and presented indicators of institutional performance, and identified areas for improvement.
3. Developed approved institutional reports for accreditation that have been evaluated by teams of reviewers under the relevant institutional review processes.
4. Demonstrated to the Commission that it meets or exceeds the expectations of the Standards.
5. Committed itself to institutional improvement, periodic self-evaluation, and continuing compliance with the Standards, policies, procedures, and decisions.

Accreditation is attained following the evaluation of the entire institution and continues until formally withdrawn. It is subject, however, to periodic review and to conditions, as determined by the Commission. Every accredited institution files an Annual Report and undergoes a comprehensive self-review and peer review at least every ten years. Initial accreditation, as a matter of Commission policy, requires institutional self-review and peer review no more than six years after the date of the Commission action granting such status. Neither accreditation nor candidacy is retroactive. (The Commission may allow an institution to apply for Initial Accreditation retroactively to a specified date, no more than one year prior to the date of Initial Accreditation. The retroactive accreditation date is not automatic and must be intentionally stipulated by the Commission on a case-by-case basis. See How to Become Accredited on the Commission website.)

As a voluntary, nongovernmental agency, the Commission does not have the responsibility to exercise the regulatory control of state and federal governments or to apply their mandates regarding collective bargaining, affirmative action, health and safety regulations, and the like. Furthermore, the Commission does not enforce the standards of specialized accrediting agencies, the American Association of University Professors, or other nongovernmental organizations, although institutions may wish to review the publications of such agencies as part of the self-review process. The Commission has its own Standards and expects institutions and teams to apply them with integrity, flexibility, and an attitude of humane concern for students and the public interest.

The Standards must be met at least at a minimum level for Candidacy to be granted to institutions seeking initial accreditation. For institutions to be granted initial accreditation and for those seeking reaffirmation of accreditation, the Standards must be met. The Standards define normative expectations and characteristics of excellence and provide a framework for institutional self-review. Depending upon the stage of development of the institution, some components of the Standards may be viewed as of greater or lesser priority.

Understanding the WSCUC Standards

The WSCUC process begins by calling upon institutions to ground their activities in three Core Commitments. By affirming these Core Commitments and taking ownership of the accreditation process, institutions create learning environments that continuously strive for educational excellence and operational effectiveness in order to serve both students and the public good.

Core Commitment to Student Learning and Success

Institutions have clear educational goals and student learning outcomes. Institutions collect, analyze, and interpret valid and reliable evidence of learning as a way of assessing student achievement and success. Institutions support the success of all students and seek to understand and improve student success.

Core Commitment to Quality and Improvement

Institutions are committed to high standards of quality in all of their educational activities. They utilize appropriate evidence to improve teaching, learning, and overall institutional effectiveness. Through strategic and integrated planning, institutions demonstrate the capacity to fulfill their current commitments and future needs and opportunities.

Core Commitment to Institutional Integrity, Sustainability, and Accountability

Institutions recognize that the public has entrusted them with the critical responsibilities of upholding the values of higher education and contributing to the public good. They engage in sound business practices, demonstrate institutional integrity, operate in a transparent manner, and adapt to changing conditions.

Standards of Accreditation

The Standards of Accreditation consist of four broad, holistic statements that reflect widely accepted good practices in higher education. WSCUC institutions are diverse in terms of mission, character, and type. The Standards are broad enough to honor that diversity, respect institutional mission, and support institutional autonomy. At the same time, institutions must demonstrate that they are in compliance with the four Standards and related Criteria for Review in order to become and remain accredited. The four Standards are:

• Standard 1: Defining Institutional Purposes and Ensuring Educational Objectives
• Standard 2: Achieving Educational Objectives through Core Functions
• Standard 3: Developing and Applying Resources and Organizational Structures to Ensure Quality and Sustainability
• Standard 4: Creating an Organization Committed to Quality Assurance, Institutional Learning, and Improvement

Criteria for Review

Thirty-nine Criteria for Review (CFR) are distributed across the four Standards. The CFRs under each Standard provide more specific statements about the meaning of the Standard. The CFRs are grouped under headings that identify major aspects of institutional functioning. The CFRs are cited by institutions in their institutional report, by peer reviewers in evaluating institutions, and by the Commission in making decisions about institutions. Many of the CFRs are cross-referenced to allow for ease in identifying related and connected CFRs.

Guidelines

Where Guidelines are provided, they assist institutions in interpreting the CFRs by offering examples of how institutions can address a particular Criterion for Review. An institution is welcome to employ different practices from those described in a particular Guideline; in that case, the institution is responsible for showing that it has addressed the intent of that Criterion in an equally effective way.

Related Commission Policies and Resources

Following some CFRs are references to policies of particular relevance to those CFRs and any related Guidelines. Institutions are encouraged to become familiar with, and to review periodically, all Commission policies, which are binding on member institutions.

Following some CFRs are references to manuals and resource guides. The procedures described in WSCUC manuals, like policies, are binding. Guides, offering principles and examples of good practice, address topics such as program review, transparency, graduate education, and the use of evidence. Guides are not binding; they are merely suggestive and intended to provide helpful information.

Current versions of WSCUC policies, manuals, and resource guides are available on our Resources page.

WSCUC Standards of Accreditation

The four Standards are:

• Standard 1: Defining Institutional Purposes and Ensuring Educational Objectives
• Standard 2: Achieving Educational Objectives through Core Functions
• Standard 3: Developing and Applying Resources and Organizational Structures to Ensure Quality and Sustainability
• Standard 4: Creating an Organization Committed to Quality Assurance, Institutional Learning, and Improvement

The Institutional Review Process

This section is designed to assist institutions as they address the Standards for reaffirmation of accreditation. It provides a description of the steps involved in an institution’s reaffirmation process, the components that need to be included in the institutional report, interactions with the review team, and other details.

The Institutional Review Process (IRP) described below applies to institutions that are seeking reaffirmation of accreditation. Other models apply for institutions seeking eligibility or initial accreditation. At the Commission’s discretion, institutions may be directed to follow a process that differs from the one described in this Handbook, and those institutions will be guided by other documents describing those reviews.

All institutions need to demonstrate they are in compliance with the Standards and with those federal regulations that the Commission is required to implement. Within this context, the goal of the process is the improvement of student learning, student success, and institutional effectiveness.

Institutions can typically expect to spend two to three years pursuing reaffirmation of WSCUC accreditation. Briefly stated, the IRP involves an Offsite Review by a peer review team, and an Accreditation Visit to the institution by the same team. These steps are followed by a Commission decision on an institution’s length of time for reaffirmation of accreditation, which can be six, eight, or ten years. A description of the review process follows.

Overview of the Institutional Review Process

Self-Study and Preparation for the Institutional Review Process

Opportunities for Guidance: WSCUC is committed to supporting institutions as they prepare for the Institutional Review Process. There will be multiple opportunities for institutions to receive information and guidance in order to prepare for the Offsite Review and Visit.

• Academic Resource Conference: Every year, WSCUC sponsors the Academic Resource Conference (ARC), which includes workshops and panels on the review process that institutions will find helpful.
• Institutional consultations: Institutions should arrange on-campus or remote consultations, at their cost, with their WSCUC staff liaison. Objectives for this consultation include a review of the institution’s responses to previous Commission recommendations and identification of the goals for the self-study, including strengths and areas of challenge. In addition, the WSCUC liaison is available to meet on-site with groups and individuals involved in the self-study process. Together, the team and staff liaison will clarify subsequent steps and strategies for the review. These may include, for example, how the institution will organize for the review, how various constituencies will be involved, and what resources will be required.

The Self-Study: The self-study is the institution’s process of gathering evidence and data and reflecting on its current functioning and effectiveness under the Standards.

WSCUC makes available to both institutions and the public a Key Indicators Dashboard (KID). Institutions should consider information presented in KID as part of the self-study process. KID includes information from federal data sets to present multiple years of metrics, trend data, and comparisons based on both national and WSCUC averages and presents disaggregated data on student performance that may be useful in understanding equity gaps. KID only includes institutions which have undergraduate programs and report to IPEDS.  Other institutions (international, graduate only, non-IPEDS reporters) should consider information presented in the Key Indicators (KI) Reports as part of the self-study process.

At the beginning of the IRP, the self-study provides the necessary preparation for later steps, but self-study continues throughout the two to three years of review for reaffirmation. A candid self-study, with broad engagement of the institutional community, provides the foundation for a high-quality institutional report.

In preparation for the self-study, institutions are expected to review their accreditation history. This includes the most recent team report and all Commission action letters received since the last reaccreditation; documents submitted to WSCUC since the last review for reaffirmation of accreditation; and WSCUC responses where applicable (e.g., recommendations related to substantive changes or an interim report).

Early in the self-study, the institution completes the Compliance with WSCUC Standards and Compliance with Federal Requirements Worksheet. The worksheet is designed to present evidence of the institution’s compliance with the Standards and to prompt conversation on institutional capacity and infrastructure, strengths, weaknesses, priorities, and plans for ensuring compliance with the Standards and institutional improvement.

This worksheet calls only for evidence and data that have not been submitted with the institution’s annual report and that demonstrate compliance with several federal requirements accreditors are expected to monitor. The institution should complete this worksheet for verification by the team during the review process.

The completed Compliance with WSCUC Standards and Federal Requirements Worksheet is submitted as an exhibit with the Institutional Report.

Instead of beginning with the Compliance with WSCUC Standards and Federal Requirements Worksheet, some institutions may prefer to frame their self-study around their own priorities and planning (e.g., strategic, financial, and/or academic). The accreditation review may then be adapted to support those goals. Some institutions administer surveys or conduct focus groups to identify top campus priorities. Such approaches have the advantage of putting the emphasis on the institution’s goals and then integrating them with WSCUC expectations; thus they may inspire broader campus engagement, stronger commitment to the process, and greater returns on the effort and resources invested. However the institution chooses to begin, explicit attention to the Standards and CFRs, as well as documented compliance with federal laws and regulations, is required.

After these initial steps, the focus of the self-study shifts to the specific components that form the institutional report. These components are described in detail below, along with prompts that can stimulate inquiry and reflection.

Another essential element at the outset of the self-study is practical planning for how the institution will launch and conduct the accreditation review. Such planning addresses the financial and human resources that will be needed, the structures that will support progress, the timeline and milestones that must be met, and evidence and metrics that are available or must be generated. To the extent possible, institutions are encouraged to make use of existing resources, e.g., standing committees, an assessment office, program review, and institutional research, before introducing new processes.

The Institutional Report

Overview: The institutional report is based on the findings of the institution’s self-study and, with the exception of an institution-specific theme, must include the components described below in the order shown.

• Introduction: Institutional Context; Response to Previous Commission Actions
• Compliance: Compliance with WSCUC Standards and Federal Requirements Worksheet
• Degree Programs: Meaning, Quality, and Integrity of Degrees
• Educational Quality: Student Learning, Core Competencies, and Standards of Performance at Graduation
• Student Success: Student Learning, Retention, and Graduation
• Quality Assurance and Improvement: Program Review; Assessment; Use of Data and Evidence
• Sustainability: Financial Viability; Preparing for the Changing Higher Education Environment
• Institution-specific Theme(s): Optional
• Conclusion: Reflection and Plans for Improvement

The required and optional components of the institutional report are described in the next section. Numbering is provided for ease of reference; it does not indicate relative value. In general, each component should include a discussion of the topic within the context of the institution; analyses undertaken; a self-assessment and reflection; areas of strength or significant progress and areas of challenge; and next steps, as appropriate. When plans are described, targets, metrics, and timelines should be included, as appropriate.

Length of the Report and Citation of Standards: The institutional report narrative is typically 12,000 to 18,000 words (approximately 50-75 pages, double-spaced) in length. In the body of the report, it is helpful to hyperlink to relevant documents in the exhibits in order to support each assertion and to provide easy navigation for reviewers.

References to the Standards and citations of specific CFRs are included, as appropriate, in the body of the report. It is not necessary to cite all the CFRs because these will have been addressed in the Compliance with the Standards worksheet. Instead, the institutional report can cite only those CFRs of direct relevance to the topic under discussion (i.e., meaning of degrees, student learning and achievement, student success, quality assurance, planning for the future, and possibly an additional theme). Institutions may cite others, as relevant to their narratives.

Interactions with the Review Team

Throughout the institutional review process, representatives of the institution interact with review team members and WSCUC staff. Interaction with the Commission occurs at the end of the institutional review process when the Commission makes a decision about the institution’s accreditation status.

The review team, composed primarily of experienced educators from peer institutions as well as other experts identified to address specific needs of the institution, has the responsibility to evaluate the institution under the Standards of Accreditation. The review team’s work involves the following: reading the institutional report, exhibits, and other documents; conducting the Offsite Review; conducting the visit; and preparing a report of its findings and recommendations.

Every institution seeking initial accreditation or reaffirmation of accreditation has a WSCUC staff liaison. The liaison, together with other staff members, provides support and guidance to the institution, the review team, and the Commission throughout the review process.

The Offsite Review

The focus of the Offsite Review is to make preliminary findings based upon the institutional report and supplementary documents. The institution submits its institutional report and exhibits 10 weeks prior to the Offsite Review. The review team then convenes to evaluate the institution and its compliance with the Standards.

Review team members share impressions, note issues for follow-up, formulate questions for the onsite review, and identify additional documents they may wish to examine before or during the visit. The review team also either confirms the scheduling of the visit to the institution (typically four to six months later) or recommends a different interval. At the conclusion of the Offsite Review, the review team holds a short video teleconference with institutional representatives to share its request for additional information and lines of inquiry for the visit.

Following the Offsite Review, the institution receives a summary of strengths, areas that need improvement, foci for the visit, questions for which the team seeks answers or clarification, additional materials that may be needed, and any special considerations. This summary (see Offsite Review Summary of Lines of Inquiry Guide) is prepared by the team with guidance from the WSCUC staff liaison. The Lines of Inquiry summary is a private communication; it is not made public. WSCUC staff then work with the institution to make arrangements for the visit.

The Accreditation Visit

The three-day visit takes place four to six months after the Offsite Review. An institution may request or the review team may recommend a longer interval if the institution is expected to need more time to prepare a follow-up to the Lines of Inquiry. During the visit, the team meets with institutional representatives to follow up on outstanding issues and verify or revise its preliminary findings concerning both compliance and improvement. The institution has an opportunity to demonstrate how it has responded to issues raised or questions asked at the time of the Offsite Review and to fill any gaps in the picture it wishes to present of itself. Following the visit, the team shares its draft team report with the institution for correction of errors of fact and challenges related to proprietary information. The team then finalizes the team report and forwards it to the Commission for action.

The Thematic Pathway for Reaffirmation

The Thematic Pathway for Reaffirmation (TPR) eliminates the Offsite Review while maintaining an institutional report – the result of one or more unique themes chosen by the institution that are explored during its self-study. A peer review team conducts a three-day visit and meets with institutional representatives, following the protocols established for Accreditation Visits.

The TPR process is available only to institutions with a history of strong student outcomes, financial equilibrium, and organizational stability that received a nine or 10-year reaffirmation during their prior review. Institutions elect to be considered for this review pathway. Once affirmed by the Commission, institutions create the “theme(s)” for their self-studies, which are in turn reviewed by WSCUC staff. The institution thus has the freedom and responsibility to choose an activity that will contribute to its ongoing improvement – consistent with its vision and mission – and to document and demonstrate how it conducted and concluded that activity. As part of the TPR, the institution prepares a report consisting of four of the nine self-study report components with the bulk of the narrative dedicated to its theme work. TPR report Components include: Component 1 (Introduction: Institutional Context; Response to Previous Commission  Actions); Component 2 (Compliance: Compliance with WSCUC Standards and Federal Requirements Worksheet); Component 8 (Institution-Specific Theme(s)); and Component 9 (Conclusion: Reflection and Plans for Improvement).  More information about the TPR is available in the Thematic Pathway for Reaffirmation Guide.

Forms of Possible Commission Action

The forms of possible Commission action with regard to institutions include:

1. Grant Candidacy
2. Grant Initial Accreditation
3. Deny Candidacy or Initial Accreditation
4. Defer Action
5. Reaffirm Accreditation
6. Issue a Formal Notice of Concern
7. Issue a Warning
8. Impose Probation
9. Issue an Order to Show Cause
10. Withdraw Candidacy or Accreditation

In taking an action, the Commission may impose conditions, or request additional reporting or site visits.

Grant Candidacy or Initial Accreditation

(See the How to Become Accredited Manual)

Candidacy: The institution must demonstrate that it meets all of the Standards at a level sufficient for Candidacy and has a clear plan in place to meet the Standards at a level sufficient for Initial Accreditation. Candidacy is limited to five years and is granted only when an institution can demonstrate that it is likely to become accredited during the five-year period.

Initial Accreditation: The institution has met the Standards at a level sufficient for Initial Accreditation. Initial Accreditation is for a period of six years before the next comprehensive review.

Deny Candidacy or Initial Accreditation

Denial of candidacy or initial accreditation reflects the Commission’s finding that an institution has failed to demonstrate that it meets all, or nearly all, of the Standards at the required level for candidacy or initial accreditation. In this circumstance, Commission policy provides that an institution may reapply once it has demonstrated that it has addressed the issues leading to the denial. In all cases, it must wait at least one year before reapplying. (See the Reapplication after Denial of Candidacy or Initial Accreditation Policy.) Denial is an appealable action.

Defer Action

Deferral is not a final decision. It is provisional and designed to provide time for the institution to correct specified deficiencies. This action allows the Commission to indicate to an institution the need for additional information or progress in one or more specified areas before a positive decision can be made. Deferrals are granted for a maximum period of one year.

Reaffirm Accreditation

Reaffirmation of accreditation occurs at the completion of the Institutional Review Process or when an institution is taken off of a sanction. It indicates that the Commission has found that an institution has met or exceeded the expectations of the Standards and the Core Commitments to Student Learning and Success; Quality and Improvement; and Institutional Integrity, Sustainability, and Innovation. Reaffirmation is granted for a period of six, eight or 10 years. The Commission may also request other reports and/or Special Visits, or a formal Notice of Concern.

Issue a Formal Notice of Concern

This action provides notice to an institution that, while it currently meets the Standards, it is in danger of being found out of compliance with one or more Standards if current trends continue. A formal Notice of Concern may also be issued when an institution is removed from a sanction and the Commission wishes to emphasize the need for continuing progress and monitoring. Institutions issued a formal Notice of Concern have a Special Visit within four years to assess progress. A Notice of Concern is public information and will be posted on the WSCUC website. If the Commission’s concerns are not addressed by the time of the visit, a sanction is imposed, as described below.

Sanctions

Under U.S. Department of Education regulations, when the Commission finds that an institution fails to meet one or more of the Standards, it is required to notify the institution of these findings and give the institution up to two years from the date of this action to correct the situation. If an institution has not remedied the deficiencies at the conclusion of the two-year sanction period, the Commission is required, under U.S. Department of Education regulations, to take an adverse action, defined in the law as the denial or withdrawal of accreditation. Thus, all institutions must address the areas cited by the Commission expeditiously, with seriousness and the full attention of the institution’s leadership. It is the responsibility of the Commission to determine, at the end of the sanction period, if the institution has corrected the situation(s) and has come into compliance with the Standards.

The Commission has adopted three sanctions – Warning, Probation, and Show Cause – to inform the institution and the public of the severity of its concerns about an institution’s failure to meet one or more Standards or one or more of any conditions or restrictions that were contained in a Commission action letter. Sanctions are not intended to be applied sequentially. Whichever sanction is imposed, the Commission is required by federal law to withdraw accreditation, rather than to continue the institution under the same or a new sanction for another two-year period, unless clear progress has been made within two years.

All sanctions are made public and are published on WSCUC’s website. The institution is also expected to notify its constituents about the Commission action, and WSCUC publishes the Commission action letter and related team report, in accordance with the Public Disclosure of Accreditation Documents and Commission Actions Policy.

In addition, when an institution is placed on a sanction, the Commission typically requests that a meeting be held between WSCUC staff, the institution’s chief executive officer, representatives of the institutional governing board, and senior faculty leadership within 90 days following the imposition of the sanction. The purposes of the meeting are to communicate the reasons for the Commission action, to learn of the institution’s plan to notify the institutional community about the action, and to discuss the institution’s plan for addressing the issues that gave rise to the sanction.

Federal law permits an extension of the two-year time frame when good cause is found. The Commission has determined that it will grant an extension for good cause only under exceptional circumstances and only when the following criteria are met:

1. The institution must have demonstrated significant accomplishments in addressing the areas of noncompliance during the period under sanction, AND
2. The institution must have demonstrated at least partial compliance with the Standard(s) cited, and, for any remaining deficiencies, demonstrate an understanding of those deficiencies, and readiness, institutional capacity, and a plan to remedy those deficiencies within the period of extension granted by the Commission.

In determining whether these criteria have been met, the Commission will also consider whether:

1. The quality of education provided by the institution is judged to be in compliance with the Standards at the time of the extension, AND
2. The Commission has evidence of any new or continuing violations of Standard 1 regarding institutional integrity, AND
3. The Commission has evidence of other reasons or current circumstances why the institution should not be continued for good cause.

The Commission may extend accreditation for good cause for a maximum of two years, depending on the seriousness of the issues involved and on its judgment of how much additional time is appropriate. By the conclusion of the extension period identified by the Commission, the institution must prepare a report that details its compliance with those Standards cited by the Commission. Demonstrated compliance with the Standards is required and must be supported by verifiable evidence. Progress or promises of future action after such an extension are not sufficient.

Issue a Warning

A Warning reflects the Commission’s finding that an institution fails to meet one or more of the Standards of Accreditation. While on Warning, any new site or degree program initiated by the institution is regarded as a substantive change (see the Substantive Change Manual for details). The candidate or accredited status of the institution continues during the Warning period. The Commission action to issue a Warning is subject to Commission Review, described below.

Impose Probation

Probation reflects the Commission’s finding that the institution has serious issues of noncompliance with one or more of the Standards. While on Probation, the institution is subject to special scrutiny by the Commission, which may include a requirement to submit periodic prescribed reports and to receive Special Visits by representatives of the Commission. In addition, while on Probation, any new site or degree program initiated by the institution is regarded as a substantive change (see the Substantive Change Manual for details). The candidate or accredited status of the institution continues during the Probation period. The Commission action to impose Probation is subject to Commission Review, described below.

Issue an Order to Show Cause

An Order to Show Cause is a decision by the Commission to terminate the accreditation of the institution within a maximum period of one year from the date of the Order, unless the institution can show cause as to why such action should not be taken. Such an Order may be issued when an institution is found to be in noncompliance with one or more of the Standards or, having been placed on Warning or Probation for at least one year, has not been found to have made sufficient progress to come into compliance with the Standards. An Order to Show Cause may also be issued as a summary sanction for unethical institutional behavior (see Summary Sanctions for Unethical Institutional Behavior, below). In response to the Order, the institution has the burden of proving why its candidacy or accreditation should not be terminated. The institution must demonstrate that it has responded satisfactorily to Commission concerns, has come into compliance with all Standards, and will likely be able to sustain compliance.

The accredited status of the institution continues during the Show Cause period, but during this period, any new site or degree program initiated by the institution is regarded as a substantive change and requires prior approval. (See the Substantive Change Manual for details). In addition, the institution may be subject to special scrutiny by the Commission, which may include special conditions and the requirement to submit prescribed reports or receive Special Visits by representatives of the Commission. The Commission action to issue and order to show cause is subject to Commission review, as described below.

Withdraw Candidacy or Accreditation

A decision to withdraw candidacy or accreditation is made by the Commission when an institution has been found to be seriously out of compliance with one or more Standards. Although not required, a decision to withdraw accreditation may be made after an Order to Show Cause or another sanction has been imposed and the institution has failed to come into compliance. When accreditation is withdrawn, a specific date of implementation is specified. An action to withdraw candidacy or accreditation is subject to the WSCUC appeals process. If an institution closes after a withdrawal action, the institution must comply with federal requirements and WSCUC policies about teach-out arrangements. WSCUC has established policies on notice of such actions (See Public Disclosure of Accreditation Documents and Commission Actions Policy) and on teach-out agreements (see Teach-out Plans and Agreements Policy). See the Documents list on the WSCUC website for the most current version of these policies.

Summary Sanctions for Unethical Institutional Behavior

If it appears to the Commission or its staff that an institution is seriously out of compliance with Standard One (Defining Institutional Purposes and Ensuring Educational Objectives) in a manner that requires immediate attention, an investigation will be made and the institution will be offered an opportunity to respond on the matter. If the Commission concludes that the institution is seriously out of compliance due to unlawful or unethical action it may:

1. Sever relations if the institution has applied for, but has not yet been granted, candidacy or accreditation; or
2. If the institution is a candidate or accredited, either:
3. issue an Order to Show Cause why its candidacy or accreditation should not be withdrawn at the end of a stated period;
4. in an extreme case, sever its relationship with the institution by denying or withdrawing candidacy or accreditation; or
5. Apply less severe sanctions as deemed appropriate.

Commission Review Process for Institutions on Sanction

Institutions that are placed on Warning, Probation, or Show Cause, or for which applications for accreditation are denied, may request a review of this decision according to the following procedures. These review procedures are designed as a continuation of the accreditation peer review process and are therefore considered to be non-adversarial.

1. When the Commission takes any of the actions listed above, its President will notify the given institution of the decision by a method requiring a signature, within approximately 14 calendar days of the Commission’s decision. Said notification shall contain a succinct statement of the reasons for the Commission’s decision.
2. If the institution desires a review of the Commission action, it shall file with the President of the Commission a request for a review under the policies and procedures of the Commission. This request is to be submitted by the chief executive officer of the institution and co-signed by the chair of the governing board. Requests for review by an institution in a multi-college system shall also be signed by the chief executive officer of the system. The request for review must be received by a method requiring a signature, within 28 calendar days of the date of the mailing of the Commission’s notification of its decision to the institution. The fee for the review process shall accompany the request.
3. Within 21 calendar days after the date of its request for review, the institution, through its chief executive officer, must submit a written statement of the specific reasons why, in the institution’s opinion, a review of the Commission’s decision is warranted. This written statement shall respond only to the Commission’s statement of reasons for the Commission’s decision and to the evidence that was before the Commission at the time of its decision. In so doing, the institution shall identify the basis for its request for review in one or more of the following areas: (1) there were errors or omissions in carrying out prescribed procedures on the part of the review team and/or the Commission which materially affected the Commission’s decision; (2) there was demonstrable bias or prejudice on the part of one or more members of the review team or Commission which materially affected the Commission’s decision; (3) the evidence before the Commission prior to and on the date when it made the decision that is being questioned was materially in error; or (4) the decision of the Commission was not supported by substantial evidence.The institution may not introduce evidence that was not received by the Commission at the time it made the decision under review. It is the responsibility of the institution to identify in the statement of reasons what specific information was not considered, or was improperly considered, by the visiting team or the Commission and to demonstrate that such acts or omissions were a material factor in the negative decision under review.

The statement of reasons will be reviewed by Commission staff for compliance with this provision. If, in the judgment of Commission staff, the statement of reasons is deficient, it will be forwarded to the Commission chair. Should the Commission chair concur with the judgment of Commission staff, no review committee will be appointed and the statement will be returned to the institution.

If the statement of reasons is returned, the institution will be provided the opportunity to revise the statement within 21 calendar days from the date the notice of return is sent to the institution. Should the institution resubmit its statement of reasons within the prescribed time period, the revised statement will be reviewed by Commission staff. If the revised statement is still found to be deficient, it will be forwarded to the Commission chair. Should the Commission chair concur that the revised statement is deficient, no review committee will be appointed. This action is final.

1. On acceptance of the institution’s written statement referred to in 3. above, a committee of three or more persons will be selected by Commission staff to serve as the review committee. A roster of the review committee will be sent to the institution, normally within 30 calendar days of the date of the Commission’s receipt of the institution’s written statement. No person who has served as a member of the visiting team whose report is subject to review shall be eligible to serve on the review committee. The institution will be provided opportunity to object for cause to any of the proposed review committee members. After giving the institution this opportunity, Commission staff will finalize the membership of the review committee.
2. Within a reasonable period of time after the review committee has been selected, the President of the Commission will schedule a meeting of the review committee at a location separate from the institution and Commission offices. No assurance can be made that the review committee process will take place in time for the review to be included on the agenda of the next Commission meeting.
3. Prior to the meeting of the review committee, the committee members will review available information. If additional information is needed, the chair of the review committee may request such information from the chief executive officer of the institution, Commission staff, or the visiting team, before, during, or after the meeting of the review committee.
4. The review will be investigative and designed to determine if any of the grounds for review cited by the institution are valid.
5. Commission staff other than the WSCUC liaison for the contested Commission action will assist the review committee as needed. The Committee may interview, among others, Commission readers, the chair or members of the previous visiting team, and the Commission staff member who supported the team visit. Outside legal counsel is not permitted to attend or be present in meetings with the review committee without consent of the review committee chair. If allowed to be present, legal counsel will not be allowed to conduct any part of the proceedings but will be permitted to advise institutional representatives as needed. The Commission legal counsel may advise the review committee, but may not attend those portions of the review committee’s meetings when it is meeting with institutional representatives, unless legal counsel for the institution is also permitted to be present.
6. The review committee should open and close its meeting with the chief executive officer or other institutional representatives by attempting to ascertain whether or not the institution has any complaints about any aspect of the review process. All written evidence is to be provided to the review committee together with the institution’s request for review. The Commission office shall provide the review committee with documents that were available to the Commission at the time of its action. If additional information is requested from the institution, it is to be provided at least seven business days in advance of the review committee’s meeting. The review committee is only allowed to consider evidence that was available to or known by the Commission at the time of its taking action. No new evidence or information relating to actions or events subsequent to the date of the Commission action is to be presented or considered by the review committee.
7. The review committee shall prepare a report that states the reasons for the Commission action, identifies each reason advanced by the institution in its request for review, and, for each reason, evaluates the evidence that the institution has presented in support of its request for review. In addition, the review committee may evaluate additional evidence that, in its opinion, is relevant to its recommendation to the Commission. The report shall state only findings of fact and not consider or cite any evidence relating to facts or events occurring after the date of Commission action.
8. The chair of the review committee will submit a copy of the review committee’s report that is referred to in 10. above to the chief executive officer of the institution, the chair of the institution’s governing board, and the President of the Commission, normally within 30 calendar days of the end of the review committee’s meeting.
9. In a confidential letter to the Commission, the review committee will recommend whether the Commission decision that is under review should be affirmed or modified. This recommendation of the review committee to the Commission will not be disclosed to the institution being reviewed. The recommendation is not binding on the Commission.
10. Within 14 calendar days of the institution’s receipt of the review committee’s report, the chief executive officer will submit a written response to the President of the Commission, with a copy to the chair of the review committee, for transmittal to the Commission. The review will be placed on the agenda of an upcoming Commission meeting, for consideration by the Commission.
11. Prior to the Commission meeting, a reader meeting will be conducted by conference call or in person where the chief executive officer of the institution and a limited number of institutional representatives will be invited to discuss the review committee report with those Commissioners designated as readers. The chair of the review committee will also be invited to participate in the call. Discussion at this reader meeting will be confined to the report of the review committee referred to in 10. above and to the institution’s response to this report.
12. The Commission readers will report the substance of this meeting to the Commission when it meets. Institutional representatives will be invited to appear before the Commission before it takes action.
13. The Commission will reach a final decision to: (1) reaffirm its original decision; (2) modify it; or (3) reverse it. As soon after the meeting as is practicable, the President of the Commission will notify the chief executive officer of the institution, by a method requiring a signature, of the Commission’s decision.
14. Special charges for the review process have been established by the Commission. A list of these charges is available from the Commission office and on the Commission website.
15. The Commission may develop any necessary procedures and instructions to review committees to implement this process. These materials will be available from the Commission office.

Sanctions

Seven institutional (formerly regional) accrediting commissions share a common framework and a common understanding of terms for certain actions regarding accredited institutions: Warning, Probation, Show Cause, Withdrawal of Accreditation, Denial of Accreditation, and Appeal.

Public Sanctions

• Warning: Indicates that an institution has been determined by the commission(¹⁾ not to meet one or more standards(²⁾ for accreditation.
• Probation: Indicates that an institution has been determined by the commission not to meet one or more standards for accreditation and is an indication of a serious concern on the part of the commission regarding the level and/or scope of non-compliance issues related to the standards.

By federal regulation, the Commission must take immediate action to withdraw accreditation if an institution is out of compliance with accreditation standards for two years unless the time is extended for good cause.

Show Cause: An institution is asked to demonstrate why its accreditation should not be withdrawn. A written report from the institution and, if specified by the commission, a focused visit are preliminary to a hearing with the commission. Show cause may occur during or at the end of the two-year probation period, or at any time a commission determines that an institution must demonstrate why its accreditation should not be withdrawn (i.e., probation is not a necessary precursor to show cause).

Withdrawal of Accreditation: An institution’s accredited status is withdrawn, and with it, membership of the association.

Denial of Accreditation: An institution is denied initial accreditation because it does not meet the requirements for accreditation.

Appeal: The withdrawal or denial of accreditation may be appealed. Institutions remain accredited (or candidates for initial accreditation) during the period of the appeal.

^{1 Commission encompasses decisions made by an appropriate decision-making body of one of the seven institutional accrediting bodies.}

^{2 Standards encompasses any requirements for accreditation, including eligibility requirements, standards, criteria, or policies of the commission.}

Decisions Regarding Accreditation Status

Commission Decisions Regarding Accreditation Status

The Commission will provide written notice to the Secretary of the U.S. Department of Education, the appropriate state licensing or authorizing agency, other accrediting agencies, WSCUC accredited and candidate institutions, and the public no later than 30 days after it makes:

• A decision to grant initial accreditation, candidacy, or reaffirmation.
• A final decision to place an institution on Warning, Probation, or Show Cause.
• A final decision to deny or withdraw candidacy or accreditation.
• Final approval of all substantive and structural changes.

No later than 60 days after a final decision to deny or withdraw accreditation, the Commission will make available to the Secretary of the U.S. Department of Education, the appropriate state licensing or authorizing agency, and the public upon request, a brief statement summarizing the reasons for the agency’s decision.

Institutional Decisions Regarding Accreditation Status

The Commission will, within 30 days, notify the Secretary of the U.S. Department of Education, the appropriate state licensing or authorizing agency, and the public upon request, if an institution:

• Voluntarily withdraws from candidacy or accreditation; or
• Allows its candidacy or accreditation to lapse.

Regard for Decisions of Other Agencies

If the Commission is notified by another recognized accrediting agency that an applicant or candidate institution has had a status of recognition with that agency denied, revoked, or withdrawn, the Commission will take such action into account in its own review if it is determined that the other agency’s action resulted from an institutional deficiency that reflects a lack of compliance with the WSCUC Standards of Accreditation.

If the Commission is notified by another recognized accrediting agency that an accredited institution has had a status of recognition with that agency revoked, suspended, or withdrawn, or has been placed on a publicly announced probationary status by such an accrediting agency, the Commission will review its own status of recognition of that institution to determine if the other agency’s action resulted from an institutional deficiency that reflects a lack of compliance with WSCUC’s Standards of Accreditation. If so, the Commission will determine if the institution’s status with the Commission needs to be called into question, or if any follow-up action is needed.

If the Commission is notified by a state agency that an applicant, candidate, or accredited institution has been informed of suspension, revocation, or withdrawal of the institution’s legal authority to provide postsecondary education, the Commission will review its own status of recognition for that institution to determine compliance with the Standards of Accreditation. If the Commission finds the institution is no longer in compliance with the Standards, the Commission will determine the appropriate action to be taken.

In implementing this policy, the Commission relies on other accrediting bodies and state agencies to inform the Commission of their actions so that the Commission can undertake the review specified in this policy. Applicants for eligibility with the Commission shall provide information on any actions by a recognized accrediting association within the past five years. In addition, the Commission requires candidate and accredited institutions holding accredited or candidate status from more than one U.S. Department of Education recognized accrediting body to keep each accrediting body apprised of any change in its status with one or another accrediting body.