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

Grant Candidacy or Initial Accreditation

(See: How to Become Accredited Manual) 

Candidacy: The institution must demonstrate that it meets all, or nearly all, of the Standards of Accreditation at a minimum level and has a clear plan in place to meet the Standards at a substantial level of compliance for 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 Commission Standards at a substantial level. 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 of Accreditation 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 policy on Reapplication After Denial of Candidacy or Initial Accreditation.) Denial is an appealable action, as explained below. 

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 6, 8 or 10 years* and will be accompanied by a requirement for a Mid-Cycle Review to enable the Commission to discover any aresa of potential non-compliance with its Standards. 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 WSCUC 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.

* Effective fall 2015

Sanctions

Under U.S. Department of Education regulations, when the Commission finds that an institution fails to meet one or more of the Standards of Accreditation, 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, whether the institution has corrected the situation(s) and has come into compliance with Commission 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 Commission 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 WSCUC policy on Disclosure of Accreditation Documents and Commission Actions. 

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 substantial compliance with Commission 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 Commission 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 of Accreditation. 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 substantial noncompliance with one or more Commission 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 Commission 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 withdrawl 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 policy on Disclosure of Accreditation Documents and Commission Actions) and on teach-out agreements (see policy on Teach-out Plans and Agreements). See the Commission Web site 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 (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:
    1.  issue an Order to Show Cause why its candidacy or accreditation should not be withdrawn at the end of a stated period; 
    2.  in an extreme case, sever its relationship with the institution by denying or withdrawing candidacy or accreditation; or 
  3. Apply less severe sanctions as deemed appropriate.