SECTION A

Specific Policies Relating to Institutional Accreditation

A-1 Accreditation Liaison Officer

An Accreditation Liaison Officer (ALO) is appointed from the faculty or administration by the president or chief executive officer of each member institution to work with appropriate individuals or agencies on matters of accreditation.

In the selection of the Accreditation Liaison Officer, it is suggested that the following points be considered:

a. knowledge of the institution;

b. visibility on the campus;

c. interest in accreditation; and

d. availability of clerical resources.

Duties of the Accreditation Liaison Officer are:

a. To serve as the central agent on campus for the collection and dissemination of information about institutional and specialized accreditation.

1) Keep on file accreditation handbooks and guidelines, self-studies, evaluation committee reports, schedules of evaluations, and copies of correspondence from accrediting agencies.

2) Answer inquiries about accreditation and make available appropriate information.

b. To serve as the key resource person in planning the self-study for accreditation.

c. To try to develop coordinated accreditation programs and schedules if the institution is involved with specialized accrediting agencies.

d. To work with the office of the accrediting agency in making campus and local arrangements for the evaluation committee report.

e. To assist in organizing and carrying out follow-up studies and reports that might result from the evaluation committee report.

f. To prepare the annual report form that provides basic information and data.

g. To notify the Commission on Colleges in advance of substantive changes that are planned. (See Policy A-2 Substantive Change, below.)

Adopted 1974

A-2 Substantive Change

The Commission on Colleges monitors proposed changes whenever an accredited or candidate institution plans a substantive change in its mission and goals, scope, control, geographic area of offerings, or other significant matters.

Introduction. Accreditation or candidacy for accreditation of an institution applies to those units, programs, and other educational activities which were included in the institutional self-study and were reviewed by an evaluation committee as required by the Commission on Colleges. Because institutions are in the continual process of change, the Commission requires that all institutions be reevaluated periodically. Most changes, such as adding or dropping courses, developing new concentrations that are allied with existing offerings, and changing personnel, are not substantive and fall within the nature and scope of the institution as last evaluated. However, a change of such magnitude as to alter significantly an institution's mission and goals, or the scope of its offerings; to alter its autonomy, sponsorship, or the locus of control over it; to embark upon offering off-campus academic programs for credit; or to change the geographic area(s) served, is considered by the Commission to be major substantive changes.

Substantive changes initiated subsequent to the most recent evaluation are not automatically included in the institution's accredited or candidate status. While the decision to modify an institution is an institutional prerogative and responsibility, the Commission is obligated to determine the effect of a substantive change on the validity of an institution's recognition by the Commission.

Major and Minor Changes. Careful consideration is sometimes necessary in deciding if an institutional change is substantive and, if so, whether or not the substantive change is major or minor in nature. Size, complexity, maturity, and experience of the institution in effecting significant change are important factors. What might be a minor change for a well-established institution may well be viewed as a major change for a candidate or newer member. A table is provided at the end of this policy which lists examples of substantive changes and indicates whether they likely are major or minor changes for candidates/new members and well-established/experienced institutions.

Notification. An institution, in considering a substantive change, is required to notify the Commission early in its deliberations. Early notification enables the staff to provide information and advice about the effect of the proposed change on the accreditation or candidate status of the institution and the procedures to be followed in seeking approval.

Major Substantive Change. The Commission on Colleges is concerned primarily with major substantive changes and relies upon the staff of the Commission to determine if a proposed substantive change is major or minor in nature. Usually, it is possible for the executive director to make such a determination. The institution is requested to describe, in a letter to the executive director of the Commission, the nature and purposes of the proposed change. If the institution disagrees with the decision of the staff, the matter may be referred to the Commission for reconsideration.

Prospectus. The purpose of the prospectus is for the institution to set forth the activities constituting the change and the impact expected on the institution as a whole. For a proposed major substantive change, a prospectus is to be submitted in six copies. The prospectus should be printed on both sides and unbound. The Commission staff will review the prospectus and request any further information that is needed. The information to be provided in the prospectus will depend upon the nature of the proposed change. The following items are required:

a. a clear statement of the nature and purposes of the change in the context of institutional mission and goals;

b. evidence of formal authorization by the governing board and by the appropriate governmental agency to grant degrees. If the institution is located in, or operates in, a state that has only minimal requirements for chartering, but also a higher level of authorization to operate and grant degrees, this higher level is required;

c. descriptive information of the educational offering(s) and evidence of approval by the appropriate academic policy body of the institution;

d. plans and descriptive materials indicating evidence of need for the change, the student clientele to be served, the procedures used in arriving at the decision to change, the organizational arrangements that must be made within the institution to accommodate the change, and a timetable for implementation; and

e. the budget projections (revenue and expenditures) for each of the first three years including:

1. revenue and expenditures associated with the change itself, and

2. institutional financial support to be reallocated to accommodate the change.

The budgetary and financial implications of the change for the entire institution also should be addressed. (Include a copy of the institution's most recent IPEDS financial report.)

When an institution seeks approval of a branch campus as a substantive change, this prospectus must include e.1 and e.2 above, as part of the business plan required by 34 CFR 602.27. Revenues and expenditures must include a cash flow analysis. (See ** page 105.)

f. provision for student services to accommodate the change and its implications for services to the rest of the student body;

g. provision for physical facilities, equipment, and library and information resources; and the impact on the institution's resources as a whole; and

h. an analysis of the faculty and staff needed, the educational and professional experience qualifications of the faculty members relative to their individual teaching assignments, and the anticipated sources of qualified faculty and staff.

Commission Review of the Prospectus. In order to expedite consideration of a substantive change prospectus, the Commission will utilize the following procedures. Member institutions may submit a prospectus for substantive change at any time during the year. Upon receipt of a prospectus, a Commission staff member will do an analysis of the prospectus and send a copy of the prospectus and the analysis to three members of the Commission, who will each review the prospectus. In conducting their reviews, the Commissioners will consider the impact of the proposed change on existing programs, resources, and services and judge whether it is reasonable to expect that the standards can continue to be met acceptably. The Commissioners will submit their findings to the executive director of the Commission and may recommend any of the following actions:

a. approve the prospectus without conditions;

b. approve the prospectus with specified conditions;

c. deny approval of the prospectus; and

d. recommend consideration by the Commission at the next scheduled meeting (December or June).

If the prospectus is approved by all three Commissioners, the institution will be notified by the Executive Director to proceed with the change and the topic will be on the agenda of the Commission's next meeting as an information item. If one or more of the Commissioner-reviewers recommend that the prospectus be denied, the institution will be notified, given the reasons for the denial and may choose to provide thirty copies of the original or a revised prospectus for consideration by the Commission at its next regularly scheduled meeting.

Commission Actions. If a prospectus is considered at a regular meeting of the Commission on Colleges, the Commission reviews the prospectus; considers the impact of the proposed change on existing programs, resources, and services; and judges whether it is reasonable to expect that the standards can continue to be met acceptably. Institutional representatives may be requested to appear before the Commission to give a brief oral presentation and to answer questions. The Commission will take one of the following actions: 1) accept the prospectus without condition, 2) accept the prospectus with conditions, 3) defer action pending the receipt of additional information, or 4) deny approval of the prospectus. Within one month following the Commission meeting, the president of the institution is notified in writing of the action taken and the reasons for the action. If the prospectus is denied, the reasons are specified in the written notification. If an institution proceeds to implement a substantive change without prior written notice to the Commission or if it proceeds to implement a substantive change that the Commission has denied, the Commission will consider issuance of an order for the institution to show cause why its accreditation or candidate status should not be discontinued.

If a prospectus for offering a degree program at a higher level than listed in the Directory in the current Annual Proceedings of the Northwest Association is accepted, the institution receives informal candidate status at the higher level while retaining accreditation at the lower degree level. For all other kinds of substantive changes, the change is included under the accreditation of the institution, upon approval by the Commission.

Institutional Reports and On-Site Evaluations. When an institution has informal candidate status at a higher degree level, it is expected to conduct a comprehensive self-study and be visited by a full evaluation committee during the academic year following the graduation of the first class. The policies and procedures for full-scale evaluations as listed in the Accreditation Handbook will apply, and the action taken by the Commission following such evaluation will apply to the accreditation of the changed institution as a whole, not merely to the part of the institution that has changed. The effective date of accreditation at the higher degree level is September 1 of the academic year preceding the one in which the evaluation took place.

For all other kinds of major substantive change, the Commission normally schedules and conducts an on-site evaluation within six months to a year following the approval of the change. Depending upon the nature of the major change, the evaluation may be limited in scope or be more comprehensive. The size and composition of the on-site evaluation committee will depend on the nature of the substantive change. The dates for the on-site evaluation are set by the Commission staff in consultation with appropriate officials of the institution.

Prior to the visit, the institution submits a concise report in 34 copies that assesses the effect of the major substantive change during the first year. This report need not repeat material submitted in the prospectus, but should provide evidence and analysis of:

a. the effects of the change on the total institution;

b. desirable revisions in the change based on the first year's experience;

c. in the case of a new program or one offered in a new location,

(1) the adequacy of administrative, faculty, financial, library, and facilities support for the program's objectives, and

(2) evidence for the program's effectiveness;

d. plans for continuing assessment of the effectiveness of the change and of its impact on the institution as a whole.

Minor Substantive Change. The Commission recognizes the importance of constructive institutional change and does not want to inhibit such change. The Commission also recognizes that while some changes are substantive because they affect the mission and goals, scope, or form of control of an institution, other changes are limited in nature and the procedures that apply for a major substantive change are not appropriate. When the Commission staff determines that a proposed substantive change is minor in nature, the change may be approved by the executive director on behalf of the Commission.

A prospectus for a minor substantive change is to provide the same information as requested for a major substantive change (6 copies). The review procedures are comparable to those for a major substantive change except that the Commission staff conducts the review and the executive director is authorized to take action. In case of a negative decision, the matter may be referred to the Commission on Colleges for reconsideration at the request of the institution. For a minor substantive change, an on-site evaluation within a year following the approval of the change may or may not be scheduled, depending on the nature of the change and other factors.

Nature of Change

Candidates/ New Members

Well Established/ Experienced Institutions

1. Mission and goals, other than minor refinements		Major		Major
2. Legal status, sponsorship, control including merger with another institution (visit within six months)		Major		Major
3. Addition of a degree program at a higher level than listed for the institution in the NASC Directory (See * page 105.) 4. Establishment of a branch campus (visit within six months) (See ** page 105.)		Major   Major		Major   Major
5. Establishment of an external degree program		Major		Major
6. Offering courses or program(s) for academic credit outside the NASC region		Major		Major
7. Offering program(s) for academic credit on a military base		Major		Major
8. Contractual agreement with non-regionally accredited organization for the organization to provide courses and program(s) for academic credit on behalf of the candidate or accredited institution		Major		Major
9. Offering program(s) for academic credit within the NASC region but in other geographic area(s) than the one(s) previously reported and evaluated		Major		Major

10. Establishing a new degree program not closely related to other fields of study previously reported and evaluated 11. Offering a degree-completion program or offering programs by distance delivery (See Policy 2.6, pages 44-47.) 12. A change from clock hours to credit hours or vice versa or a substantial increase or decrease in the length of a program or the number of clock or credit hours awarded for successful completion of a program.	Major   Major     Minor		Major/Minor   Major
Minor13. Offering program(s) for academic credit in the geographic area(s) previously reported and evaluated but at new off-campus sites		Minor		(No Change)
14. Offering a new program on a trial basis or for a limited time, such as during a summer session or for a special group		Minor		(No Change)
15. Offering a few new courses for academic credit at off- campus sites in the geographic area(s) previously reported and evaluated		Minor		(No Change)
16. Establishing a new degree program closely related to well- established fields of study at the institution that have been previously reported and evaluated		Minor		(No Change)
17. Adding or dropping a modest number of courses in the programs offered		(No Change)		(No Change)

*Program. A systematic, usually sequential, grouping of courses forming a considerable part, or all, of the requirements for a degree or credential.

** Branch Campus: A location of an institution that is geographically apart and independent of the main campus and (1) is permanent in nature; (2) offers at least 50% of the courses of an educational program leading to a degree, certificate, or other educational credential; (3) has its own faculty and administrative organization; and (4) has its own budgetary and hiring authority.

Adopted 1972/Revised 1978, 1994, 1996

A-3 Disclosure of Accrediting Documents and Commission Actions

Disclosure of Accrediting Documents

The records of the Commission, including self-study and visiting committee reports, are confidential as described in Policy B-3 - Code of Good Practice in Accrediting in Higher Education, pages 139-140.

Self-study and Other Institutional Reports. Institutions are encouraged to distribute throughout the institution the self-study and other reports filed with the Commission.

The Commission, with the approval of the institution, may permit representatives from other institutions access to the self-study or other reports, if helpful to their self-study or accreditation processes. Also, with prior approval of the institution, the Commission may allow self-studies and other reports to be used by educators who are conducting research relating to the accreditation process and institutional improvement.

Evaluation Committee Reports. Institutions are encouraged to distribute the evaluation committee report widely within the college community and especially to the governing board. The institution should take special effort to avoid publication or distribution of excerpts that quote only those portions favorable to the institution or that take statements out of their context in the report. This mandate does not preclude individual schools or departments from quoting with objectivity portions relating only to them. When selective quotations are made in public documents, the institution must also indicate that a copy of the entire report can be obtained from the institution.

The Commission, as a general rule, will not release committee reports to the public. If an institution releases only selected portions of the report, the Commission reserves the right to release the entire report.

Public Statements by Institutions. If an institution uses a public forum to take issue with an official action of the Commission relating to the institution, or conducts its affairs such that they become a matter of public concern, the Commission may announce, through the Executive Director, the action taken, the basis for that action, and make public any pertinent information available to it.

Public Disclosure by the Commission About Institutions. Upon inquiry, the Commission will release the following information about accredited, candidate, or applying institutions:

1. The status of candidacy application(s) made and Commission decisions concerning those applications;

2. The date when initial candidacy was granted;

3. The date of denial or removal from candidacy;

4. The date and nature of the most recent on-site evaluation or special report, and subsequent Commission action regarding the institution's candidate or accredited status;

5. The date and nature of the next scheduled on-site evaluation or special report required by the Commission;

6. The date when institutions were placed on probation or show-cause status, denied initial candidacy or accreditation, or had their candidacy or accreditation terminated; and

7. Whether or not the institution has appealed a negative action of the Commission, and, if so, the status and outcome of such an appeal.

Commission Decisions on Institutions

Once the Commission has made a decision regarding candidacy or accreditation of an institution, it will notify the institution, in writing, as promptly as possible. The forms of possible Commission action with regard to institutions are to:

1. Defer action on the institution's application for candidacy or accreditation.

2. Deny the institution's application for candidacy or accreditation.

3. Grant Candidacy or Initial Accreditation.

4. Extend Candidacy or reaffirm Accreditation.

5. Request a Progress Report or a Focused Interim Visit.

6. Issue a Warning.

7. Impose Probation or continue Probation for a specific period of time.

8. Issue a Show-Cause order with accreditation to terminate unless the institution has demonstrated, to the satisfaction of the Commission, that it has satisfied the Commission's concerns or responded to its directives prior to a specified date.

9. Terminate Candidacy or Accreditation.

All of the Commission actions set forth above, except number six, are published in the annual Proceedings and in the minutes of the Commission meeting at which the action took place. In addition, in taking any of the above actions, the Commission may impose conditions on continued accreditation or candidacy status or request additional reporting or site visits.

Negative Decisions. Sanctions may be applied to an institution when the Commission concludes that the institution is in serious non-compliance with one or more Commission standards, policies, or eligibility requirements. If the Commission takes a negative action regarding an institution, the reason(s) will be stated in the Commission's action letter to the institution. The intent of a sanction is to highlight the immediate need for an institution to bring itself into compliance. While the Commission has discretion to determine the appropriate course of actions, 34 CFR Part 602.26(c) provides that the Commission must require that an institution bring itself into compliance with accreditation standards and policies within a specific period which may not exceed:

1. Twelve months, if the program is less than one year in length;

2. Eighteen months, if the program is at least one year, but less than two years, in length; or

3. Two years, if the program is at least two years in length.

The nature and gravity of an institutional deficiency will determine whether or not, in the judgment of the Commission, one of the following five actions will be taken. While these alternatives are of increasing severity, they are not necessarily applied sequentially by the Commission. The Commission may apply any of these alternatives any time it takes a formal action on an institution.

Deferral or Denial of Candidacy or Accreditation. The candidacy or accreditation of an initial applicant or reapplicant institution may be deferred or denied as defined in the following statements:

1. A deferral is not a final decision. It is interlocutory in nature and designed to provide further guidance and time for the institution to correct certain deficiencies or supply specifically requested information.

2. A denial is a final decision that is subject to appeal under the published appeal policies and procedures.

Warning. When the Commission finds that an institution has pursued a course that, if continued, could lead to more serious sanctions, it may issue to the institution a Warning to correct its deficiencies, to refrain from certain activities, or to initiate certain activities, within a stated period of time. A Warning does not affect the candidate or accredited status of the institution and will not be made public by the Commission.

Probation. When a candidate or accredited institution fails to respond to the concerns (including Warning) communicated by the Commission or when it deviates significantly from the Commission's standards, policies, or eligibility requirements, but not to such an extent as to warrant the issuing of a Show-Cause order or withdrawal of candidacy or accreditation, the institution may be placed on Probation for a specified period of time. While on Probation, the institution may be subject to special monitoring 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, during the Probation period, any new site or degree program initiated by the institution will be regarded as a major substantive change. (See Policy A-2 - Substantive Change, pages 100-105.) The candidate or accredited status of the institution continues during the Probation period.

One copy of the Probation action letter will be sent to the chief executive officer and one copy will be sent to the chair of the governing board.

Show-Cause. When the Commission finds that an institution has not taken satisfactory steps to remove the causes for its having been placed on Probation or when an institution has not responded to a Warning issued by the Commission or to conditions imposed on it by the Commission, or when an institution neither under Warning nor on Probation is found to have deviated substantially from Commission standards, policies, or eligibility requirements, the Commission may require the institution to show cause why its candidacy or accreditation should not be terminated at the end of a stated period. In such cases, the burden rests with the institution to demonstrate why its candidacy or accreditation should be continued beyond the stated period. The candidate or accredited status of the institution continues during the show-cause period, and any new site or degree program initiated by the institution will be regarded as a major substantive change (for further information, see Policy A-2 - Substantive Change, pages 100-105). In addition, the institution will be subject to special monitoring by the Commission, which may include a requirement to submit periodic prescribed reports and to receive special visits by representatives of the Commission.

One copy of the Show-Cause action letter will be sent to the chief executive officer and one copy will be sent to the chair of the governing board.

Termination of Candidacy or Accreditation. If, in the judgment of the Commission, an institution has not satisfactorily corrected deficiencies noted by the Commission and communicated to the institution, its candidacy may be terminated or allowed to lapse or its accreditation may be terminated. In such a case, the institution must complete again the entire application process to qualify for candidacy. Termination of candidacy or accreditation is subject to appeal under the applicable policies and procedures of the Commission. If an institution's candidacy is terminated, or if its accreditation is terminated, and if it requests an appeal, its status will continue unchanged until the appeal processes have been completed. Otherwise, its candidacy or accreditation ends on the date when the deadline for filing an appeal expires. Termination of candidacy or accreditation becomes effective July 1 following action taken at a December Commission meeting and January 1 following action taken at a June Commission meeting.

Notification to Appropriate State Agency and United States Secretary of Education. The Commission on Colleges, within 30 days of the final decision to withdraw accreditation or candidate for accreditation status of a postsecondary institution, will notify the Secretary of the U.S. Department of Education, the Council for Higher Education Accreditation, other recognized institutional accrediting agencies, and the appropriate agency of the state in which the institution is based. Such final action also will be reported in the Annual Proceedings of the Northwest Association of Schools and Colleges.

Adopted 1994/Revised 1996, 1997

A-4 Conflict of Interest

In carrying out its accreditation responsibilities, the Commission on Colleges seeks to ensure that its decisions are based solely on the application of professional judgment to the information resulting from its evaluation procedures. Therefore, it seeks to avoid both the reality and the appearance of a conflict of interest. For purposes of this policy, a conflict of interest is defined as:

a circumstance in which an individual's capacity to make an impartial or unbiased accreditation decision may be affected because of prior, current, or anticipated institutional affiliation(s), other significant relationship(s) or association(s) with the institution under review.

The following are examples of affiliations that should be disclosed to the Commission staff for discussion and evaluation.

Affiliation:

employee, former employee, board member, appointee, consultant, or graduate;

Other Significant Relationships:

affiliation with another institution in the same system of public higher education, or with which there is a significant religious connection;

affiliation with another institution which is a member of a consortium or has a substantial cooperative or contractual arrangement with the institution under review;

affiliation with an institution competing directly with the institution under review;

having a close relative affiliated with the institution under review;

sought or seeking a position at the institution under review;

Other Associations:

knowledge or personal interest concerning the institution under review from whatever source, including competitive geographical proximity, which might prejudice decision-making.

Evaluation Committee Members. In selecting evaluation committees, the Commission avoids individuals who have, or appear to have, a conflict of interest in participating in a specific institutional review. However, the Commission also recognizes that it is not possible to be aware of all circumstances where a conflict, or the appearance of a conflict, may obtain. Therefore, institutions, in reviewing proposed evaluation committees, are encouraged to bring to the attention of Commission staff any conflicts of interest or the appearance of such. Individuals invited to participate in the evaluation process are expected to decline to serve in the evaluation of an institution where they have, or where it might reasonably appear that they have, a conflict of interest; potential evaluators are expected to disclose possible conflicts or appearance of conflict to Commission Staff.

In addition, an evaluator is expected to refrain from serving as a consultant, paid or otherwise. The Commission also views as conflict of interest an evaluator's intent to use an institutional evaluation visit as an opportunity to seek employment.

Commissioners. Commission members are committed to full disclosure and restraint in any institutional consideration involving a conflict of interest. Members of the Commission will absent themselves from deliberations or votes on decisions regarding institutions with which they are affiliated. They do not participate in discussions or vote on decisions on institutions to which they have acted as consultants or with which they have relationships or other associations where they have, or where it would reasonably appear they have, a conflict of interest. Commissioners who are uncertain regarding the possible appearance or reality of conflict of interest shall seek the advice of the Commission chair. At the request of the Commission chair, the Commission can determine the question by vote. In general, however, if there is any doubt on the part of a Commissioner, it should be resolved by the Commissioner refraining from any discussion or action relating to the institution under review.

Commission Staff. The Commission staff members are committed to full disclosure and restraint in any institutional consideration involving a conflict of interest. The Commission staff is responsible for managing the accreditation process and for ensuring that all policies and procedures are carried out fairly. The staff does not engage in the evaluation of institutions, nor does it take responsibility for operating the accreditation process at individual institutions. However, the staff is responsible for providing advice and assistance on request, and is otherwise involved in developing and providing services to assist institutions in structuring their own use of accreditation procedures.

Adopted 1996

A-5 Public Notification and Third Party Comments Regarding Full-Scale Evaluations

It is the policy of the Commission on Colleges, in accordance with 34 CFR 602.27 (c)(5), to publish the year when candidate or member institutions are being considered for initial or continuing accreditation. The Commission also provides an opportunity for third-party comment, in writing, concerning the institution's qualifications for candidacy or accreditation.

Procedures

A. Procedure for Publication by Institutions

In accordance with Commission policy, an institution that is scheduled for a full-scale evaluation advertises to its publics that a visit is scheduled and invites their comments. Comments will be accepted only when they are submitted in writing and signed.

1. Dissemination of notification. In most cases, a local newspaper will be the most appropriate vehicle for an announcement of a forthcoming visit. However, the Commission recognizes that an institution's opportunities and vehicles for reaching its publics vary from place to place. In some situations, submitting a press release to a newspaper may not ensure publication; it may be necessary for the institution to purchase space in an appropriate publication or find other means of publicizing the visit.

Alumni magazines and campus newsletters may also be useful ways to communicate to certain constituencies. An institution with operations off-campus, including those outside the United States, should find ways to provide appropriate notification to those affected by the institution's presence at those sites.

2. Content of notice. The Commission does not prescribe specific language for the public notification of impending visit. However, the Commission recommends that the institution's announcement include the following information:

a) the purpose of the forthcoming visit;

b) the dates of the visit;

c) the institution's current accreditation status with the Commission on Colleges;

d) the year of the most recent Commission action relating to the institution; and

e) an invitation to send comments directly to the Commission that includes the Commission's address and the date by which comments must be received (no later than one month before the visit).

3. Timing of the notice. The notice should appear three to four months before a full-scale evaluation. The institution sends a photocopy of the printed notice to the Commission headquarters.

B. Procedure for Publication by the Commission

In accordance with Commission policy, the Commission publishes the list of institutions scheduled for evaluation through appropriate Commission publications and invites comments from third parties. Comments will be accepted only when they are submitted in writing and signed.

1. Distribution of notification. The primary means of publicizing the list of institutions for evaluation are the newsletter of the Northwest Association of Schools and Colleges and the minutes of the Commission's meeting held in June and December each year. The Commission may also provide lists of institutions scheduled for evaluation through other means, such as letters or announcements, to specific groups such as state agencies.

2. Content of notice:

a) the names of institutions scheduled for full-scale evaluation (i.e., initial candidacy, initial accreditation, or continued accreditation);

b) the dates the evaluation is scheduled to begin; and

c) the address of the Commission's headquarters to which comments and information may be sent and the date by which comments must be received (no later than one month before the visit).

C. Commission's Procedure for Handling Third-Party Comments

1. The office of the Commission on Colleges will acknowledge, in writing, the receipt of all written third-party comments pertaining to an institution's qualification for candidacy or accreditation.

2. Copies of third-party comments will be made available to members of the evaluation committee and to the institution being visited for candidacy or accreditation at least ten days prior to the scheduled evaluation.

3. The institution being evaluated may respond, in writing, to the chair of the evaluation committee. Such response is to be provided no later than the beginning of the on-campus evaluation.

4. The evaluation committee will consider third-party comments and the institution's written response along with all other information available during the evaluation process.

5. The Commission will maintain a file of third-party comments for each institution, and a copy of the letter acknowledging the third-party comments. These records will be maintained for at least five years.

Adopted 1996

A-6 Contractual Relationships with Organizations Not Regionally Accredited

No postsecondary educational institution accredited by a regional institutional accrediting commission can lend the prestige or authority of its accreditation to authenticate courses or programs offered under contract with organizations not so accredited unless it demonstrates adherence to the following principles:

a. The primary purpose of offering such a course or program is educational. (Although the primary purpose of the offering must be educational, what ancillary purposes also provide the foundation for the program or course, such as auxiliary services, anticipated income, and public relations?)

b. Any course offered must be consistent with the institution's educational mission and goals as they were at the time of the last evaluation. If the institution alters its mission and goals, the regional commission must be notified and the policy on substantive change applied. (How does the institution define the specific relationship between the primary and ancillary purposes and the contracted service, and how does it demonstrate its capability to attain these objectives?)

c. Courses to be offered and the value and level of their credit must be determined in accordance with established institutional procedures and under the usual mechanisms of review. (What evidence exists that established institutional procedures have been followed?)

d. Courses offered for credit must remain under the sole and direct control of the sponsoring accredited institution which exercises ultimate and continuing responsibility for the performance of these functions as reflected in the contract, with provisions to ensure that conduct of the courses meets the standards of its regular programs as disclosed fully in the institution's publications, especially as these pertain to:

1) recruitment and counseling of students;

2) admission of students to courses and/or to the sponsoring institution where credit programs are pursued;

3) instruction in the courses;

4) evaluation of student progress;

5) record keeping;

6) tuition and/or fees charged, receipt and disbursement of funds, and refund policy;

7) appointment and validation of credentials of faculty teaching the course;

8) nature and location of courses; and

9) library and information resources.

Additional data needed would include course outlines, syllabi, copies of exams, records of students, and evidence of equivalencies with established programs.

Requirements for Contractual Arrangements.

In establishing contractual arrangements with organizations not regionally accredited, institutions are expected to demonstrate that the following requirements have been met. The not-for-profit institutions should establish that their tax exempt status, as governed by state or federal regulations, will not be affected by such contractual arrangements with a for-profit organization.

a. The Contract:

1) should be executed only by duly designated officers of the institutions and their counterparts in the contracting organization. While other faculty and administrative representatives will undoubtedly be involved in the contract negotiations, care should be taken to avoid implied or apparent power to execute the contract by unauthorized personnel.

2) should establish a definite understanding between the institution and contractor regarding the work to be performed, the period of the agreement, and the conditions under which any possible renewal or renegotiation of the contract would take place;

3) should clearly vest the ultimate responsibility for the performance of the necessary control functions for the educational offering with the accredited institution granting credit for the offering. Such performance responsibility by the credit-granting institution would minimally consist of adequate provisions for review and approval of work performed by the contractor in each functional area.

4) should clearly establish the responsibilities of the institution and contractor regarding:

a) indirect costs

b) approval of salaries

c) equipment

d) subcontracts and travel

e) property ownership and accountability

f) inventions and patents

g) publications and copyrights

h) accounting records and audits

i) security

j) termination costs

k) tuition refund

l) student records

m) faculty facilities

n) safety regulations

o) insurance coverage

b. Enrollment Agreement

1) The enrollment agreement should clearly outline the obligations of both the institution and the student, and a copy of the enrollment agreement should be furnished to the student before any payment is made.

2) The institution should determine that applicants are fully informed about the nature of the obligation they are entering into, and their responsibilities and rights under the enrollment agreement before they sign it.

3) No enrollment agreement should be binding until it has been accepted by the authorities of the institution vested with this responsibility.

c. Tuition Policies

1) Rates

a) The total tuition for any specific given course should be the same for all persons at any given time. Group training contracts showing lower individual rates may be negotiated with business, industrial, or governmental agencies.

b) Tuition charges in courses should be bona fide, effective on specific dates, and applicable to all who enroll thereafter or are presently in school, provided the enrollment agreement so stipulates.

c) All extra charges and costs incidental to training should be disclosed to prospective student before they are enrolled.

d) The institution should show that the total tuition charges for each of its courses are reasonable in the light of the service to be rendered, the equipment to be furnished, and its operating costs.

2) Refunds and Cancellations

a) The institution should have a fair and equitable tuition refund and cancellation policy.

b) The institution should publish its tuition refund and cancellation policy in its catalog or other appropriate literature.

3) Collection Practices

a) Methods used by an institution in requesting or demanding payment should follow sound and ethical business practices.

b) If promissory notes or contracts for tuition are sold or discounted to third parties by the institution, enrollees or their financial sponsors should be aware of this action.

d. Student Recruitment

1) Advertising and Promotional Literature

a) All advertisements and promotional literature used should be truthful and avoid leaving any false, misleading, or exaggerated impressions with respect to the school, its personnel, its courses and services, or the occupational opportunities for its graduates.

b) All advertising and promotional literature should clearly indicate that education, not employment, is being offered.

c) All advertising and promotional literature should include the correct name of the school. So-called "blind" advertisements are considered misleading and unethical.

2) Field Agents

a) An institution is responsible to its current and prospective students for the representations made by its field representatives (including agencies and other authorized persons and firms soliciting students), and therefore should select each of them with the utmost care, provide them with adequate training, and arrange for proper supervision of their work.

b) It is the responsibility of an institution to conform to the laws and regulations of each of the states in which it operates or solicits students and in particular to see that each of its field representatives working in any such state is properly licensed or registered as required by the laws of the state.

c) If field representatives are authorized to prepare and/or run advertising or to use promotional materials, the institution should accept full responsibility for the materials used and should approve any such promotional materials in advance of their use.

d) When field representatives are authorized to collect money from an applicant for enrollment, they should leave with the applicant a receipt for the money collected and a copy of the enrollment agreement.

e) No field representative should use any title, such as "counselor," "advisor," or "registrar" which may indicate that duties and responsibilities are other than they actually are.

f) No field representative should violate, orally or otherwise, any of the standards applicable to advertising and promotional materials.

Adopted 1973

A-7 Principles of Good Practice in Educational Courses and Programs Offered Outside the United States

It is the policy of the Commission on Colleges to require adherence to the following principles. The Commission recommends the accompanying practices to all institutions within its jurisdiction:

a. Institutional Mission and Goals

1) The international program is rooted in the U.S. institution's stated mission and goals and reflects any special social, religious, and ethical elements of that mission.

2) The faculty, administration, and governing board of the U.S. institution understand the relationship of the international program to the institution's stated mission and purposes.

b. Authorization

1) The international program has received all appropriate internal institutional approvals, including that of the governing board.

2) The international program has received all appropriate external approvals where required, including system administration, government bodies, and accrediting associations.

3) The U.S. institution documents the accepted legal basis for its operations in the host country.

c. Instructional Program

1) The U.S. institution specifies the educational needs to be met by its international program.

2) The content of the international educational program is subject to review and approval by the faculty of the U.S. institution.

3) The international education program reflects the educational emphasis of the U.S. institution, including a commitment to general education when appropriate.

4) The program is taught by faculty with appropriate academic preparation and language proficiencies, and whose credentials have been reviewed and approved by the U.S. institution.

5) The standard of student achievement in the international program is equivalent to the standard of student achievement on the U.S. campus.

6) The international education program, where possible and appropriate, is adapted to the culture of the host country.

d. Resources

1) The institution currently uses and ensures the continuing use of adequate physical facilities for its international educational program, including classrooms, offices, libraries, and laboratories, and provides access to computer facilities where appropriate.

2) The U.S. institution has demonstrated its financial capacity to underwrite the international program without diminishing its financial support of the U.S. campus. Financing of the international program is incorporated into the regular budgeting and auditing process.

e. Admissions and Records

1) International students admitted abroad meet admissions requirements similar to those used for international students admitted to the U.S. campus, including appropriate language proficiencies.

2) The U.S. institution exercises control over recruitment and admission of students in the international program.

3) All international students admitted to the U.S. program are recognized as students of the U.S. institution.

4) All college-level academic credits earned in the international program are applicable to degree programs at the U.S. institution.

5) The U.S. institution maintains official records of academic credit earned in its international program.

6) The official transcript of record issued by the U.S. institution follows the institution's practices in identifying, by site or through course numbering, the credits earned in its off-campus programs.

f. Students

1) The U.S. institution ensures that its institutional program provides a supportive environment for student development, consistent with the culture and mores of the international setting.

2) Students in the international program are fully informed as to services that will or will not be provided.

g. Control and Administration

1) The international program is controlled by the U.S. institution.

2) The teaching and administrative staff abroad, responsible for the educational quality of the international program, are accountable to a resident administrator of the U.S. institution.

3) The U.S. institution formally and regularly reviews all faculty and staff associated with its international program.

4) The U.S. institution assesses its international program on a regular basis in light of institutional goals, and incorporates these outcomes of such assessments into its regular planning process.

h. Ethics and Public Disclosure

1) The U.S. institution can, upon request, provide to its accrediting agencies a full accounting of the financing of its international program, including an accounting of funds designated for third parties within any contractual relationship.

2) The U.S. institution ensures that all media presentations about the international program are factual, fair, and accurate.

3) The U.S. institution's primary catalog describes its international program.

4) The U.S. institution does not sell or franchise the rights to its name or its accreditation.

5) The U.S. institution ensures that all references to transfer of academic credit reflect the reality of U.S. practice.

6) The U.S. institution ensures that if U.S. accreditation is mentioned in materials related to the international program, the role and purpose of U.S. accreditation is fairly and accurately explained within these materials.

i. Contractual Arrangements

1) The official contract is in English and the primary language of the contracting institution.

2) The contract specifically provides that the U.S. institution controls the international program in conformity with these guidelines and the requirements of the U.S. institution's accreditation.

3) The U.S. institution confirms that the foreign party to the contract is legally qualified to enter into the contract.

4) The contract clearly states that the legal jurisdiction under which its provisions will be interpreted will be that of the U.S. institution.

5) Conditions for program termination specified in the contract include appropriate protection for enrolled students.

6) All contractual arrangements must be consistent with the regional commission's document, Policy A-6 - Contractual Relationships with Organizations Not Regionally Accredited, pages 112-115.

Adopted 1992

A-8 Principles and Practices Regarding Institutional Mission and Goals, Policies and Administration

It is the policy of the Commission on Colleges to require adherence to the following principles. The Commission recommends the accompanying practices to all institutions within its jurisdiction:

a. Institutional Mission and Goals

Principle: An institution's current operation should reflect its statement of mission and goals with reasonable accuracy and should be supported by appropriate faculty and staff, programs, facilities, and finances.

Recommended Practices:

1) Document the adequacy of faculty for programs offered and monitor competency through explicit evaluation of faculty performance.

2) Encourage and assist all members of the faculty in continuous professional growth, including provision to terminate the services of faculty members who have become ineffective.

3) Implement faculty security through ethical appointment, advancement, and termination procedures.

4) Provide salaries and benefits which enable faculty to live with dignity and which are reasonably competitive with similar institutions.

5) Encourage research and scholarly/creative activity by faculty as appropriate to institutional goals.

6) Employ sufficient personnel to keep academic and support programs functioning efficiently.

7) Maintain regular and open channels of communication within the entire institutional community.

8) Develop a curriculum which is responsive to institutional purposes, faculty qualifications, and student needs.

9) Plan curricular changes on the basis of known resources, agreed-upon goals, and the strength of existing programs.

10) Own, or have at its disposal, physical facilities adequate to support institutional purposes.

11) Plan for reasonable maintenance and ultimate replacement of buildings and equipment currently in use.

12) Prepare realistic operating budgets, develop feasible funding patterns, and demonstrate fiscal responsibility in utilizing resources.

13) Have verified information available to give a complete picture of the institution's financial position.

14) Provide and publicize an appropriate student financial aid program.

b. Institutional Policies

Principle: The policies of each institution should conform to its mission and goals, be clearly stated, easily available, and consistently made evident in operation.

Recommended Practices:

1) Publish a current catalog to give detailed information concerning admissions, curriculum, academic regulations, student costs, and services.

2) Maintain and publish a reasonable tuition refund policy.

3) Maintain records to document student achievement and institutional practice.

4) Publish clearly stated rules regarding conduct on campus.

5) Maintain an up-to-date, published compendium of policies and institutional practices which guide institutional operations.

6) Foster freedom of expression while protecting the rights of all members of the institutional community.

7) Provide explicit and fair procedures for hearing grievances and appealing administrative decisions.

c. Institutional Administration

Principle: An institution should be governed and administered humanely, responding to the educational needs and legitimate claims of the constituencies it serves, as determined by its chartered purposes and accredited status.

Recommended Practices:

1) Take action to see that there is no discrimination in the campus community based on race, religion, color, national origin, sex, or age.

2) Publish candidly any reasonable limitations on freedom of inquiry or expression which are dictated by institutional mission and goals.

3) See that the resources of the institution are focused exclusively toward fulfilling its stated function.

4) Have a capable governing board which recognizes its responsibility to the public as well as its duty to protect the institution from undue outside pressures.

5) Keep the policy-making function of the governing board clearly apart from the executive responsibilities of institutional administrators.

6) Prohibit members of its governing boards, faculty, or staff from having any financial or other interests which conflict with the proper discharge of their duties.

7) Prepare information which the governing board will need to provide overall direction, and make this information available through appropriate channels.

8) Provide capable counselors who are easily accessible to students and who make available psychological and educational tests appropriate to the institution.

9) Provide for student health services and reasonably adequate housing and food services appropriate to the size, location, and nature of the institution.

10) Make assistance available to students and alumni in securing appropriate employment.

Adopted 1980

A-9 Non-Credit, Extension, and Continuing Education Studies

Non-credit educational courses, programs, and activities in post-secondary education have increased significantly in recent years. It is expected that postsecondary educational institutions will play a primary role in providing relevant continuing education programs of quality for the professions, business and industry, and the public in general. They can also provide guidance to others who will be producing similar programs outside of the traditional institutional framework.

The Commission on Colleges, supportive of the important public and community service functions of postsecondary institutions, commends the variety of non-credit adult, extension, and continuing education opportunities provided by many accredited and candidate institutions. These are integral parts of such institutions' total education program, designed to fulfill stated objectives and to meet their responsibilities to constituents.

Where such offerings are included in an institution's educational program, careful attention needs to be given to developing a comprehensive record system which gives appropriate recognition to the individual student and also properly accounts for the institutional effort and resources expended.

Among the systems currently in use is the Continuing Education Unit (CEU), an adaptable unit of measure for non-credit activities. The CEU can be used to record an individual's participation in formal classes, courses, and programs as well as in nontraditional modes of non-credit education, including various forms of independent, informal, and experiential study and learning.

The CEU or comparable measures apply only to non-credit courses, programs, and experiences, however, and care must be taken to prevent uses for which they are not intended or which would distort their limited purposes. It is especially important that the CEU or comparable units not be used to inhibit or impede educational innovation and experimentation.

Adopted 1975

A-10 Postsecondary Education Programs on Military Bases

The Commission on Colleges is pleased to note that the military services are very much aware of the critical need for well-educated manpower and fully endorses the development of educational programs on military bases designed to provide for the personal and professional growth of personnel through educational courses and programs in cooperation with accredited and candidate postsecondary institutions.

Institutions are encouraged to cooperate with the military services in designing appropriate courses and programs for both military personnel and also such military-related or civilian personnel as it may be considered feasible to accept. In establishing courses or programs, institutions should recognize that special considerations frequently must be made; e.g., courses designed for the undergraduate on a college campus or for professional preparation in an academic discipline may not adequately meet the needs or capitalize on the experiences of military personnel. The usual fixed requirements of residence and traditional methods of accumulating credits may fail to allow for the unique circumstances of the military person. Hence, it is the Commission's view that an institution offering such courses, while holding to the basic quality essential to good educational programs, should feel free to adapt methods, policies, and procedures to the regimen and conditions under which the military student must perform his/her duties and pursue studies.

Providing educational opportunities for interested personnel on military bases is a dual responsibility. Certain guidelines and requisites can be established which may provide both incentive and direction for officers of the military in positions of responsibility on base. Likewise, there are helpful guides that might provide direction for those from the college campus responsible for such services. Successful programs in these situations will not be realized unless there is mutual understanding, a sharing of responsibilities, and a marshaling of resources essential for such offerings.

a. Guidelines for Responsibilities of Institutions

1) Programs offered should relate to the mission and goals and adhere to the educational standards of the institution.

Provision should be made for students to work toward completion of appropriate programs offered by the institution. Without compromising the principle that quality will be equivalent to that on campus, course offerings might be more flexible or nontraditional than those required of the campus student. Thus the educational goal of the military base student might be given special consideration within the general graduation requirements of the institution without depreciation of standards. Although institutions should refrain from offering work unrelated to either their mission or resources, they may provide service or cultural courses without credit when such experiences can be of personal worth or upgrade competencies required of the military person.

2) In organizing and administering base programs, institutions should take into consideration the uniqueness of military situations.

The staff member assigned the responsibility of representing an institution in its military base effort must recognize the unique demands of the situation. This person must realize that the first demand upon the base personnel is a military commitment and arrangements for such individuals must fit into this demand. Although organization and administration practices need not duplicate or conform to campus routines, appropriate standards must be maintained.

3) Student personnel policies and services should be such as to facilitate the success of a program on a military base.

Admission requirements should reflect the demands of postsecondary studies and degree requirements and, at the same time, take into consideration the student's background in terms of equivalencies. Registration procedures should be accommodated to the conditions under which the military work, and counseling services should be provided by relevantly prepared and experienced individuals. Special provisions should be made for program advising so students may know requirements and make adjustments in terms of their own educational goals. Adjustments may need to be made in residency requirements and/or the substitution of courses for transfer credit or degree purposes. Provision should be made for the possibility of advanced placement or credit by examination or evaluation.

4) Both faculty and instruction should be of recognized quality.

For military base education programs, the faculty are drawn from the cooperating institution, the military base staff, and from other institutions. Qualified specialists without institutional affiliation may also be employed. Instructors must be professionally competent in regard to specific preparation and recency of involvement in the field. When participating institutions employ faculty from other institutions on a part-time basis, it is recommended that they do so with permission from the faculty member's full-time employer; this will avoid the danger of excessive overloads.

The quality of instruction should be comparable to that on campus, with the same degree of concern for teaching tools and information resources. Necessary library materials must be available or accessible. Special provisions may be needed for the completion of course work when students are called from base. Regardless of departures from campus practice, grades should not be given until students meet all course requirements.

5) Integrity is essential among institutions offering programs on a single base.

Institutions placed in competition with each other in making bids to provide services must guard against the erosion of quality of instruction. To avoid negative aspects of competition, several participating institutions on a base should consult among themselves and with the military education services officer. In all deliberations and negotiations, it is expected that a high degree of integrity will be maintained.

b. Guidelines and Obligations of the Military

1) The military should not hesitate to initiate negotiations for the purposes of providing educational programs on base.

When postsecondary educational opportunities are not being provided and when personnel on base express an interest in them, military officials should initiate the action necessary for securing such programs. The leadership should first assess and identify the types of programs and services desired before approaching an institution. It is always helpful to know at the outset precisely what is desired, the approximate number of students that are likely to be involved, and the resources which the base might be able to provide. Education officers should be open in making needs known to interested institutions and in inviting proposals for programs. Memoranda of understanding or contracts should be negotiated directly between military bases and participating institutions. Where possible, it is recommended that such memoranda of understanding or contracts run for more than one year to ensure program stability. Perhaps bases could work toward standardization of contracts and thus ensure greater consistency in the services provided by an institution.

2) A joint meeting of both institutional and base leadership should come early.

After the educational needs of base personnel are determined, there should be a joint exploration and planning session of base and institution representatives. Such a meeting should define the needs, identify essential resources, describe the general nature of programs desired, and define the specific responsibilities of all parties. Written agreements should be reached prior to the initiation of the program to guide both the base and the participating institution in carrying out the program.

3) The military will have responsibility for supplying certain essential resources.

In addition to identifying programs desired, the number of persons involved, and the costs, the military should expect to provide certain essentials for such programs on base:

a) suitable and adequate facilities;

b) space and facilities for a library or information resource center;

c) adequate information resources to support the program;

d) laboratory space and essential equipment for courses requiring laboratory experiments;

e) other equipment and supplies (e.g., typewriters, business machines, etc.) essential to the courses offered.

It is the responsibility of the educational institution to notify the military base of additional or extraordinary needs, sufficiently in advance, to make it possible for the base to fulfill the request.

In most instances, the military will be expected to provide certain initial funds for starting the service.

4) The military must give full support and backing to the program once it is initiated.

No program will succeed without the continuing support of the post commander, the commander's staff, and the highest officials of the respective service branch. A postsecondary program will also need the attention of an educational officer who is a qualified educator, and is given time and staff to manage and evaluate the program and provide essential academic advisement. The educational officer will need the full support of all base officials. The success of such programs is highly dependent upon the experience, leadership, and resourcefulness of such an individual.

5) On bases where non-military personnel are permitted to take courses, it is understood that the first responsibility, in terms of space and instructional services, is to the military student. However, the inclusion of community people on a space-available and self-paid basis may be beneficial to all parties concerned and is encouraged.

c. The Evaluation of Educational Programs on Military Bases

1) Educational programs conducted by accredited or candidate postsecondary institutions on a military base should be evaluated by the appropriate regional accrediting commission in conjunction with an institutional evaluation.

Although informal evaluations may be made by military education staff, it is not appropriate for the military to engage in formally evaluating the programs of an accredited postsecondary institution. It is recommended, however, that appropriate military educational personnel confer with the institution in doing the relevant part of its self-study. An evaluation committee may wish to confer with the military regarding the support, resources, and effectiveness of a given program.

2) If an accredited institution offers educational programs on a military base within another accrediting region, the evaluation should be conducted jointly by the affected commissions, with primary responsibility vested in the parent commission. In the case of overseas programs conducted outside the United States or its possessions, the evaluation should be conducted by the appropriate regional commission.

3) Those responsible for postsecondary military base programs will be cognizant of, and generally expected to meet, the appropriate military, state, and regional accrediting commission guidelines for operation of the programs.

d. Consortia Agreements

Where two or more institutions are joined together in consortia to provide educational programs on military bases, certain common administrative arrangements and educational policies need to be agreed upon. This can be handled by a consortium board with appropriate representation from each of the participating institutions and the military. Such matters as calendar, admissions, course and degree requirements, transfer of credits, and tuition should be developed.

From the outset, the appropriate regional accrediting commission should be notified of, and involved in, the development of the consortia. Evaluation of the consortia educational program will be in conjunction with the evaluation and accreditation process with each participating institution. Consortia arrangements will not be evaluated for separate accredited status.

Adopted 1972

A-11 Military-Sponsored Educational Programs

The several regional accrediting commissions will expect military-sponsored institutions seeking accreditation to meet basically the same criteria as do non-military institutions. In respect to the requirement of a public board, the commissions will take into account the peculiar responsibility of the government and the military for the ultimate control of the institution. However, it will expect the institution to have a public advisory board which exerts broad and significant influences upon the institution's programs and operations. It will further expect, in keeping with the academic tradition, that the faculty will play a significant role in the determination of the educational policies of the institution.

When classified materials are used in the instructional program, these materials must be used in a manner consistent with the academic principles of the search for truth, and these materials and their instructional uses must be open to examination by evaluation committee members selected by the accrediting commission.

Adopted 1975

A-12 Considerations When Closing a Postsecondary Educational Institution

Planning for a possible decision to close an educational institution requires thoughtful consideration and careful consultation with all affected constituencies. Every effort should be devoted to informing each constituency, as fully as possible, about the conditions requiring consideration of a decision of such importance, and all available information should be shared. Before closing, such alternatives as merging with another institution, forming a consortium, or participating in extensive inter-institutional sharing and cooperation should be carefully considered. As much as possible, the determination to close an institution should involve a consultative process, but responsibility for the final decision to close rests with the governing board.

Tradition and sentiment are important considerations, but sentimentality should not be allowed to determine events. A decision to close should never be made or reversed simply on the basis of fears, hopes, or aspirations that have little relation to reality. Neither should it be delayed to the point where the institution has lost its viability and its educational program no longer retains quality and integrity. Since the immediate interests of current students and faculty are most directly affected, their present and future prospects require especially sensitive attention and involvement.

It is assumed that closing an institution means a decision to discontinue its educational activities permanently, not merely to suspend them for an indefinite period in the hope that circumstances may someday permit their resumption. But it should be noted that most institutions of higher education are corporations established under the provisions of state law, and, as such, they may have legal responsibilities (holding title to real property, for example) that may necessitate the continued existence of the corporation after the educational activities of the institution have been terminated. Indeed, it is probable that such continued corporate existence, at least for a time, will prove to be the usual situation. In most cases, it is unlikely that corporate existence and educational activities can be terminated simultaneously.

Closing an Institution. A decision to close requires specific plans for providing in appropriate ways for the students, the faculty, the administrative and support staff, and for the disposition of the institution's assets. Many considerations bear upon closing an educational institution, and each situation will be unique. The nature and sponsorship of public institutions, seminaries, and church-related colleges require different emphases and pose particular conditions to be met in reaching and carrying out the ultimate decision. Nevertheless, general guidelines may be helpful to each institution considering closing.

This statement makes only incidental reference to such corporate responsibilities and always in the educational context. It is imperative, therefore, that a board of trustees considering closing an institution under its care should be guided not only by guidelines such as these and by the state educational authorities, but also by advice of legal counsel. Special counsel to advise, with respect to problems of closing, may be desirable for the institution. Institutional and specialized accrediting bodies should also be consulted and be kept fully apprised of developments.

The Students. Students who have not completed their degrees should be provided for according to their academic needs. Arrangements for transfer to other institutions will require complete academic records and all other related information gathered in dossiers which can be transmitted promptly to receiving institutions. Agreements made with other institutions to receive transferring students and to accept their records should be in writing. Where financial aid is concerned, particularly federal or state grants, arrangements should be made with the appropriate agencies to transfer the grants to the receiving institutions. Where such arrangements cannot be completed, students should be fully informed. In cases where students have held institutional scholarships or grants and there are available funds which can legally be used to support students while completing degrees at other institutions, appropriate agreements should be negotiated.

Academic Records and Financial Aid Transcripts. All academic, financial aid information, and other records should be prepared for permanent filing, including microfilming. Arrangements for filing students' records should be made with the state department of higher education or other appropriate agency. If there is no state educational agency which can receive records, arrangements should be made with another college or university or with the state archives to preserve the records. Notification should be sent to every current and past student indicating where the records are being stored and what the access to those records will be. Where possible, a copy of a student's record should be forwarded to the individual student.

Completion of Institutional Obligations. When a student chooses to continue at another institution but is within a year or 18 months of completing an academic degree in the closing institution, arrangements may be made to permit that student to complete the requirements for a degree elsewhere, but to receive it from the closed institution. This may require special action by the appropriate state agency. Such arrangements should also include provision for continuation of the institution's accreditation--for this purpose only by the accrediting agency involved. These steps normally require the institution to continue as a legal entity for 12 to 18 months beyond the closing date, but any such arrangement must be established in careful consultation with the appropriate authorities and with their written consent. If an institution enters into a teach-out agreement with another institution, it must submit the agreement to the Commission on Colleges for approval (Policy A-13- Teach-Out Agreements, page 128).

Provisions for Faculty and Staff. In every possible case, the institution should arrange for continuation of those faculty and staff who will be necessary for the completion of the institution's work up to the closing date. When faculty and staff are no longer needed, the institution should make every effort to assist them in finding alternative employment. It should be understood that the institution can make no guarantees, but genuine good-faith efforts to assist in relocation and reassignment are essential. In the event that faculty or staff members find new positions, early resignations should be accepted.

The Final Determination. Determinations must be made to allocate whatever financial resources and assets remain after providing for the basic needs of current students, faculty, and staff. When the financial resources of the institution are inadequate to honor commitments, the Board should investigate what alternatives and protection are available under applicable bankruptcy laws before deciding to close. If funds are insufficient to maintain normal operations through the end of the closing process, the institution should not overlook the possibility of soliciting one-time gifts and donations to assist in fulfilling its final obligations.

Every effort should be made to develop publicly defensible policies for dividing the resources equitably among those with claims against the institution. One of the best ways of achieving this goal is to involve potential claimants in the process of developing the policies. Time and effort devoted to carrying the process to a judicious conclusion may considerably reduce the likelihood of lawsuits or other forms of confrontation.

It is impossible to anticipate in advance the many claims that might be made against remaining resources of an institution, but the following three principles may help to sort out possible claims and to set priorities:

1. Students have the right to expect basic minimal services during the final term, not only in the academic division but also in the business office, financial aid office, registrar's office, counseling, and other essential support services. Staff should be retained long enough to provide these services. It may be appropriate to offer special incentives to keep key personnel present.

2. Reasonable notice is given to all employees, explaining the possibility of early termination of contracts and that the reasons for retaining some personnel longer than others are based on satisfying the minimal needs of students and the legal requirements for closing.

3. Every effort should be made to honor long-term financial obligations (e.g., loans, debenture), even though the parties holding such claims may choose not to press them.

The Closing Date. The board of trustees should take a formal vote to terminate the institution on a specified date. That date will depend on a number of factors, including the decision to file or not to file for bankruptcy. Another key factor is whether or not all obligations to students will have been satisfactorily discharged. This is particularly important if the decision is made to allow seniors in their final year to graduate from the institution by completing their degree requirements elsewhere. If such arrangements are made, the board must be sure to take the legal action necessary to permit awarding degrees after the institution otherwise ceases to function. Normally, formal vote to award a degree is made after all requirements have been met, but it is legally possible to make arrangements for a student to complete the requirements for a degree at another institution and to receive the degree from the closed institution. These requirements must be clearly specified along with a deadline for completion. Also, the board must identify the person or persons authorized to determine whether or not these requirements have, in fact, been satisfied. Arrangements must be completed with the appropriate state and accrediting agencies in advance in order to ensure that the degree is awarded by a legally authorized and accredited institution.

Disposition of Assets. In the case of a not-for-profit institution, the legal requirements of the state and federal government must be carefully examined with respect to the disposition of institutional assets. Arrangements for the sale of the physical plant, equipment, the library, special collections, art, or other essential holdings, and for the disposition of any endowments or special funds, must be explored with legal counsel. In the case of wills, endowments, or special grants, the institution should discuss with the donors, grantors, executors of estates, and other providers of special funds, arrangements to accommodate their wishes. State laws regarding the disposition of funds from a non-profit institution must be meticulously followed.

All concerned federal and state agencies need to be apprised of the institution's situation, and any obligations relating to state or federal funds need to be cleared with the proper agencies.

Other Considerations. The institution should establish a clear understanding with its creditors and all other agencies involved with its activities to ensure that their claims and interests will be properly processed. Insofar as possible, the institution should ensure that its final arrangements will not be subject to later legal proceedings which might jeopardize the records or status of its students or faculty.

Conclusion. The closing of an educational institution is never a happy event. Nevertheless, such action can be rendered less traumatic through careful attention to the details of the legal and moral obligations of the institution. Closing will be marked by sadness, but well-planned and conscientious efforts to ensure that the institution's students, faculty, and staff will be optimally provided for, and that its assets will be used in ways that will honor the intentions of the original donors, should help in avoiding bitterness and rancor. A final report on the closing should be submitted to the appropriate accrediting and state agencies for their records.

Adopted 1982/Revised 1996

A-13 Teach-Out Agreements

In accordance with federal regulation 34 CFR 602.27(b)(6), if an institution enters into a teach-out agreement with another institution, it must submit the agreement to the executive director of the Commission on Colleges for approval prior to its implementation. For the purpose of this regulation, a teach-out agreement is defined to mean a written agreement between accredited institutions that provides for the equitable treatment of students if one of those institutions discontinues an educational program before all students enrolled in that program complete the program (602.2).

For approval by the Commission, the agreement must be consistent with applicable accreditation standards and Commission policies, and provide for the equitable treatment of students by ensuring that:

1. students are provided, at a comparable charge, all of the instruction required by the institution prior to its closure or prior to its termination of a program;

2. the teach-out institution is located as closely as possible to the institution scheduled to close or scheduled to discontinue a program; and

3. the teach-out institution's program is compatible with the other institution's program structure and scheduling.

In cases where an institution plans to close, representatives of the institution should refer to the general guidelines outlined in Policy A-12 - Considerations When Closing a Postsecondary Educational Institution, pages 125-128.

Adopted 1996

A-14 Complaints Regarding Member or Candidate Institutions

The Commission considers complaints regarding member or candidate institutions only when the reported conditions are substantially documented and are related to the eligibility requirements, standards, and policies of the Commission on Colleges. The Commission assumes no responsibility for adjudicating isolated individual grievances; however, it may investigate individual complaints and reports to determine whether they reflect conditions within an institution that affect the quality of its programs or are detrimental to the general welfare. The Commission on Colleges shall maintain an up-to-date record of all student complaints received by the Commission.

The Commission on Colleges interprets its complaint procedures to defer to courts when litigation is instituted over the same issue brought to the Commission by a complainant. This shall be Commission procedure unless a preliminary review by Commission staff of the complaint and the institution's response clearly indicates serious non-compliance with a Commission standard. In such instance, the Commission procedures for handling complaints against a member or candidate institution will be implemented.

Procedures for Handling Complaints

a. When an oral complaint regarding a member institution is received, the person is advised of the policy statement and requested to submit the complaint in writing with substantial documentation to the executive director of the Commission on Colleges.

b. When a written complaint regarding a member institution is received, the executive director acknowledges receipt of the complaint in writing within 15 business days.

c. After acknowledging receipt of the complaint, the executive director and/or his or her designee analyzes it to determine if there is adequate documentation and if, where appropriate, institutional appeals procedures have been utilized. In case adequate documentation is not provided, the complainant is notified, in writing, within 10 business days that complaints can be considered only when reported conditions are substantially documented and are such as to jeopardize the quality of the educational program or the general welfare of the institution. In case institutional appeal procedures have not been utilized, the complainant is advised to do so first.

d. When the complaint is substantially documented, or a pattern or practice appears to be present when considering past complaints received against the institution, the chief executive of the institution is notified, in writing, by the executive director within 15 business days after acknowledging the complaint. The complaint is reported to the institution or a copy of the complaint is enclosed, and a written response is requested, normally within 20 business days.

e. When the response from the chief executive of the institution is received, the executive director compares the documentation provided by the complainant and the institution and, where appropriate, suggests a resolution of the matter to the complainant and the institution.

f. When a resolution suggested by the executive director is not accepted by one or both parties, or the response from the institution is considered to be inadequate by the executive director, the matter is referred to the Commission on Colleges for consideration and action at its next regular meeting. Both the complainant and the institution are notified of the referral.

g. Commission actions ordinarily include one or more of the following:

1) dismissal of the complaint;

2) executive sessions with complainant and institutional representatives in an attempt to resolve the complaint;

3) recommendations to the institution suggesting changes in procedures or adherence to standards and policies of the Commission;

4) visit to the institution by an ad hoc committee of the Commission to review situations.

Adopted 1982/Revised 1984, 1994, 1998

A-15 Appeals Policy and Procedure

Appeals in General. An institution that is aggrieved by a negative action of the Commission on Schools or the Commission on Colleges of the Northwest Association of Schools and Colleges, may appeal.

a. The institution must give written notice of its intention to appeal within thirty (30) days of the institution's receipt of the accreditation decision.

b. The notice of intention to appeal shall set forth the specific grounds for the request, and shall include a statement of the reasons for each ground, along with any other relevant statements or documents the institution desires to include.

c. The notice of intention to appeal must be filed with the President of the Northwest Association of Schools and Colleges and a copy provided to the executive director of the Commission that made the decision being appealed.

d. Upon appeal, the prior status of the institution, if any, shall be restored pending disposition of the appeal.

Actions Which May Be Appealed. The Commission on Colleges shall provide institutions the opportunity to appeal all adverse actions including probation and show-cause actions. In addition, the Commission on Colleges will provide the institution with written notification of the result of the appeal as well as a detailed explanation for the result in a timely manner.

a. denial of candidacy;

b. termination of candidacy;

c. denial of advancement to accredited status;

d. termination of accredited status.

Grounds for Appeal. An appeal shall be based on one or more of the following grounds:

a. the evaluation committee and/or the Commission made substantial errors or omissions in carrying out prescribed procedures which affected the decision of the Commission;

b. the evidence before the Commission at the time the accrediting decision was made was materially in error;

c. the decision of the Commission was not adequately supported by the facts before it at the time, or it was contrary to the substantial weight of evidence before the Commission.

President's Role. In handling properly filed appeals, the President of the Northwest Association of Schools and Colleges shall appoint a special five-member Appeal Board to consider the grievance and designate the chair. No member of an Appeal Board shall be a current member of a Commission or the Board of Trustees of the Northwest Association of Schools and Colleges or shall have served on an evaluation committee to the aggrieved institution. Where the appeal is from a postsecondary institution, at least three (3) of the members of the Appeal Board shall be from the field of higher education. Where the appeal is from an elementary, middle school/junior high, or high school, at least three (3) of the members shall be from those levels of education.

The President of the Northwest Association of Schools and Colleges shall set the date, time, and place of the Appeal Board. The hearing shall be no later than one hundred twenty (120) days after receipt of the appeal and there shall be at least thirty (30) days' notice of the hearing given to the parties in writing. If the institution and/or the Commission plan to call witnesses at the hearing, they shall provide the President of the Northwest Association of Schools and Colleges and the opposing party with all the witnesses' names and positions at least five (5) calendar days before the hearing.

Appeal Board Duties. In carrying out its duties the Appeal Board shall:

a. meet at the time and place designated by the President to consider the appeal;

b. provide a hearing if the institution so requests;

c. consider the grounds for the appeal as alleged by the institution;

d. study the evidence submitted by the institution in support of its allegation;

e. consider the report of the evaluation committee, the institution's response, and other supporting statements and documents;

f. consider whether the Commission substantially followed stated policies and procedures;

g. prepare a report of the meeting of the Appeal Board, including a final judgment of the Board, within twenty (20) days after the end of the hearing; and

h. forward a record to the President of the Association, including a report of the hearing of the Appeal Board, the appeal filed by the applicant, and other relevant statements and documents considered by the Board.

Conduct of the Hearing. The chair of the Appeal Board may retain legal counsel as he/she deems appropriate and may decide any prehearing issues that may arise. Discovery such as depositions, interrogatories, and production of documents is not available to the parties except by mutual agreement. The chair of the Appeal Board shall make an initial determination of whether the Appeal Board has jurisdiction to hear the appeal.

a. The chair of the Appeal Board shall control the hearing and the presentation of the evidence. He/she shall ensure that all participants have a reasonable opportunity to be heard and to present relevant oral and written evidence. The chair of the Appeal Board may limit the duration of a hearing dividing the available time equitably between the parties.

b. The technical rules of evidence shall not apply, but the chair of the Appeal Board may limit the evidence to avoid undue repetition and to ensure relevance. He/she shall rule on all questions pertaining to the conduct of the hearing.

c. The institution's presentation during the appeal hearing shall be strictly limited to those matters raised in the appeal documents; no additional written materials or evidence unavailable to the Commission at the time of its action may be presented.

d. Each party shall have the right to be represented by counsel or authorized spokesperson, to examine the witnesses of the other party, and to present oral and written evidence.

e. The hearing shall be closed. A secretary shall record the minutes of the hearing. A court reporter may be present to prepare a record of the hearing at the election of either party and at the expense of the electing party. Where the hearing is closed, only necessary participants shall be present.

Decision of the Appeal Board. The Appeal Board shall uphold the appeal of the institution only when it is shown with clear and convincing evidence that the institution sustained one of the grounds for appeal listed under Grounds for Appeal, items a through c. Upon finding that an institution has sustained the burden of proof, the Appeal Board shall remand the case to the appropriate Commission for reconsideration.

Costs of Hearing. The request for a hearing shall be accompanied by a deposit of $5,000.00 to the Association to cover necessary costs of the appeal. The costs shall include the travel, board, lodging, and other actual and necessary expenses of the Appeal Board. If the institution is represented by legal counsel at the hearing, it shall provide the name of its legal counsel to the Appeal Board at least 30 days in advance of the hearing, and the institution shall deposit an additional $20,000.00. Upon final disposition of the appeal, the parties shall be provided a detailed written statement of their share of the costs. Any unused portion of the institution's deposit shall be refunded.

a. If the decision of the Commission is sustained, the entire cost of the Appeal Board, and cost of Commission legal counsel, shall be borne by the institution.

b. If the case is remanded to the appropriate Commission, the cost of the Appeal Board shall be borne by the parties equally. In such case, the institution and the Commission shall each bear the cost of its own legal counsel.

Adopted 1988/Revised 1997

A-16 Communication of Commission Action Regarding Recommendations

In order to clearly identify in the evaluation committee report which recommendations represent standards that the institution does not meet and which are suggestions for improvement, the Commission on Colleges has determined that it will no longer use recommendations for deficiencies calling for institutional attention but do not affect compliance with accreditation standards. In such instances evaluators will use the term suggestion in their reports.

Evaluators will continue to use the term recommendation only in those instances where the institution may not be in full compliance with a Commission standard or eligibility requirement. These recommendations will continue to be enumerated at the end of the evaluation report and will need to be addressed by the institution as determined by the Commission and indicated in the Commission's notification letter to the institution following the Commission's most recent review and action.

Adopted 1997

A-17 Public Disclosure of Information Regarding Type of Accreditation Granted, Criteria, Accreditation Procedures, Evaluation Schedule, and Commissioners and Commission Staff

The Commission on Colleges of the Northwest Association of Schools and Colleges makes publicly available through its Accreditation Handbook, Annual Directory, Minutes of Commission meetings, newsletters, other publications or relevant correspondence the following information:

1) Each type of accreditation and preaccreditation granted by the Commission on Colleges;

2) The Commission's procedures for applying for accreditation or preaccreditation;

3) The criteria and procedures used by the Commission on Colleges for determining whether to grant, reaffirm, reinstate, deny, restrict, revoke, or take any other action related to each type of accreditation and preaccreditation that it grants;

(4) The names, academic and professional qualifications, and relevant employment and organizational affiliations of the Commission as well as the Commission's administrative staff; and

(5) The institutions that the Commission currently accredits or preaccredits and the date when the Commission will review or reconsider the accreditation or preaccreditation of each institution.

Adopted 1997

A-18 Policy on Commission Action Regarding Institutional Compliance Within Specified Period

In instances when an institution does not come into compliance with the standards for accreditation within the period specified by the Commission, the Commission must take an adverse action unless it extends the period for achieving compliance for good cause. Should an institution deem that it is not able to comply with the standard within the specified period of time due to mitigating circumstances, the institution shall submit in writing a request for additional time along with a detailed narrative explanation of why the institution cannot comply within the designated time period. The Commission will then make a determination as to whether the institution has based its request on valid reasons. If the Commission determines that the institution has substantiated good cause for not complying within the specified time period, the Commission will extend the period for achieving compliance and request that the institution submit a progress report in one year.

Adopted 1997

A-19 Policy on Publication of Adverse Actions

The Commission on Colleges of the Northwest Association of Schools and Colleges makes public through its executive director and publishes in the roster of member institutions and in the appropriate national directories the status of each institution. Those institutions on Probation or under Show-Cause will be so noted in these publications. In all cases of public negative sanction, the Commission will give the institution written reasons for its decision. A statement for response to inquiries regarding the action will be prepared in consultation with the institution. The Commission reserves the right to make the final determination of the nature and content of the public statement. The public statement issued by the Commission summarizing its decision to take an adverse action will be made available to the Secretary, the appropriate State postsecondary review entity, and the public upon request, no later than 60 days after the final decision has been made.

Adopted and Amended 1997

A-20 Policy on Notification to Appropriate Accrediting Agencies and State Agencies Regarding Institutions' Accreditation

The Commission on Colleges of the Northwest Association of Schools and Colleges shall routinely share with other appropriate recognized accrediting agencies and State agencies information regarding the accreditation status of its institutions, including all adverse actions it has taken against an accredited institution.

Adopted 1997