BY HANK REICHMAN

A bit more than a year ago then-Secretary of Education John King ruled that the Accrediting Commission for Community and Junior Colleges (ACCJC), which accredits all of California’s 112 community colleges, had a year to come into compliance with two Department of Education regulations.  Of particular importance was Regulation 34 C.F.R. § 602. B(a) – Wide Acceptance by Educators, under which an accrediting agency “must demonstrate that its standards, policies, procedures, and decisions to grant or deny accreditation are widely accepted in the United States by,” among others, “[e]ducators and educational institutions.”  King noted that “staff found ACCJC conspicuously lacking in support from academic faculty, and therefore did not consider ACCJC ‘widely accepted’ by educators. I agree. This conclusion is bolstered where, as here, an entire category of educators withheld support and, in some cases, voiced opposition.”

Now, preparatory to a meeting next week of the National Advisory Commission for Institutional Quality and Integrity (NACIQI), which advises the Secretary, department staff have issued a report finding that ACCJC has now come into compliance with this requirement and recommending its authorization be extended for 18 months.  With respect to the requirement for “wide acceptance,” the DOE report states in part:

To demonstrate wide acceptance by educators, ACCJC provided a significant number of letters from educators and educational administrators, to include faculty, deans and department heads, which endorsed ACCJC and its standards, policies, procedures, and decisions. These letters were from educators across ACCJC’s region. ACCJC also provided a summary of the evaluations for various symposiums and workshops, which were attended by educators and educational administrators. The number and breadth of support from educators within its region is compelling to demonstrate wide acceptance by educators of its standards, policies, procedures, and decisions to grant or deny accreditation.

Department staff notes the significant number of letters from educators, educator groups, union organizations, and the public within the third-party comments that do not support ACCJC and its standards, policies, procedures, and decisions. These comments were overwhelmingly from the San Francisco area and related to one institution, City College of San Francisco (CCSF). Even though the number of comments opposed to ACCJC is close to equal to those in support, the fact that the letters are primarily related to one institution is not, in and of itself, compelling to demonstrate a lack of wide acceptance – especially as many of the third-party comments in opposition are not from educators.

Within its expanded narrative, ACCJC states that the wide acceptance by educators, as required by this section, does not mean unanimous acceptance. Department staff agrees. ACCJC also states that a State agency is not included within the educator category. Department staff also agrees. However the opinion of the State agency that oversees a majority of ACCJC’s membership – in the form of the California Community College Chancellor’s Office Task Force Report on Accreditation 2015 (Task Force Report) – must be reviewed seriously by both ACCJC and the Department, especially when such a report recommends a “new model for accreditation” which could include the replacement of ACCJC. This is true for the review of the March 2016 Resolution from the Board of Governors of the California Community Colleges (Resolution) in review of the Task Force Report, as well as the June 2014 California State Auditor’s Report (Auditor Report).

Based on the narrative and documentation provided, ACCJC appears to regard the Task Force Report as politically-motivated interference and punishment for its action on CCSF. Nonetheless, within its expanded narrative and documentation, ACCJC addressed the specific concerns included within the Task Force Report – lost confidence of members, more frequent sanctions than other accreditors, insufficient transparency of decision meetings, and inaction on past recommendations. ACCJC used the results of an independent survey included within the Auditor Report, the letters of support from educators and educational administrators, and its own accreditation data and standards review process, to support its narrative to address the concerns. Notably, the survey results from the Auditor Report showed a high level of support for ACCJC’s actions and evaluation teams.

With regards to the Resolution, ACCJC framed it as supportive of the agency. Department staff notes that the final resolution “directs the Chancellor to … Present to the Board of Governors final recommendations on a new structure or agency for accreditation of the California Community Colleges based on the work of the planning groups coordinated by the CEO’s, review the formal plan for college transition and bring to the Board of Governors the necessary information for the Board to recommend a new accreditor for the California Community Colleges to be submitted to the U.S. Department of Education for approval,” which does not appear to be supportive of ACCJC.

These findings are at best mixed, but the bottom line endorsement of ACCJC’s claim to wide acceptance is at minimum troubling. To be sure, the removal of the polarizing Barbara Beno from leadership of the commission and the replacement of the majority of commissioners may have opened the door to reform.  However, as Jonathan Lightman, executive director of the Faculty Association for California Community Colleges (FACCC) noted in an email, “Whether or not we believe that personnel changes at ACCJC have reformed the agency is one matter. To suggest that there is ‘wide acceptance’ by faculty, pursuant to Section 602.13, is something completely different.”

California community college faculty, students, administrators, and supporters will be attending the NACIQI meeting next week to voice their concerns about ACCJC.  Unfortunately, for personal reasons I am unable to join them, as I did last year.  Therefore, I will here publicly quote some of what I submitted in writing a few months ago to the department:

The AAUP is concerned that

• ACCJC is not widely accepted by educators and educational institutions [602.13]
• ACCJC does not have sufficient academic representation on its evaluation, policy, and decision-making bodies [602.15]
• ACCJC is inconsistent in its application and enforcement of standards [602.18]
• ACCJC does not maintain clear standards or offer reasonable time for institutions to comply with those standards [602.25]

Many of our members do not believe that ACCJC’s “standards, policies, procedures, and decisions to grant or deny accreditation are widely accepted.” [602.13]  Certainly, large numbers of community college faculty and administrators do not accept them.  That a task force of community college faculty and administrators found that the “California Community College system and its member institutions have lost confidence in the ACCJC” is, of course, especially telling.  Previously, in 2009, a task force of faculty, administrators, staff, students and trustees convened by former California Community College Chancellor Jack Scott offered several recommendations for improvement to ACCJC.  One suggestion was to “work more cooperatively to have accreditation result in improvement rather than compliance.”  Another was to broaden the composition of the accreditation review teams and a third was to “scale accreditation expectations” to those of other agencies, presumably referring to ACCJC’s abnormally high sanction rates. It would seem that ACCJC has rejected all such suggestions for improvement.

These concerns and others find powerful validation in the 2015 Report of the California Community Colleges Chancellor’s Office Task Force On Accreditation, which concluded unanimously that “ACCJC has consistently failed to meet the expectations” of the institutions it serves and that “The California Community College system and its member institutions have lost confidence in the ACCJC.”

This loss of confidence in ACCJC has spread among faculty members at four-year institutions as well.  We have looked on with growing incredulity as ACCJC has sanctioned a series of community colleges that we know from experience to have sent to us extremely well-prepared and educated transfer students.  ACCJC’s controversial decision to revoke the accreditation of the City College of San Francisco (CCSF) was especially astonishing, as CCSF’s well-earned reputation made its graduates highly successful in four-year institutions, including my own institution, California State University, East Bay.  The willingness of ACCJC to close that institution owing to a series of ill-defined and largely educationally irrelevant weaknesses was shocking, to say the least.