TO: National Advisory Committee on Institutional Quality and Integrity (NACIQI)
DATE: September 23, 2015
SUBJECT: Third Party Comment on the Continuation of recognition of the Accrediting Commission for Community and Junior Colleges (ACCJC), Novato, California
I am an educator and the Director of Public Relations and Communication for the California Part-time Faculty Association (CPFA). I am speaking for the California Part-time Faculty Association (CPFA).
We understand that the Western Association of Schools and Colleges (WASC) / Accrediting Commission for Community and Junior Colleges (ACCJC) is seeking recognition to continue its role in the Accreditation of two-year, associate degree-granting institutions located in California, Hawaii, the United States territories of Guam and American Samoa, the Republic of Palau, the Federated States of Micronesia, the Commonwealth of the Northern Mariana Islands, and the Republic of the Marshall Islands, including the accreditation of such programs offered via distance education at these colleges.
We understand that such recognition will be reviewed on December 16, 17, and 18, 2015, from 8:30 a.m. to 5:30 p.m. at a location in the Washington DC area to be announced in a later notice (posted by Nov 17, 2015).
Further, we understand NACIQI has Statutory Authority to grant recognition of accrediting bodies, as NACIQI is established under section 114 of the Higher Education Act of 1965, as amended (HEA), 20 U.S.C. 1011c.
We understand that the NACIQI advises the Secretary of Education about:
The establishment and enforcement of the criteria for recognition of accrediting agencies or associations under subpart 2, part H, title IV of the HEA, as amended.
During the process of re-authorization of accrediting agencies, 3rd party comments are solicited, and the period for 3rd party comments on the re-authorization and recognition of WASC/ACCJC is open until Sept 25, 2015.
We therefore are making a formal 3rd party comment herein:
We urge NACIQI to discontinue or revoke the recognition of ACCJC as an authorized accrediting agency in the Western US regions, named above, for the reasons that follow (I-VI). Our position is that ACCJC/ WASC is non-compliant with the Code of Federal Regulations Title 34 602.13, which requires that agencies demonstrate the acceptance of their policies, procedures and decisions by others.
Our interest: The California Part-time Faculty Association (“CPFA”) represents nearly 40,000 Part-time faculty in the California community college system, a system comprised of 72 districts in California, all of which are currently accredited by the ACCJC. This two-year college system is the largest in the United States, and currently enrolls over 2.3 million students annually. Part-time Faculty (“PTF”) employed in California community colleges comprise around 70% of the academic instructional staff, by headcount, and are thus the largest single constituency of on-the ground academic instructional staff in the geographic areas under ACCJC’s accrediting jurisdiction. As such, we have a strong interest in what standards, policies, and procedures are used, and what decisions to grant or deny accreditation are made, in relation to the 72 California Community college districts.
CPFA is not a union or collective bargaining entity. CPFA is an entirely volunteer, grass-roots organization, in existence since 1998. We do advocacy work, conduct independent research, provide analyses for our members on issues critical to their working conditions via the CPFA Journal, convene annual conferences, and maintain a network of listservs, rapid response teams, and coalitions. We conduct analyses of proposed legislation that will affect PTF working in the districts that the ACCJC presently accredits. We have been following with grave concern the high rate of sanctions meted out by ACCJC in the past 10 years, and have witnessed firsthand the damage caused by inappropriate and/or unfair accrediting policies, procedures, and decisions. Prior to the era of unfair ACCJC sanctions, California was known world-wide for the excellent quality of education provided via its 2-year college system. Anchored to the communities it served, it was affordable and of very high quality.
We are aware of the impact accreditation “down-sizing” of the community college system has had on PTF statewide, who have (along with students) bore the brunt of the massive diversion of resources that have been required to counter hostile accrediting actions.
We understand that one of the conditions for re-authorization of ACCJC as an accrediting agency is “acceptance of the agency by others” (Code of Federal Regulations Title 34 602.13).
The agency must demonstrate that its standards, policies, procedures, and decisions to grant or deny accreditation are widely accepted in the United States by—
(a) Educators and educational institutions; and
(b) Licensing bodies, practitioners, and employers in the professional or vocational fields, for which the educational institutions or programs within the agency’s jurisdiction prepare their students.
CPFA has reviewed ACCJC Standards, policies, procedures and decisions to grant or deny accreditation during the past decade or so.
I. CPFA does not accept the Standards used by ACCJC to judge whether an institution deserves to be, or remain, accredited. We reject the language of some standards, and the way these standards were formulated. For example, in Standard I. B 1. (Assuring Academic Quality and Institutional Effectiveness), adopted in June 2014, we find that the requirement for districts to engage in “sustained, substantive and collegial dialogue” is impossible to meet. PTF, who comprise approximately 70% of the instructional staff by headcount, statewide, are categorically unable to participate in this “sustained, substantive and collegial dialogue” due to the nature of their employment status as contingent faculty, hired on a semester-by-semester basis for teaching-only duties. While all would generally embrace the notion of “sustained dialogue,” no one could conceivably believe this to be attainable under current conditions. Did ACCJC intentionally embed a standard impossible to meet? Is this a trip wire that can be invoked, selectively, in future?
If any community college district has passed this standard, it could only be by deliberately obscuring the “Missing in Action” status of the majority of those tasked with engaging in “dialogue” around student success and implementing the subsequent changes, for just one interlocking example. We do not share ACCJC’s affection for, or belief in, Student Learning Outcomes (“SLOs”). Additionally, we don’t believe SLOs collectively to be an appropriate and effective tool to rescue students and institutions from the cascade of bad policy decisions associated with higher education “reforms.” These policy decisions have led to a new class of working poor (the PTF) trying to serve the historic working poor (community college students). Nor do PTF’s employment conditions as contingent faculty (paid only for teaching) encourage, permit, or even at times, allow consultation. PTF would need to “choose to volunteer” their time and the department, senate, division would all need to permit PTF participation as voting members in order for the voice of this sector to be in any way audible in sustained, substantive and collegial dialogue.
Even should PTF wish to “volunteer,” and even if a department, senate, division, or other governance body permit PTF participation, it would be a rare occurrence, since PTF annualized wages are so low on average ($35,789 per year for FTE workload at PTF pay rates in 2013) that PTF must, typically, work 2, 3 or 4 jobs. (Source: 2013 California Chancellor’s Office Datamart).
Because the PTF load in the California community college system is limited, by state statute, to 67% of a FTF load, the highest annual earnings for the average PTF member would be about $23,948, hardly the sort of wage that affords the leisure for “volunteering.” (Source: 2013 Chancellor’s office Datamart figures, with the average hourly annualized by 525 / hour average FT load).
Under the terms of Standard I.B.1., as written, every single community college in California, and presumably most or all other two-year colleges under the jurisdiction of ACCJC, would fail. The reliance on a largely contingent academic instructional cohort makes broadly-constituted institutional consultation and well organized student success efforts that depend on college-wide or district-wide consultation to support student success, for just two examples among many governance tasks, systemically impossible.
We are certainly not asking ACCJC, or its replacement, to sanction all of the two-year colleges in California, or put them on “show cause” or “warning,” or put them out of business. Instead, we are asking NAIQI to recognize that as an accrediting agency ACCJC has demonstrated that it is incapable of crafting meaningful standards, in collaboration with stakeholders, that take into account the limited or non-existent opportunities for participation in governance by the majority of the teaching staff. Nor given its current standards, can ACCJC guide its member institutions to more meaningful institutional integration of this constituency.
In fact, we do not accept any of the ACCJC-authored Standards that depend on attestations of, or requirements for, full institutional “consultation,” and “collaboration” (and there are a number), on the grounds that these types of unquestionably valuable conversations are, in point of fact, impossible, given that 70% of the faculty members who are delivering roughly half of the educational services in the California community college system, and have the experience to weigh in on curricular change and improvement in student success (for two examples), are cut out of such deliberation, by apparent design, and with what appears to be the tacit approval of ACCJC for a good many years.
We look forward to “accepting” the authority of, and registering our acceptance of the Standards put forward by, an accrediting agency that genuinely supports improvement to the accessibility and success of a high-quality two-year educational system and does so by explicitly recognizing and supporting the validity and contributions–both actual and latent–of this important sector of higher education, the PTF cohort. Further, we would be look forward to accepting accreditation standards that explicitly guided institutions under an accrediting agency’s jurisdiction to a fuller integration of this sector via clearly articulated timetables and benchmarks for equity and integration, that might well, and most probably should, have the force of a mandate.
Any accrediting agency recognized by the Department of Education should be required to craft standards that are securely anchored to the real conditions of the majority faculty in the two-year college systems of higher education. We are troubled that most of the standards that reference “faculty” seem to be assuming that “faculty” means that group of individuals who have an office; who are paid to attend, participate actively in, and forge new initiatives within, a shared governance structure; who are expected and required to hold office hours and meet with students; who have opportunities to work with colleagues on curricula, program review and other necessary governance business; who participate in preparing important documents and reviewing important policies and policy changes.
That is not the case for the PTF.
II. CPFA does not accept ACCJC Standard I. C.7. in Institutional Integrity, on much the same grounds as above.
The Standard reads:
In order to assure institutional and academic integrity, the institution uses and publishes governing board policies on academic freedom and responsibility. These policies make clear the institution’s commitment to the free pursuit and dissemination of knowledge, and its support for an atmosphere in which intellectual freedom exists for all constituencies, including faculty and students. [Emphasis added].
We draw your attention to the last phrase “institution’s commitment to free pursuit and dissemination of knowledge and its support for an atmosphere in which intellectual freedom exists for all constituencies”[emphasis added].
This, again, is an unreasonable Standard, one that no community college in California could reasonably pretend to uphold, given that neither “academic freedom” nor “intellectual freedom” exist in any meaningful way for any PTF in any of the two-year colleges seeking, or having sought in the last decade, accreditation from the ACCJC.
No institution can plausibly and honestly say that the majority of their faculty have any meaningful version of academic or intellectual freedom as PTF have little or no job protections, compared to FTF, and have no guarantee of re-employment in the first three semesters in most districts (and no guarantee at all in a number of districts, for their entire career). PTF may lose course load through non-reassignment for ANY reason in most districts, including intellectual and academic “incompatibilities,” (often disguised under the vague code words of “good fit” /“bad fit” or “departmental needs”), and as a consequence of unfair evaluation proceedings, inconsistent course schedule changes that have the effect of edging out long-serving or activist PTF, or age-related discrimination. PTF in our communication networks have consistently brought a range of non-reappointment cases to our attention which seem to be violations of academic or intellectual freedom.
Since the ACCJC has not genuinely investigated the “existence” of intellectual freedom . . . for all constituencies, we can only conclude that this standard has been consistently “not met” and that ACCJC has consistently granted accreditation despite this. In fact, ACCJC has chosen to selectively invoke or ignore parts of its own standards, and has deployed its granting or denying of accreditation on subrosa factors extraneous to the stated standards.
- must implement curricular reform without consultation despite being the primary faculty constituency, by head count, to deliver the curriculum,
- are cornered into political docility by insecure semester-by-semester employment,
- are segregated within their home institutions by limits on work areas or lack of work areas, or wholly inferior work areas,
- are shut out of academic decision making by their status as “teaching only staff,”
- feel themselves to be pressured to pass students through the system or risk losing their jobs,
- are disenfranchised by their departments and divisions in decision-making related to academic matters that only FTF are permitted to vote on,
- are generally uncompensated for participation in governance at any level, and
- are subject to a complex set of assumptions and perspectives, and must abide by a complex web of imposed rules, regulations, and protocols that are often hostile to their academic and intellectual freedom and to which PTF have neither acceded nor been provided with the “institutional space” in which they might accede.
III. CPFA does not accept ACCJC’s site visit policies.
PTF have no opportunity to talk to ACCJC accrediting teams, as consultation of any sort with any entity is not part of PTF’s role or job description. CPFA is concerned that ACCJC site visit policies do not deliberately seek consultation with the majority faculty cohort, and encourage or require compensation for such consultations. This omission in “site visit policy” and procedure indisputably affects the conclusions of the visiting team, about such matters as consultation, collegiality, and governance, and limits the visiting team’s perspectives to a non-majority sector of the academic / instructional staff.
IV. We do not accept ACCJC’s pattern of granting or denying accreditation.
Others parties have no doubt referenced the many reports, legislative reviews, audits, and lawsuits, including the most recent Taskforce on Accreditation released last week (September 2015) by a taskforce convened by the California Chancellor’s Office, and have well documented that the criteria for granting (or denying) accreditation have been unevenly applied to California community college districts under ACCJC jurisdiction. We are trusting that many third party commentators will address the imbalance in sanctions in historical and geographic terms, and we need not repeat those here. Suffice to say that we share the widespread view that ACCJC has failed its obligation to this sector of higher education, on the basis of its pattern of accrediting, for instance, a number of for-profit colleges, while sanctioning successful community-based two-year colleges, such as CCSF. These for-profit colleges, with long histories of dishonest marketing, significant lapses in academic integrity, and a poor record on accurate disclosures about their graduates’ “ job placement” rates, have exploited vulnerable student populations by saddling them with unsupportable student debt burdens that are tied to questionable if not worthless academic progress. At the same time ACCJC has sanctioned colleges such as CCSF that have maintained excellent student services and student success history, for over 50 years, and has long been a state leader in providing a more integrated, more fairly compensated, PTF cohort.
V. On the financial question, relative to the granting and denying of accreditation. We do not accept sanctions and show cause judgments produced by ACCJC’s flawed policies, procedures, assumptions and practices for another reason: We object to the ACCJC requiring districts to spend millions of dollars of their limited resources to satisfy demands for ever more costly, ever more detailed and ever more pedagogically shallow “student success” initiatives (and other so-called reforms). We believe this focus is deeply hypocritical, given the lack of institutional integration of PTF, and the lack of equity within the professoriate tasked with delivering equity to students. We would welcome an accrediting agency that formulated, via articulated standards and procedures and policies, a strong set of goals and timetables to help districts achieve faculty equity, without which any efforts at “student equity” or “student success” will likely fail, or fall significantly short.
We are distressed that ACCJC has historically done nothing to address the effects of dramatically unequal wage structures, and urgent health, dental, office space, office hour pay, and other issues about which PTF are concerned, and which indisputably have direct or indirect impact on student success. We are distressed that districts have been forced to siphon off and sequester millions of dollars to pre-fund FT-only post-employment benefits (OPEB). While funding future liabilities is prudent, in long range financial planning terms, it is the wrong time to focus on this when we have such a backlog of urgent, unmet present needs. Encouraging a patient who is experiencing uncontrolled blood loss due to an injury to “floss,” is clearly and demonstrably the “wrong” priority at that singular time and place, though flossing itself, everyone would agree, is a “good” thing.
In addition to the pre-funding of post-employment liabilities, millions more have been misdirected, in obedience to ACCJC policies and procedures. This includes the outsourcing of critical functions to edu-profiteers, who have proven in many cases to be more expensive and to have delivered a lower quality service or product than even the worst-run two-year college administrations. Textbook ordering, student printing functions, writing and math tutoring, and IT support, marketing campaigns, and the development of institution-specific Total Cost of Ownership (TCO) documents are examples of privatized functions that have proven to be problematic–expensive, badly done, and damaging to institutional integrity.
At the same time that millions of dollars have been diverted to “solve” the largely “manufactured” accrediting crises that are burning like wildfires across the state, the majority of the instructional staff, the Part-time faculty (PTF) have seen their average annualized pay stagnate. The current annualized pay for PTF (a PTF’s annual income if he or she worked a full time load at PTF rates of pay) is lower than the average annual pay for a fast-food worker, a hotel cleaning staff person, or a janitor.
In comparison to their FT faculty colleagues, the California community colleges’ “average actual parity” for PTF fell from 40% (that is, PTF were paid 40%of what FTF were, on average, in 2003–annualized to a full-time load for both statuses of faculty) to 39% in 2013, the last year for which data has been published on the California CC Chancellor’s office Datamart. This ten-year period saw a further erosion of an already scandalously unequal pay structure for two tiers of faculty performing identical work (excepting the 10-15% of world load of a FTF dedicated to service), and it coincides with the period of the most aggressive accreditation demands in the history of the California Community College system.
That is, the accrediting boondoggle–the untimely emphasis on OPEB sequestering, on bulking up other reserves, on spending more money for administrators, lavish facilities and landscaping, outsourced functions and needlessly complex bureaucratic processes, has driven hundreds of millions of dollars away from what we believe to be the most pressing urgency in the community college system for the past three decades: equitable pay, benefits and institutional integration for the majority instructional staff: the 40,000 PTF.
We are quite sure that the Department of Education is aware of the central place that faculty play in the success of an educational enterprise, and that the necessity for a well-trained, well-supported faculty is unquestioned.
We ask that the Secretary of Education, the NAIQI, and the accreditation agencies tasked with accrediting institutions of higher education in the United States and surrounding territories, put more robust emphasis on the role played by this important sector of “in-class” instructional staff.
Although it may be understandable that the accreditation process has not yet expressed any interested in the following questions, we might well ask why the well-being and integration of PTF is not a more pressing concern of accrediting agencies.
- How many PTF are working three, four, and five jobs?
- How many PTF are homeless or food insecure?
- How many PTF have not seen a dentist in the past ten years?
- How many PTF have chronic, untreated medical conditions?
- How many PTF over 65 do not have sufficient retirement?
- Can the PTF working in your institution “live” on the pay earned at an institution without resorting to food stamps, public housing, second hand stores and food banks?
Because the ACCJC has insisted that CC districts in California “build up reserves” beyond the prudent recommendations of their internal financial advisors, and sequester OPEB money before the districts are legally obliged to do so, critical and desperately needed present-day resources are diverted.
ACCJC’s adverse decisions, well documented elsewhere, have led to millions of dollars of resources wasted (during the last six-year cycle), and a staggering number of man hours have been devoted to cramping diverse, distinctive and community-based institutions into narrowly-focused, rigidly uniform degree factories. We, as an association of educators, find that “decisions” to terminate, sanction, or threaten to terminate, the accreditation of a number of California community colleges during the past ten years are ill-considered, harmful to students, harmful to the faculty, harmful to our future work force needs, and damaging to our communities. We emphatically do not accept the decisions, nor the underlying assumptions that have validated these decisions.
VI. We find it unacceptable that a reform agenda has been embedded in our state’s CC accreditation processes, in part through grant streams to ACCJC/WASC that favor the privatization of certain functions and sectors of higher education, the sequestering of OPEB, and the compression of the educational experience by a narrow, outcome-oriented harness.
VII. We are particularly troubled by the assault on the City College of San Francisco (“CCSF”). Most PTF in California look to CCSF as a model institution, in the specific areas of PTF pay, benefits, and institutional integration. Unlike virtually all other community colleges, CCSF makes available fully paid health coverage to all PTF employed half time or more after three (3) semesters of teaching. The college has made a concerted effort to integrate PTF into curriculum discussion and governance. Part-time Faculty activists and analysts interpret the attack on CCSF, in many ways, as an attack on PTF.
CPFA does not agree with, and does not accept the validity of what appears to be a mission- and goal shift that has been imposed from the outside by forces hostile to the positive civic virtues embedded in the ethos of the community college system in California, and indeed hostile to the very concept of “community.”