Alamo Community College District

Accreditation Review

Committee Report,

2009

To the Board of Trustees & Chancellor

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Final Report of the Accreditation Review Committee

To the Alamo Colleges Board of Trustees & Chancellor

TABLE OF CONTENTS

TRANSMITTAL LETTER ............................................................................................................ v

MEMBERS, FACILITATORS, AND STAFF OF THE ACCREDITATION REVIEW COMMITTEE ................................................................................................................................ vi

EXECUTIVE SUMMARY ............................................................................................................ 1

PART I. COMMITTEE HISTORY ................................................................................................ 4

Grants Subcommittee .............................................................................................................. 5

Costs Subcommittee ................................................................................................................ 5

SACs Subcommittee ................................................................................................................ 6

PART II. ANSWERS TO CHARGE .............................................................................................. 7

1a. Are the Standards of Accreditation any different for Individual Accreditation versus Single Accreditation? .................................................................................................................. 7

1b. Is the district capable of achieving the Standards of Accreditation if we become a “Single Accreditation” system? .................................................................................................. 8

1c. What are the implications for the Alamo Colleges as having Individual Accreditation versus Single Accreditation? ....................................................................................................... 9

2. Is there any impact on Federal requirements for accreditation? ........................................ 10

3. Is there any impact on either St. Philip's College's designation as an HBCU, or the colleges' designations as Hispanic Serving Institutions; are other designations or grants affected? .................................................................................................................................... 11

4. Are any of the Core Requirements of accreditation affected differently by becoming a Single Accreditation college district? ....................................................................................... 13

5. Are any of the Comprehensive Standards affected? If so, which ones and how? ............. 15

6. Determine the costs associated with remaining “Individual Accreditation” colleges, especially determining the cost of establishing new colleges and the necessity of separate books and audits and the cost of on-going reaffirmation for the five colleges versus accrediting and reaffirming a Single Accreditation district. Consider this over a ten-year cycle of accreditation and reaffirmation. Also, because our colleges, as independent entities, have

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organized themselves as autonomous organizations, consider the costs of continuing to operate separate yet concurrent systems, such as bursar services, at each of the colleges. ................... 17

7. As we serve a relatively compact geographic service area and because students may desire to attend a college outside of their neighborhood or attend more than one of our colleges, what are the implications to student access and success in an Individual Accreditation system versus a Single Accreditation system? ................................................................................................. 18

8. Consider accurately from discussions with other multi-college districts whether any of the "unique cultures" of our five colleges will be adversely affected by becoming a “Single Accreditation” district. How do others, both “Individual Accreditation” districts and “Single Accreditation” districts address the need to celebrate and reinforce the unique cultures of each of the colleges? Please be precise in how you analyze this item, as the response of the other colleges will depend on how the question is asked. .................................................................. 19

9. Which methodology provides the best opportunities for the future of our students and communities and why? .............................................................................................................. 20

10. What are the timelines and processes for accrediting new colleges (Northeast Lakeview College, North Central College) versus achieving Single Accreditation? ................................ 20

11. Describe the pros and cons of each option. How do we mitigate the cons to either option? ....................................................................................................................................... 26

12. Higher education is under great pressure to become more cost effective, more flexible and capable of rapid change. How does each model allow the Alamo Colleges to achieve these goals? 30

13. Are there any other considerations that should be explored? Please describe them and their impact. ............................................................................................................................... 30

APPENDICES .............................................................................................................................. 31

Appendix A – Memorandum from Dr. Bruce Leslie to Accreditation Review Committee, July 2, 2009 ....................................................................................................................................... 31

Appendix B – Response from United States Department of Education, November 4, 2009 .... 36

Appendix C – 34 CFR Ch. VI (7-1-03 Edition) ........................................................................ 39

Appendix D – Demographic Information, October 9, 2009 ..................................................... 42

Appendix E – 1998 Amendments to the Higher Education Act of 1965 P.L. 105-244 ............ 43

Appendix F – St. Philip’s College – HBCU Designation 1987 ................................................ 44

Appendix G – 20 U.S.C.A, Ch. 28, Subch. III, Part B §§ 1060 – 1063c .................................. 50

Appendix H – Alamo Colleges – Grant Information ................................................................ 63

Appendix I - Current Structure of Alamo Colleges as of September 9. 2009 ........................... 67

Appendix J - Proposed Structure of Alamo Colleges as of September 9. 2009 ........................ 68

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Appendix K – Comparative Community College Systems ....................................................... 69

Appendix L - Incremental Costs of Individual Accreditation by Year - for Core Requirement 2.11.1 Financial Requirements .................................................................................................. 70

Appendix M – CR 2.11 Financial Core Requirement ............................................................... 71

Appendix N – Review Committee’s Questions for Peer Institutions – Telephone Interviews . 74

GLOSSARY OF TERMS ............................................................................................................. 77

 

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Accreditation Review Committee

TRANSMITTAL LETTER

December 16, 2009

Denver McClendon, Chairman Dr. Bruce Leslie Alamo Colleges – Board of Trustees Alamo Colleges - Chancellor 201 W. Sheridan 201 W. Sheridan San Antonio, Texas 78204 San Antonio, Texas 78204 Dear Chairman McClendon & Dr. Leslie: On behalf of the Accreditation Review Committee, it is our pleasure and privilege to present our Final Report to you and the other Trustees. The Accreditation Review Committee has devoted five months to this effort. We solicited input from multiple sources and consolidated that information into this Final Report for your review. We believe the extensive scope of our efforts will be extremely useful in analyzing our Final Report and making decisions concerning accreditation issues for the Alamo Colleges. We commend the Board of Trustees and the Chancellor for their initiative in creating the Accreditation Review Committee, in shaping its broad charter, and in supporting its labors. You were generous in furnishing staff, faculty, administrative assistance, community representation, and student representation. We trust that our Final Report meets your expectations. Each of the Committee members stands ready to lend whatever further assistance may be required in promoting a full understanding of the data contained in this Final Report. Respectfully submitted on behalf of the Committee, __________________________ __________________________ Dr. Jacqueline Claunch Jeff Hunt Committee Co-Chair Committee Co-Chair

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MEMBERS, FACILITATORS, AND STAFF OF THE ACCREDITATION REVIEW COMMITTEE

Members: Dr. Jacqueline Claunch, Co-Chair President, Northwest Vista College (Grants Subcommittee, Convener) Mr. Jeff Hunt, Co-Chair Theatre and Speech, San Antonio College (SACs Subcommittee, Convener) Dr. Thomas Brown Assistant Professor, Sociology, Northeast Lakeview College (SACs Subcommittee) Dr. Thomas Cleary Vice Chancellor, Planning, Performance & Information Systems (Costs Subcommittee) Dr. Mike Flores Vice President of Colleges Services, Palo Alto College (Grants Subcommittee) Mr. Geraldo R. Guerra Multimedia Specialist, San Antonio College (SACs Subcommittee) Dr. Debbie Hamilton Vice President of Student Services, Northeast Lakeview College (Grants Subcommittee) Dr. Mary-Ellen Jacobs Associate Professor, English, Palo Alto College (SACs Subcommittee) Mr. George H. Johnson, III Professor, Mathematics, St. Philip’s College (Grants Subcommittee) Dr. Beth Lewis Vice President of Academic Affairs. Northeast Lakeview College (Costs Subcommittee, SACs Subcommittee)

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Dr. Paul Martinez Associate Professor, History, Faculty Senate President, Northwest Vista College (Costs Subcommittee) Dr. Diana Muniz Vice President of Student Success, Northwest Vista College (SACs Subcommittee) Dr. Christopher Pate Dean, Division of Health Services, St. Philip’s College (Costs Subcommittee) Mr. Tim Rockey Dean of Continuing Education, Training Network, San Antonio College (Costs Subcommittee) Ms. Diane Snyder Associate Vice Chancellor for Finance & Fiscal Services (Costs Subcommittee, Convener & SACs Subcommittee) Student Representatives: Julianne Cantu San Antonio College (Grants Subcommittee) Nicole DeHoyos Northeast Lakeview College (Costs Subcommittee) Amanda Salvio St. Philip’s College (SACs Subcommittee) Matthew Sanchez-Sandoval Palo Alto College (Grants Subcommittee) Alberto Saucedo Northwest Vista College (Costs Subcommittee) Community Member: Margaret Anderson Executive Director – P16Plus Council of Greater Bexar County (SACs Subcommittee)

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Staff: Pamela Ansboury, CPA, M.Ed Comptroller – Alamo Colleges (Costs Subcommittee, Staff) Lydia Beaver Executive Assistant to Jacqueline Claunch (Committee Recorder and Communications) Dr. Adriana Contreras Deputy to the Chancellor – Alamo Colleges (Grants Subcommittee, Staff) Facilitators: Dr. Allen T. Craddock, Facilitator Director, Ceasefire Conflict Resolution Services Honorable Dan Naranjo, Facilitator Ceasefire Conflict Resolution Services

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EXECUTIVE SUMMARY In July 2009 the Chancellor, Dr. Bruce Leslie, at the request of the Board of Trustees Chairman, Denver McClendon, appointed the Accreditation Review Committee (“Committee”) and charged the Committee with responding to thirteen questions in order to identify the relative benefits of moving to a Single Accreditation for the Alamo Colleges (ACCD) versus retaining the current Individual Accreditation model. In order to work toward an accurate representation of the facts, the Committee identified three major thematic areas for fact gathering: Accreditation Costs, Grant Implications, and SACS (Southern Association of Colleges and Schools) Accreditation Issues. Subcommittees were formed for the three thematic areas to engage in fact finding research and to draft responses to the thirteen questions posed in the charge to the Committee. Although the process was at times chaotic and frustrating, it was also a learning experience for all ARC members. Hopefully, the body of the report allows some of that learning to be shared with readers. What follows is a summary of key Committee findings by thematic area. Accreditation Costs – A Single ACCD Accreditation model would be less costly than the current Individual College Accreditation model.

o The average annual cost savings over the next ten years are estimated at around

$235,000. o The cost differential comes primarily from two places. First, in order to obtain

accreditation for new colleges (in this case Northeast Lakeview College), SACS requires that a totally separate financial audit be submitted for the new applicant. There is an annual cost associated with setting up and maintaining separate financials for each College. The second key cost area relates to the actual cost of ongoing accreditation (i.e. site visits, dues, QEP’s for five accredited bodies versus one).

Grant Implications – A Single ACCD Accreditation model would risk the loss of up to $7,000,000 in grant finds annually for the Alamo Colleges.

o The Alamo Colleges (ACCD) may be unique among community colleges across the country in having four (soon to be five) accredited colleges, one of which is an historically black college (HBCU designation) and all of which are Hispanic serving institutions (three are currently eligible for federal grants as HSI eligible institutions). Based on the written information the Accreditation Review Committee has been able to gather from the Department of Education and from the federal Higher Education Codes, it appears that under a Single Accreditation model, St. Philip’s College will lose its current Title III(B) funding as an HBCU. There is a process for appeal, but if the appeal were granted, the ACCD would then have to choose between HBCU and HSI eligibility. If the appeal is not granted, then each of the colleges could, as “Branch Campuses,” retain HSI eligibility for Title V grants as long as the overall District and the branch campus meet HSI eligibility criteria.

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The loss of HBCU status and funding eligibility will cost St. Philip’s College $5,000,000 to $7,000,000 annually. St. Philip’s College has, since receiving HBCU designation in 1987, received an annual allocation. The allocation for the current budget year is approximately $5,746,256 from Title III, Part B (HBCU) and $1,655,250 from HBCU/CCRAA, bringing the total federal funding for St. Philip’s College, to $7,401,506. This would be a huge loss for the College. Both Title III, Part B (HBCU) and the HBCU/CCRAA programs

are funded under a “non-competitive” basis, but annual applications and budgets are submitted for review and approval and allocations are determined on an annual basis.

Although there could be an opportunity to submit an appeal to retain

HBCU status, there is no way of knowing if such an appeal would be granted, and there appears to be a precedent for not approving such an appeal.

If, by chance, St. Philip’s were granted permission in an appeal to retain

its HBCU designation, the other College’s (San Antonio College, Palo Alto College, Northwest Vista College and, in the future, Northeast Lakeview College) would then forfeit their ability to apply for Title V grants, a loss of at least $700,000 annually. An “institution” (which under Single Accreditation would be the ACCD as a whole) cannot receive both Title III and Title V funding. The Title V funding potential, based on an application process, ranges from $700,000 to more than $1,000,000 (includes San Antonio College, Palo Alto College, and Northwest Vista College) annually with funding at approximately $700,000 for the current year.

SACS Accreditation Issues – The SACS criteria for accreditation essentially apply in the same manner under a Single ACCD Accreditation model or under an Individual College Accreditation model. The primary changes that would need to occur to move to Single Accreditation involve some key processes.

A Single ACCD Accreditation would require effective district-wide processes to

coordinate all aspects of compliance with the SACS criteria for accreditation. The SACS requirements involving the most significant change in process deal with

institutional effectiveness criteria. Under the current Individual Accreditation model, each ACCD College, as required by SACS, demonstrates that it has established student outcomes for programs and services, measures the achievement of those outcomes, and engages in cycles of improvement. Under a Single Accreditation model the District would collectively have to develop common outcomes, establish measures of effectiveness for those outcomes, assess the results, and engage in cycles of improvement. Although this move toward common outcomes is possible and even

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desirable, the process of building the system and moving through cycles of assessment and improvement to show compliance with SACS criteria will take several years.

According to information from SACS, a move to Single Accreditation would occur using

the substantive change process. The substantive change process provides for the movement from four accredited institutions to one accredited body and allows five years to demonstrate compliance with SACS criteria (including the development of a new QEP for the District). The substantive change process also provides for bringing in a new and currently unaccredited campus, in this case Northeast Lakeview. It appears that the process of bringing in Northeast Lakeview might have to wait until after the initial combining of accredited colleges is completed and approved by SACS. It would be up to SACS to decide when that could happen, but it could take as much as five years, depending on SACS rulings.

Other Issues – Certain questions in the Committee charge dealt with issues of culture and change. Although the Committee attempted to gather some information through dialogues with other Singly Accredited institutions as well as Individually Accredited institutions, there are no definitive conclusions that could be drawn. What seems important, therefore, is to express key fears and concerns among many, if not most, faculty and staff across the Alamo Colleges.

Individuals at the Colleges strongly identify with the College of residence. There is a

fear that a move to Single Accreditation threatens long established college cultures and identities. Although a Single Accreditation does not have to be accompanied by such loss of identity, concerns loom large.

Most faculty and staff members appear to see the benefits of increased collaboration,

process alignment, and a set of common outcomes. There exists, however, deep concern about the potential loss of flexibility and agility at the colleges where the students reside to effect programs and innovations that improve student results.

There is obviously a common interest among Board members, District Office personnel,

and college employees that student success is our primary goal and concern. There also seems to be agreement that Alamo Colleges needs to move toward greater collaboration to improve processes and attain the best balance of cost and benefit. The issue of what accreditation model we use to achieve those ends may not be the most important issue we have to address as this point in the history of the Alamo Colleges.

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PART I. COMMITTEE HISTORY The Accreditation Review Committee (“Committee”) was formed through a joint effort of the Alamo Colleges Board of Trustees and Chancellor. On July 29, 2009, Dr. Bruce Leslie, Chancellor, charged the Committee with the tasks of collecting and examining data regarding the advantages, disadvantages, costs, and cost savings of two (2) distinct models of accreditation for Alamo Colleges: Individual Accreditation and Single Accreditation (Appendix A). The first meeting of the Committee was convened on July 20, 2009. Dr. Bruce Leslie addressed the Committee and established that the role of the Committee was to provide information to the Board of Trustees so that the Board of Trustees could make decisions regarding accreditation that would serve the best interests of Alamo Colleges. In an effort to eliminate bias, Dr. Bruce Leslie clarified that the role of the Committee was not to make specific recommendations regarding accreditation, but to collect data and present the advantages and disadvantages of both models. Dr. Bruce Leslie corrected language to Question #4 of the charge to the Committee to state, “Are any of the Core Requirements of accreditation affected differently by becoming a Single Accreditation college district?” Further, the questions were refined by the Committee to promote consistency of language, and the terms “Individual Accreditation” and “Single Accreditation” were adopted. By agreement of the Committee and the Chancellor, a deadline of December 2009, was set for completion of the Committee’s work and final report. Committee members further agreed that its duties included 1) gathering the facts; 2) engaging in open and respectful dialogue; and 3) maintaining the integrity of the data collected. Through the use of two outside facilitators from Ceasefire Conflict Resolution Services, Honorable Dan Naranjo and Dr. Allen T. Craddock, the following ground rules were developed and agreed upon in order to facilitate effective committee meetings:

1. The Committee developed the following protocol of inquiry: a. Determine what questions must be asked to obtain the most reliable data; b. Determine what sources are reliable providers of the data; and c. After obtaining the data, the Committee would then

i. Determine the facts that are relevant; and

ii. Determine the facts that are reliable.

2. The Committee agreed to use a consensus model to evaluate the validity and reliability of

the data obtained. 3. All data would be gathered from reliable sources in written form, if available. 4. Subjective items and issues would be addressed after the data were gathered and verified.

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5. In order to reduce miscommunication, Committee members agreed that co-chairs, Dr. Jackie Claunch and Mr. Jeff Hunt, would be the exclusive spokespersons for the Committee with the media.

The Committee met as a whole six (6) additional times from July 2009 through December 2009. In order to eliminate redundancy of effort and facilitate the investigative work required, the Committee created three subcommittees to explore the key factors. These subcommittees consisted of Grants (Chaired by Jackie Claunch), SACS [Southern Association of Colleges and Schools] (Chaired by Jeff Hunt), and Costs (Chaired by Diane Snyder).The subcommittees were tasked with contacting reliable outside sources and obtaining relevant data that would be reported to the Committee. Each subcommittee met multiple times throughout the Fall to prepare documented responses to each of the relevant questions posed by the Committee charge as well as the supplemental questions outlined below. Grants Subcommittee The Grants Subcommittee was tasked with the following initial inquiries:

1. What are the implications for grant eligibility if Alamo Colleges moved from Individual Accreditation to Single Accreditation, specifically addressing losses and gains? In answering this question, the following subject areas were considered:

a. Would St. Philip’s College maintain its Historically Black College designation and grant funding?

b. Currently, each of the four accredited colleges meets criteria to be eligible for

Title V Hispanic Serving Institution grants. Would Single Accreditation allow these colleges to retain that eligibility and the associated funding opportunities?

c. What are the total annual funds currently awarded across the colleges?

d. Are there other grant opportunities that would be affected by Individual

Accreditation versus Single Accreditation?

e. Are there any other advantages or disadvantages? Costs Subcommittee The Costs Subcommittee was tasked with the following initial inquiries:

1. What are the costs associated with Individual Accreditation versus Single Accreditation? In answering this question, the following subject areas were considered:

a. What are the computed and annualized direct costs for accreditation (visiting

teams, release time, systems requirements, etc.) for Individual Accreditation versus Single Accreditation?

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b. What are the other associated costs such as SACS dues, dues to other organizations, etc?

c. What are the costs of initial accreditation for Northeast Lakeview versus initial

costs of moving to Single Accreditation?

d. Are there other financial implications or considerations? SACs Subcommittee The SACs Subcommittee was tasked with the following initial inquiries:

1. In regard to accreditation of Northeast Lakeview College, what is the specific process for accreditation along with expected timelines of completion?

2. In regard to Single Accreditation: a. Can SACS provide written clarification as to the process for conversion to Single

Accreditation as well as a timeline? b. Is there any impact on federal requirements?

c. Are there other factors and expectations that may enter into the process to either

simplify or complicate matters? 3. In regard to Principles of Accreditation:

a. Do the Core Requirements for Accreditation affect the institution(s) or the

students differently in an Individual Accreditation model versus a Single Accreditation model?

b. Do the Comprehensive Standards for Accreditation affect the institution(s) or the

students differently in an Individual Accreditation model versus a Single Accreditation model?

The subcommittee work was compiled into a draft report that was reviewed and refined at several meetings by the Committee as a whole. A writing subcommittee was also used to finalize the document.  

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PART II. ANSWERS TO CHARGE 1a. Are the Standards of Accreditation any different for Individual Accreditation

versus Single Accreditation?

No. The SACS Principles are identical for both models. SACS does not make a distinction between the two models when applying its standards to an institution under review.

Committee’s observations: Certain technical, professional, and workforce programs require other program accreditations or approvals by agencies in addition to SACS.

o Agencies responsible for program-specific accreditation or approval must

be kept apprised of changes in leadership, governance, and the accreditation status of a governing institution. Potentially, these types of changes may influence institutional decisions about structure and resources (i.e., budget, staffing) that could affect a program’s ability to meet established requirements.

o Accrediting bodies have different requirements for reporting significant

institutional changes, timelines, formats, and thresholds for notification. o An example of how an agency responsible for program specific

accreditation or approval responds to a substantive institutional change is detailed in the November, 2009, policies and procedures manual developed by the Commission on Accreditation for Respiratory Care (CoARC).

The CoARC manual states: “A substantive change is one that the

CoARC believes is significant enough to require the program to notify the Commission of its occurrence. The sponsor must report substantive change(s) to the appropriate parties no less than 4 months prior to the intended date of implementation, with the exception of an adverse action by an appropriate institutional accrediting agency or a change in the program’s institutional accreditation status. Such a change requires an immediate notification to the CoARC” (CoARC, 2009, p. 39).

A number of different outcomes are possible given the notice of a

substantive change. First, the accrediting body, such as the CoARC, reviews the information submitted and bases subsequent decisions on its review. According to the procedure outlined by the CoARC, the agency would then have several options: 1) approve the change; 2) make a recommendation for a progress report from the program; 3) ask for additional information; 4) arrange a

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focused site visit or alter the date of the next visit (CoARC, 2009, p. 39).

Although each accrediting/approving body has developed its own

specific administrative processes to address substantive change, the CoARC procedure provides a representative example of an accrediting agency’s response to substantive change.

o Economies of scale for consolidation of certain health science programs

may be gained. For example, under a Single Accreditation model, nursing programs would be able to save approximately $6,000 by combining an initial application for voluntary accreditation under the National League for Nursing Accrediting Commission (NLNAC). Ongoing savings of approximately $11,000 per accreditation visit would also be achieved through consolidation. These savings must be tempered, however, by any transaction costs incurred through consolidation efforts.

1b. Is the district capable of achieving the Standards of Accreditation if we become a

“Single Accreditation” system?

Yes. Since the SACS standards are the same for both accreditation models, each of the district’s individual colleges should be capable of achieving the same outcome under either an Individual Accreditation Model of a Single Accreditation model.

Committee’s observations: Certain processes would need to be standardized and integrated at the district level in order to achieve Single Accreditation (see Committee’s response to Question 1c). This would require the Alamo Colleges, as a consolidated entity, to develop many new competencies as a district in order to implement and maintain accreditation requirements district-wide. Although the Committee is confident that the district can build these new competencies over time, the Committee anticipates that there would be a substantial learning curve while these processes are put in place.

o According to SACS guidelines (see Committee’s response to Question

10); the newly consolidated system must achieve re-affirmation of accreditation within five years following SACS approval to continue its accreditation of the consolidated system. Thus, all district-wide competencies integral to the accreditation process would need to be fully operational prior to the SACS reaffirmation.

 

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1c. What are the implications for the Alamo Colleges as having Individual Accreditation versus Single Accreditation?

Institutional Effectiveness is SACS’ focus area. Each accredited college meets

the SACS criteria today, but Northeast Lakeview College’s ability to meet these criteria has not yet been demonstrated due to its newness and lack of longitudinal data.

In a Single Accreditation model, the entire district would need to meet the

accreditation standards set by SACS and any other accrediting agency. The failure of any Branch Campus (College) to meet a standard could endanger the accreditation status of the entire district.

Standardization work would have to be done if a Single Accreditation model were

implemented: o In preparation for launching the student component of Banner, the

standardization of a common course database and a common course catalog has already been accomplished.

o Program Outcomes and Student Learning Outcomes for every course

would need to be standardized across the district. A distinct challenge would be creating Program Outcomes that are inclusive enough to be meaningful for both beginning and established programs. New programs might require additional resources to meet standardized program outcomes.

o District-wide learning outcomes would involve further integration of

curricula and program objectives across the district. In addition, Single Accreditation would require one district-wide Quality Enhancement Plan (QEP) with clearly delineated processes for district-wide planning, implementation, measurement, and evaluation.

o Consolidation would require integration and coordination at the district

level that is not currently necessary under Individual Accreditation. This implies that the district may need to hire additional personnel, hire outside consultants, or reassign current employees to provide the necessary coordination.

 

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2. Is there any impact on Federal requirements for accreditation?

No. According to SACS’ Principles of Accreditation, federal funding agencies defer to the regional accrediting bodies when making determinations of eligibility for funding that are based on accreditation status. In Alamo Colleges’ region, SACS assesses whether or not an institution meets the requirements imposed by the U.S. Department of Education.

The Federal Requirements do not change depending on the accreditation model.

However, the district’s approach to meeting those requirements may necessitate some revision if it moves to a Single Accreditation model. The Committee addresses below the specific Federal Requirements that may be affected differently by moving to a Single Accreditation model:

FR 4.1 “When evaluating success with respect to student achievement in relation to the institution’s mission, the institution includes, as appropriate, consideration of course completion, state licensing examinations, and job placement rates.” Committee’s observations: District-level Institutional Research results on the FR 4.1 referenced three variables would be required.

FR 4.2 “The institution maintains a curriculum that is directly related and appropriate to its purpose and goals and to diplomas, certificates, or degrees awarded.” Committee’s observations: No impact. FR 4.3 “The institution makes available to students and the public current academic calendars, grading policies, and refund policies.” Committee’s observations: No impact. FR 4.4 “The institution demonstrates that program length is appropriate for each of the degrees offered.” Committee’s observations: Program length maximums are set by the Texas Higher Education Coordinating Board (THECB). With a Single Accreditation model, existing degrees will become district degrees and program length will need to be standardized within the state-mandated guidelines for maximum length. The Branch Campus (College) where the degree criteria were fulfilled could be denoted on the transcript.

FR 4.5 “The institution has adequate procedures for addressing written student complaints and is responsible for demonstrating that it follows those procedures when resolving student complaints.” Committee’s observations: Work is currently being done to create standard processes and documentation district-wide.

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FR 4.6 “Recruitment materials and presentations accurately represent the institution’s practices and policies.” Committee’s observations: No impact. FR 4.7 “The institution is in compliance with its program responsibilities under Title IV of the 1998 Higher Education Amendments.” Committee’s observations: No impact.

3. Is there any impact on either St. Philip's College's designation as an HBCU, or the colleges' designations as Hispanic Serving Institutions; are other designations or grants affected?

With regard to St.Philip’s College’s designation as an HBCU and the other

colleges’ designations as Hispanic Serving Institutions (HSI’s), the United States’ Department of Education (DOE) sent a response, dated November 4, 2009, to the inquiry of the Accreditation Review Committee (Appendix B).

The contents of the letter appear to indicate:

o HSI eligibility - If Alamo Colleges moves to Single Accreditation model, each college, as a branch campus, could apply for Title V grants, assuming the District and the campus both meet the criteria in Code of Federal Regulations, 34 CFR Ch. VI (Appendix C). The available data indicate that the District would meet the eligibility criteria (Appendix D).

o HBCU Status versus HSI Status - Based on the definition of an

“institution,” as stated in the Code of Federal Regulations, if we were to move to Single Accreditation, the Alamo Colleges (ACCD) becomes the “institution” (Appendix E). It appears, based on the definition and the specifications in the DOE letter that Alamo Colleges would have to choose between the HBCU designation for SPC and HSI designation for the other colleges.

o Possible loss of HBCU Status for St. Philip’s – According to available

information (Board Minutes from 1987) St. Philip’s was not designated as a special needs institution prior to 1987 and could therefore lose its HBCU funding status (Appendices G & H).

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Financial Implications:

o Current Funding Levels – As of September 2009, St. Philips College receives $5,643,726 (Title III(B)) annually as an HBCU. St. Philip’s also receives an approximate average of $1,200,000 annually in grant funding over four (4) years as a result of its HBCU status. Northwest Vista College, Palo Alto College, and San Antonio College receive a combined total of $724,296 annually for Title V grants.

o Potential Funding under Single Accreditation – Based on the response

letter from the Department of Education (Appendix B) and the DOE definition of an “institution” of higher education, Single Accreditation would mean a loss of Title III(B) HBCU funding. The loss could be as much as $7,000,000 annually. There would also be the loss of other potential funding for which Alamo Colleges is eligible but are not currently funded.

o There are numerous other grant funding sources which the Committee has not had the opportunity to investigate the eligibility implications of Individual Accreditation versus Single Accreditation (Appendix H).

Other Relevant Facts:

o Structure: The Department of Education (DOE) stated unequivocally, that

the decision handed down by the DOE will be based on the information provided by the Alamo Colleges, and any deviation would nullify the ruling (telephone conference call with DOE representatives on October 15, 2009). The current and proposed ACCD structures, as sent to DOE, are provided in Appendices J & K.

o Title V information from other community colleges: The information

collected from the Alamo Colleges peer institutions with single accreditation indicates variations from institution to institution in Title V HSI eligibility for branch campuses (Appendix K); the Grants Committee is unable to draw conclusions from the sampling regarding the apparent differences.

o The Grants Committee reviewed 45 major grants for which the Alamo

Colleges are individually eligible to apply or are currently funded under the current structure (Appendix H). Due to the varying criteria, each grant would require individual research in terms of the impact of moving from Individual Accreditation to Single Accreditation.

o There is a concern regarding high-income dilution from the Alamo

Colleges eight (8) county service area inhibiting the district’s qualification for HSI grants under the Single Accreditation model. Although the district is likely to maintain a high Hispanic enrollment for the foreseeable future,

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there is uncertainty that Hispanic students will continue to meet Pell grant qualifications throughout the district.

4. Are any of the Core Requirements of accreditation affected differently by becoming

a Single Accreditation college district?

See 1(b) above. The Core Requirements do not change depending on the accreditation model. However, the district’s approach to meeting those requirements may necessitate some revision if it moves to the Single Accreditation model. The Committee addresses below the specific Core Requirements that may be affected by moving to the Single Accreditation model:

CR 2.1 “The institution has degree-granting authority from the appropriate government agency or agencies.” Committee’s observations: As part of the substantive change process, the district would need to work with the Texas Higher Education Coordinating Board (THECB) to change degree-granting authority from individual colleges to the district. This would be accomplished by completing a request for administrative change and submitting it to the board as described on the THECB website: http://www.thecb.state.tx.us/index.cfm?objectid=839594BE-E203-5016-1ADF9E08CB741879&flushcache=1&showdraft=1 According to information posted on the website, administrative changes with new costs under $2 million during the first five years are automatically approved. If new five-year costs equal or exceed $2 million, administrative change would need to be approved by the Coordinating Board at one of its quarterly meetings. CR 2.5 “The institution engages in ongoing, integrated, and institution-wide research-based planning and evaluation processes that incorporate a systematic review of programs and services that (a) results in continuing improvement and (b) demonstrates that the institution is effectively accomplishing its mission.” Committee’s observations: Alamo Colleges has district-wide planning and Institutional Research, but the process to review all academic programs and services is currently the purview of each individual college. The review itself is based on data provided by district Institutional Research. A district-wide review process would have to be developed to supplant the current program reviews done locally at each college.

o District-wide review process must be followed consistently or non-

compliance at one Branch Campus (College) impacts the entire district.

o Time and ongoing administrative oversight (requiring financial and personnel resources) will be needed to develop and maintain district program review competencies.

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CR 2.7 “(Core requirements 2.7.1-2.7.4 address degree programs, specifically program length, program content, general education, and course work for degrees.)” Committee’s observations: No impact. District-wide degree plans are being developed and standardized. CR 2.8 “The number of full-time faculty members is adequate to support the mission of the institution. The institution has adequate faculty resources to ensure the quality and integrity of its academic programs. In addition, upon application for candidacy, an applicant institution demonstrates that it meets Comprehensive Standard 3.7.1 for faculty qualifications.” Committee’s observations: No impact. Employee Services already maintains data on faculty qualifications at the district level. CR 2.9 “The institution, through ownership or formal arrangements or agreements, provides and supports student and faculty access and user privileges to adequate library collections as well as to other learning/information resources consistent with the degrees offered. These collections and resources are sufficient to support all its educational, research, and public service programs.” Committee’s observations: No impact. CR 2.10 “The institution provides student support programs, services, and activities consistent with its mission that promote student learning and enhance the development of its students.” Committee’s observations: No impact. All essential student support programs, services, and activities are provided at each college. In addition, each college tailors distinct support programs for the population it serves. CR 2.11.1 “The institution has a sound financial base and demonstrated financial stability to support the mission of the institution and the scope of its programs and services.”

o Single Accreditation: No impact on accreditation if the district adopts

the Single Accreditation model. If a substantive change is initiated, submission of ACCD’s Audited Financial Statements will meet the requirements.

o Reaccreditation of Individually Accredited Colleges: Alamo Colleges

that are already Individually Accredited (i.e., Palo Alto College, San Antonio College, St. Philip’s College, and Northwest Vista College) are not required to have a separate audit for reaccreditation provided there is a district audit with supplemental schedules for each individual institution. For reaccreditation of Individually Accredited institutions, submission of ACCD’s Audited Financial Statements meets the requirements.

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o New College Applications (i.e. Northeast Lakeview College): Audit requirements are more stringent for non-members of SACS than for members. When a public institution applies for membership, SACS requires a separate, stand-alone full-set of financial statements in accordance with accounting principles generally accepted in the United States. At present, these required financial statements cannot be prepared without incurring expense to create separate college-level accounting records (i.e., a separate set of books reflecting detailed transactions at the college level). Personnel and audit costs to implement this accounting procedure are estimated at $190,000 to $269,000 per year ($2 million over 10 year period; see Appendix L). For SACS confirmation of requirements to meet CR 2.11, see Appendix M.

CR 2.12 “The institution has developed an acceptable Quality Enhancement Plan and demonstrates that the plan is part of an ongoing planning and evaluation process.” Committee’s observations: Consolidation would require the development and implementation of a district-wide Quality Enhancement Plan (QEP) that would standardize objectives and measurement instruments currently developed and maintained at the college level. Institutional Research will need to provide consistent, district-wide methodology. Consolidation would require that a district-wide QEP be developed within five years.

5. Are any of the Comprehensive Standards affected? If so, which ones and how?

See 1(b) above. The Comprehensive Standards do not change depending on the accreditation model. However, the district’s approach to meeting those standards may necessitate some revision if we move to Single Accreditation. The Committee addresses below the specific Comprehensive Standards that may be affected differently by moving to Single Accreditation.

SACS’ Principles of Accreditation holds that: “It is implicit in every Comprehensive Standard mandating a policy or procedure that the policy or procedure is in writing, approved through appropriate institutional processes, published in appropriate institutional documents accessible to those affected by the policy or procedure, and implemented and enforced by the institution.” Committee’s observations: No significant impact; however, Alamo Colleges may need to further develop district-wide means of implementing and enforcing policy and procedures.

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CS 3.3.1 “The institution identifies expected outcomes for its educational programs and its administrative and educational support services; assesses whether it achieves these outcomes; and provides evidence of improvement based on analysis of those results.”

Committee’s observations: District-wide learning outcomes would involve further integration of curricula and program objectives across the district. The Alamo Colleges common learning outcomes project is slated to begin in the near future, but there is much work to be done to develop, implement, and assess outcomes as well as to develop cycles of improved performance on those outcomes. The following estimated timelines indicate that it will take at least six years to develop learning outcomes and to then complete at least three cycles of assessment and improvement to meet the CS3.3.1. Projected Timeline for developing, implementing, assessing and improving District-wide common learning outcomes: Activity Projected Completion Program Alignment March 2011 Core Learning Outcomes (Core Curriculum) June 2011 Aligned Program Learning Outcomes June 2012 Common Course Learning Outcomes June 2012 Build Measurement System for Learning Outcomes June 2013 Baseline Assessment/Results for Outcome Measures June 2014 2nd year Assessment/Results Improvement Cycle June 2015 3rd year Assessment/Results Improvement Cycle June 2016

CS 3.4.1 “The institution demonstrates that each educational program for which academic credit is awarded (a) is approved by the faculty and the administration, and (b) establishes and evaluates program and learning outcomes.” Committee’s observations: A district-wide curriculum process is being initiated this Fall by which faculty at the various colleges would work together to approve course curricula (including skill levels and prerequisites), educational programs, and learning outcomes.

 

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6. Determine the costs associated with remaining “Individual Accreditation” colleges, especially determining the cost of establishing new colleges and the necessity of separate books and audits and the cost of on-going reaffirmation for the five colleges versus accrediting and reaffirming a Single Accreditation district. Consider this over a ten-year cycle of accreditation and reaffirmation. Also, because our colleges, as independent entities, have organized themselves as autonomous organizations, consider the costs of continuing to operate separate yet concurrent systems, such as bursar services, at each of the colleges.

Costs associated with Individual Accreditation (total $4.18 million over a 10 year

accreditation period or $418,000 annually):

o Financial and audits: Personnel and audit costs to maintain a separate set of books is estimated at $190,000 - $269,000 per year ($2.03 million over 10 year period; see Appendix L).

o Cost of on-going reaffirmation for five colleges’ applications and site

visits: $15,000 per year.

o Quality Enhancement Plans (QEP): $2000,000 per year ($2 million over 10 year period) as follows:

Annual

San Antonio College Actual Expenditure $70,000 St. Philip’s College Actual Expenditure $70,000 Northwest Vista College Actual Expenditure $10,000

(Northwest Vista costs were less due to infrastructure that was already in place and the availability of grant funds to cover faculty development.)

Northeast Lakeview College – Estimated $10,000 Palo Alto College – Estimated as average $40,000

Costs associated with Single Accreditation (total $1.83 million over 10 years or

$183,000 annually):

o Financial and audits: no cost as District Annual Financial Statements meet requirements.

o Cost of accrediting and reaffirming a multi-college district: application and site visits: $3,000 per year.

o Quality Enhancement Plans (QEP): assumed 10% savings over current

level of expenditures with economy of scale of single comprehensive QEP

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for the district; however additional district oversight and coordination would be required. Estimate Total Costs of $180,000 per year ($1.8 million over 10 year period).

Other Considerations: Strategic initiatives to centralize support services such as

Bursar, Registration, and Financial Aid can be implemented irrespective of the accreditation model adopted and, as a result, are excluded from this analysis.

In summary, single accreditation saves approximately $235,000 annually ($2.35 million over 10 years):

Individual Accreditation Single Accreditation

FY2010 (1/2 year) 258,750 183,000 FY2011 477,438 183,000 FY2012 483,625 183,000 FY2013 439,813 183,000 FY2014 405,220 183,000 FY2015 410,927 183,000 FY2016 416,804 183,000 FY2017 422,859 183,000 FY2018 429,094 183,000 FY2019 435,517 183,000 10 Year Total 4,180,046 1,830,000

7. As we serve a relatively compact geographic service area and because students may

desire to attend a college outside of their neighborhood or attend more than one of our colleges, what are the implications to student access and success in an Individual Accreditation system versus a Single Accreditation system?

Committee’s observations: Given that core curriculum, programs, degree plans, and Student Learning Outcomes are already being standardized across the district, moving to single accreditation would have no significant impact for student access or success.

 

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8. Consider accurately from discussions with other multi-college districts whether any of the "unique cultures" of our five colleges will be adversely affected by becoming a “Single Accreditation” district. How do others, both “Individual Accreditation” districts and “Single Accreditation” districts address the need to celebrate and reinforce the unique cultures of each of the colleges? Please be precise in how you analyze this item, as the response of the other colleges will depend on how the question is asked.

Four peer community college systems were selected to interview: a) Individual

Accreditation district (Dallas) and b) Single Accreditation districts (Houston, El Paso, and Lone Star). Houston and Lone Star were unavailable for interviews; thus, data gathering was limited to El Paso and Dallas. In both accreditation models, these colleges believed “unique cultures” were accommodated. See Appendix N for questions asked and attendees. Highlights of the conversation are as follows:

o Richland College: Each of the seven colleges in the Dallas system has a

separate mission and vision statement that is unique to its particular focus, distinct culture, and demographics. Although Richland does share the same core curriculum and the same degree plans with other colleges in the Dallas system, Dean Janet James commented during the interview that members of the Richland College community feel that they have “more ability to innovate and create because we are separately accredited.”

o El Paso Community College: El Paso Community College is Singly Accredited. However, each campus has developed its own culture based on the programs that it offers (e.g., Allied Health at the Downtown campus; law enforcement at the Mission campus). All campuses collaborate on curriculum. The district has a single graduation, and organizations for students, faculty, and staff are centralized. Programs celebrating local cultures are initiated and implemented by the district then hosted for a limited time at a particular campus.

Committee’s observations: The “local culture” evident at each of the Alamo Colleges are attributed by the Colleges, at least in part, to the fact that each college serves a different community and grew out of a different climate. Northeast Lakeview College serves Judson Independent School District and the

military community of Randolph Air Force Base.

Palo Alto College focuses on access for first-generation and underserved populations. Architecturally, the college is designed for small class sizes and individual attention to students. The college partners with Texas A&M-San Antonio.

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St. Philip’s College, the nation’s only institution having both HBCU and HSI designations, draws students from throughout the Alamo Colleges service area because of its distinct technical programs.

San Antonio College is the fourth largest single campus community college in the nation with a distinct university feel.

Northwest Vista serves the northwest-side demographic and has a uniquely progressive pedagogical culture with innovative approaches to assessment.

Committee’s observations: The ARC did not, based on the time constraints, choose to contact additional institutions because it did not appear that further interviews on the question of culture would further inform whether Single or Individual College Accreditation is preferable.

9. Which methodology provides the best opportunities for the future of our students

and communities and why?

The Committee feels this question is too subjective for an unbiased opinion and is better suited for the reader to answer based on the content of this report. Therefore, the Committee refers to question 11 which states the Pros and Cons of the models – allowing the reader to reach his or her own conclusions.

10. What are the timelines and processes for accrediting new colleges (Northeast Lakeview College, North Central College) versus achieving Single Accreditation?

Committee’s observations: The response to this question is taken almost verbatim from the document found on the SACS website Substantive Change for Accredited Institutions of the Commission on Colleges. Of particular interest is the substantive change process for becoming Singly Accredited as a district. The four accredited colleges will participate in the accreditation associated with substantive change. As an unaccredited institution, Northeast Lakeview College will then undergo separate accreditation to join the Alamo Colleges. SACS will decide the time line for the accreditation of Northeast Lakeview College under the Single Accreditation model when Northeast Lakeview College makes its application (i.e., its prior application for candidacy will be considered and may expedite the accreditation process according to Dr. Ann Chard, Commission on Colleges Vice President).

Timeline and processes for accrediting new colleges (Northeast Lakeview

College, North Central College):

o General Steps in the Process for Achieving Initial Membership for Single Accreditation (This material is taken from the SACS-COC website.)

1. Attendance at a Workshop for Pre-Applicant Institutions (minimum of 18 months prior to submission)

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An institution planning to submit an application must attend a one day workshop at the SACS-COC offices in Atlanta. These workshops are held twice a year. The workshop acquaints attendees with the accreditation process and with the Core Requirements, Comprehensive Standards, and Federal Requirements.

2. Submission of an Application by the Institution and Initial Review by the Commission (This process can take up to 24 months, but a minimum of 12 months because the application requires a full year’s independent audit as well as a full year’s worth of institutional effectiveness data.)

An institution seeking membership must first submit an application describing the characteristics of the institution and documenting its compliance with Core Requirements 2.1-2.11, Comprehensive Standards 3.3.1, 3.5.1, and 3.7.1, and Federal Requirements 4.1-4.7. The application is initially reviewed by Commission staff and then by peer reviewers, known as the Committee on Compliance and Reports. (In October 2009, Northeast Lakeview College submitted its application and requested it be sent to the Committee on Compliance and Reports. NLC will be notified at the December SACS-COC Meeting if a Candidacy Committee has been authorized and a site visit scheduled.)

3. Authorization by the Commission of a Candidacy Committee (The Commission meets twice a year, in June and December. Materials for consideration must be sent to them at least two months prior to their meetings. )

When the Commission determines that the institution has demonstrated compliance with Core Requirements 2.1-2.11, Comprehensive Standards 3.3.1, 3.5.1, and 3.7.1, and Federal Requirements 4.1-4.7, it will authorize a Candidacy Committee to visit the institution in either the Spring or Fall. The Candidacy Committee verifies on site the documentation presented in the application and writes a report that is forwarded to the Committee on Compliance and Reports for review and consideration of Candidacy status for the institution. The institution has a minimum of two weeks to respond to the Candidacy Committee Report if it wishes to do so. If it responds to the report, the response will also be forwarded to the Committee on Compliance and Reports. If the Commission determines that the institution is not in compliance with any of the above requirements, it will deny authorization of a Candidacy Committee. Denial of authorization of a Candidacy

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Committee visit by the Commission is not appealable. The institution may submit a new application whenever it wishes.

4. Granting of Candidacy Status by the Commission

The institution is granted Candidacy status upon recommendation of the Committee on Compliance and Reports and subsequent action by the Commission indicating that the institution has demonstrated compliance with the requirements of the application and that this compliance has been verified by a Candidacy Committee which has visited the institution. Candidacy is effective on the date of Commission action to grant Candidacy. If Candidacy is denied, the institution must submit a new application along with application fees and must be authorized to receive another Candidacy Committee visit before being considered again for Candidacy. Denial of Candidacy is appealable.

5. Completion by the Institution of a Compliance Certification (Must be completed within 24 months of being granted Candidacy.)

When Candidacy is granted, the institution must complete a Compliance Certification documenting continued compliance with Core Requirements 2.1-2.11, Comprehensive Standards 3.3.1, 3.5.1, and 3.7.1, and Federal Requirements 4.1-4.7 and must document compliance with the remainder of the Comprehensive Standards of the Principles of Accreditation and receive an Accreditation Committee visit within the two years following the date the institution was granted Candidacy status. The report of the Accreditation Committee and the institution’s response to the recommendations in that report are sent to the Commission for one of the following actions:

1. grant membership, or 2. continue the institution in Candidacy status for a maximum of two more years, or 3. remove the institution from Candidacy.

Removal from Candidacy is an appealable action. If the Appeals Committee’s final decision is to reverse the Commission’s decision to remove the institution from Candidacy, the institution remains in Candidacy, receives another Accreditation Committee visit, and

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within two years is again considered for membership by the Commission. If the institution is granted Continued Candidacy, an Accreditation Committee will again visit the institution within the next two years of Candidacy. The report of that Accreditation Committee and the institution’s response to that report will be sent to the Commission for action either granting or denying membership. If the decision of the Commission is to deny membership, the institution will be removed from Candidacy. This action is appealable. If the Appeals Committee’s final decision is to reverse the Commission’s decision to remove the institution from Candidacy, the institution is granted membership status.

Timeline and processes for achieving single accreditation of the four already

accredited colleges (SAC, SPC, PAC, NVC)

o Procedure for the Review and Approval of Consolidations/Mergers

Definition The Commission defines a consolidation as the combination or transfer of the assets of at least two distinct institutions (corporations) to that of a newly-formed institution (corporation), and defines a merger as the acquisition by one institution of another institution's assets. For the purposes of accreditation, consolidations and mergers are considered substantive changes requiring review by the Board of Trustees. (Examples include: a senior college acquiring a junior college, a degree-granting institution acquiring a non-degree-granting institution, two junior or senior colleges consolidating to form a new institution, or an institution accredited by the Commission on Colleges merging with a non-accredited institution). Procedures for a COC Member Institution Initiating a Consolidation/Merger with another COC Member Institution(s) Time of Notification: The chief executive officers of the member institutions undergoing merger/consolidation must provide written notification of the change to the President of the Commission on Colleges six months in advance of the designated date for final approval of the consolidation/merger by the new institution's governing board. Upon notification, the President of the Commission will ask the institutions involved in the consolidation/merger to submit a combined written prospectus.

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Submission of the Prospectus: The Board of Trustees meets in June and in December. The prospectus for substantive change must be submitted to the Commission office by April 15 for review and consideration at the June meeting, and by October 1 for consideration at the December meeting. The prospectus must describe how each institution plans to continue to meet the Principles while implementing the change. (Please refer to Exhibit A for descriptions of information to be included in the prospectus.) Four copies of the prospectus should be submitted to the President of the Commission in print form or on CD or DVD. Review Process: The President of the Commission will forward the institutions’ prospectus to the Board of Trustees. If the prospectus is accepted, the Board will approve the consolidation/merger of the institutions involved pending final approval of the consolidation/merger by the new institution's governing board. It also will authorize the appointment of a Substantive Change Committee to visit the new institution to determine ongoing compliance with the Principles of Accreditation. After the Board has acted favorably on the prospectus and the newly-formed institution has received final authority from its governing board, the institutions involved in the consolidation/merger will be considered one accredited institution. The Substantive Change Committee visit will occur within six months after the Board of Trustees’ approval and the institutional governing board's final approval of the consolidation/merger. The report of the Substantive Change Committee, together with the response of the institution to any recommendations contained in that report, will be reviewed by the Board of Trustees. Following review, the Board of Trustees will (1) continue the new institution in accreditation or (2) impose sanctions for failure to maintain compliance with the Principles. If the Commission does not approve the prospectus for a consolidation or merger and the institutions do not proceed with the change, the COC-accredited institutions will maintain their separately accredited status. However, if they continue with the change without prior approval, all institutions participating in the merger/consolidation could lose their accreditation. The newly-formed institution may apply for accreditation by the Commission on Colleges in keeping with the Commission's procedures for applicant institutions. Changes to the Reaffirmation Cycle: The newly consolidated/merged institution will be required to achieve reaffirmation of accreditation within five years following the Board of Trustee's action to continue accreditation. The institution will then maintain the normal ten-year reaffirmation cycle. If the Board of Trustees determines that the substantive change adversely affects each member's continued compliance

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with the Principles of Accreditation, the accreditation of all member institutions involved will be placed in jeopardy.

Time line and processes for achieving the merger of a COC-accredited institution

(i.e., Alamo Colleges) with a non-COC accredited institution (i.e., NLC, NCC)

o Procedures for a COC Member Institution Initiating a Consolidation/Merger with a Non-COC Accredited Institution

Time of Notification: The chief executive officer of the COC-accredited institution undergoing consolidation/merger must provide written notification of the change to the President of the Commission six months in advance of the designated date for final approval of the consolidation/merger by the new institution’s governing board. Upon notification, the President of the Commission will ask the COC-accredited institution to submit a written prospectus. Submission of the Prospectus: The Board of Trustees meets in June and in December. The prospectus for substantive change must be submitted to the Commission office by April 15 for review and consideration at the June meeting, and by October 1 for consideration at the December meeting. The prospectus must describe how the member institution plans to continue to meet the Principles while implementing the change. (Please refer to Exhibit A for descriptions of information to be included in the prospectus.) Four copies of the prospectus should be submitted to the President of the Commission in print form or on CD or DVD. Review Process: Upon receipt of the prospectus, the President of the Commission will refer it to the Board of Trustees for review. Following review, the Board of Trustees will (1) accept the prospectus and authorize the appointment of a Substantive Change Committee to visit the institution, (2) deny acceptance of the prospectus, or (3) defer action to the next Board of Trustees meeting, pending submission of additional information. If the prospectus is accepted, the institutions can begin implementation of the consolidation/merger. During this time, the accreditation status of the COC-accredited member institution will remain unchanged until after the consolidation/merger has been approved by the Board of Trustees. A Substantive Change Committee visit will occur within six months after its authorization. The report of the Substantive Change Committee, together with the response of the member institution to any recommendations contained in that report, shall be reviewed by the Board of Trustees. The Board of Trustees will (1) approve the consolidation/merger of the newly-formed institution, (2) deny the

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consolidation/merger for failure of the new institution to comply with the Principles, or (3) defer action. If the Board of Trustees does not accept the prospectus for a consolidation/merger or the Board of Trustees does not approve the consolidation/merger following the visit by the Substantive Change Committee and the COC-accredited institution does not proceed with the change, the COC-accredited institution will maintain its separately accredited status. However, if the member institution continues with the change without prior or final approval, it could lose its accreditation with the Commission. The newly-formed institution may then apply for accreditation with the Board of Trustees in keeping with the Commission's accreditation procedures for applicant institutions. Changes to the Reaffirmation Cycle: The newly consolidated/merged institution will be required to achieve reaffirmation of accreditation within five years following the Commission's action to continue accreditation. The institution will then maintain the normal ten-year reaffirmation of accreditation cycle. If the Board of Trustees determines that the substantive change adversely affects each member's continued compliance with the Principles of Accreditation, the accreditation of the COC member institution involved shall be placed in jeopardy.

11. Describe the pros and cons of each option. How do we mitigate the cons to either

option?

Committee’s observations: The Committee notes the subjective nature of this question and seeks to provide the most unbiased factual observations possible based on the data obtained through this process. Advantages of Individual College Accreditation Model (Current Model)

o Grant Implications – The Alamo Colleges (ACCD) may be unique among

community colleges across the country in having four (soon to be five) accredited colleges, one of which is an Historically Black College (HBCU designation) and all of which are Hispanic Serving Institutions (three are currently eligible for federal grants as HSI eligible institutions). Based on the written information the Committee has been able to gather from the Department of Education and from the federal Higher Education Codes, it appears that under a Single Accreditation model, St. Philip’s College would lose its current Title III(B) funding as an HBCU. Each of the colleges could, however, as “Branch Campuses” retain HSI eligibility for Title V grants as long as the overall District and the branch campus meet eligibility criteria.

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The loss of HBCU funding eligibility would cost St. Philip’s college $5,000,000 to $7,000,000 annually.

Although there could be an opportunity to submit an appeal

to retain HBCU status, there is no way of knowing if such an appeal would be granted, and there appears to be a precedent for not approving such an appeal.

If by chance St. Philip’s were granted permission to retain

its HBCU designation, the other College’s (San Antonio College, Palo Alto College, Northwest Vista College and, in the future, Northeast Lakeview College) would then forfeit their ability to apply for Title V grants. Pursuant to CFR definitions, an “institution” (which under Single Accreditation would be the ACCD as a whole) cannot receive both Title III and Title V funding (over $1,000,000 annually in potential grant funding).

o SACS Accreditation Issues -- According to information from SACS, a

move to Single Accreditation would occur using the Substantive Change Process. That process provides for the movement from four accredited institutions to one accredited body and allows five years to demonstrate compliance with SACS criteria (including the development of a new QEP for the District). The Substantive Change Process also provides for bringing in a new, currently unaccredited campus, in this case Northeast Lakeview College. It appears that the process of bringing in Northeast Lakeview College might have to wait until after the initial combining of accredited colleges is completed and approved by SACS. It would be up to SACS to decide when that could happen, but it could take as much as five years, depending on SACS rulings.

o Other Issues – Certain questions in the Committee charge dealt with issues

of culture and change. Although the Committee attempted to gather some information through dialogues with other Singly Accredited institutions as well as Individually Accredited institutions there are no definitive conclusions that could be drawn. What seems important, therefore, is to express key fears and concerns among many, if not most, faculty and staff across the Alamo Colleges.

Individuals at the Colleges strongly identify with the College of

residence. There is a fear that a move to Single Accreditation threatens long established college cultures and identities. Although a Single Accreditation does not have to be accompanied by such loss of identity, concerns loom large.

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Most faculty and staff members appear to see the benefits of increased collaboration, process alignment, and a set of common outcomes. There exists, however, deep concern about the potential loss of flexibility and agility at the colleges where the students reside to effect programs and innovations that improve student results.

There is obviously a common interest among Board members,

District Office personnel, and college employees that student success is our primary goal and concern. There also seems to be agreement that Alamo Colleges needs to move toward greater collaboration to improve processes and attain the best balance of cost and benefit. The issue of what accreditation model Alamo Colleges uses to achieve those ends may not be the most important issue to be addressed at this point in the history of the Alamo Colleges.

o According to extensive research literature, such as Organizational

Configuration And Performance: The Case Of Primary And Secondary School Systems by William G. Ouchi, Bruce S. Cooper, Lydia G. Segal, Tim DeRoche, Carolyn Brown, and Elizabeth Galvin, the most successful educational organizations seek to maximize their flexibility through Site-Based Management “SBM”. Complex, collegial, and uncertain work, lends itself to decentralization and employee involvement, which is the core of SBM. A significant amount of work in the education sector is complex, requires teamwork, and exists in a dynamic environment that may demand ongoing innovation. By definition, a highly centralized, authoritarian management structure cannot foster innovation to the same extent that a SBM environment can.

Research literature in the learning sciences indicates that SBM

leads to improved student learning outcomes.

There is concern that a Single Accreditation model could lead to further centralization of authority and decision-making in order to comply with SACS requirements. Such an organizational structure may contradict the principles of SBM and could undermine the district’s commitment to improving student success.

The potential issues could be mitigated by maintaining a Site-

Based Management approach, regardless of the accreditation model.

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Advantages of Single ACCD Accreditation Model

o Accreditation Costs – A Single ACCD Accreditation model would be less costly than the current Individual College Accreditation model.

The average annual cost savings over the next ten years are

estimated at around $235,000.

The cost differential comes primarily from two places. First, in order to obtain accreditation for new colleges (in this case Northeast Lakeview College), SACS requires that a totally separate financial audit be submitted for the new applicant. There is an annual cost associated with setting up and maintaining separate financials for each College. The second key cost area relates to the actual cost of ongoing accreditation (i.e. site visits, dues, QEP’s for five accredited bodies versus one).

o SACS Accreditation Issues – The SACS criteria for accreditation essential

apply in the same manner under a Single ACCD Accreditation model or under an Individual College Accreditation model. The primary changes that would need to occur to move to Single Accreditation involve some key processes.

A Single ACCD Accreditation would require effective district-

wide processes to coordinate all aspects of compliance with the SACS criteria for accreditation.

The SACS requirements involving the most significant change in

process deal with institutional effectiveness criteria. Under the current Individual College Accreditation model, each ACCD College, as required by SACS, demonstrates that it has established student outcomes for programs and services, measures the achievement of those outcomes, and engages in cycles of improvement. Under a Single Accreditation model the District would collectively have to develop common outcomes, establish measures of effectiveness for those outcomes, assess the results, and engage in cycles of improvement. Although this move toward common outcomes is possible and even desirable, the process of building the system and moving through cycles of assessment and improvement to show compliance with SACS criteria will take several years.

 

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12. Higher education is under great pressure to become more cost effective, more flexible and capable of rapid change. How does each model allow the Alamo Colleges to achieve these goals?

Committee’s observations: There is no simple answer to this question as each model provides unique benefits and challenges. For example, uniformity and centralization may allow students to traverse between colleges more quickly and easily but it may also slow down decision-making as decision-points would have to be negotiated amongst five institutions. Savings on one end could be offset by additional costs on the other. To quantify the dollar impact of one model over another is problematic. Regardless of the model adopted, the Committee agrees that the Alamo Colleges needs to increase its capacity to adapt to rapid change and operate more efficiently and effectively. The response to question 6 provides data related to those areas that can be more easily financially quantified. There is public school research on decentralized, site-based management models that indicates site-based management achieves better student results, possibly due to greater flexibility and agility for innovations and other strategies regarding student interventions and programs. Such a management structure can be implemented under either a Single Accreditation model or an Individual Accreditation model. There exist deep concerns on the part of faculty and staff at the colleges about the potential loss of that flexibility if Single Accreditation brings a more centralized approach.

13. Are there any other considerations that should be explored? Please describe them

and their impact.

Committee’s observations: The Committee has worked diligently to gather as much data as possible in order to provide a complete understanding of each accreditation model contemplated by Alamo Colleges. The Committee believes that additional areas of exploration include:

Other Grant opportunities for all colleges and the impact, if any, of each

accreditation model on those individual grants (Appendix G).

Additional exploration of future demographic data in current service areas as well as expansion service areas to ensure demographic changes do not negatively affect Title V HSI grant eligibility.

Additional legal analysis and research of the implications of “Merger” on St.

Philip’s HBCU status.

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APPENDICES

Appendix A – Memorandum from Dr. Bruce Leslie to Accreditation Review Committee, July 2, 2009

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Dr. Adriana ContrerasDeputy to the Chancellor

Chancellor's Office

MEMORANDUM TO: Ms. Pamela Ansboury, Comptroller

Dr. Thomas Brown, Associate Professor, Sociology, NLC Dr. Jackie Claunch, President, NVC Dr. Tom Cleary, Vice Chancellor, Planning, Performance & Information Systems Dr. Adriana Contreras, Deputy to the Chancellor Dr. Mike Flores, Vice President of Colleges Services, PAC Mr. Gerardo Guerra, Multimedia Specialist, SAC Dr. Debbie Hamilton, Vice President of Student Services, NLC Mr. Jeff Hunt, Chairperson, Theatre and Speech Communication, SAC Dr. Mary Ellen Jacobs, Chairperson/Associate Professor, English, PAC Dr. George Johnson, Associate Professor, Mathematics, SPC Dr. Beth Lewis, Vice President of Academic Affairs, f\JLC Dr. Paul Martinez, Associate Professor, History, NVC Dr. Diana Muniz, Vice President of Student Success, NVC Dr. Christopher Pate, Dean of Health Sciences, SPC Mr. Tim Rockey, Dean of Continuing Education, Training Network, SAC Ms. Diane Snyder, Associate Vice Chancellor for Finance & Fiscal Services

FROM: Dr. Bruce Leslie, Chancellor DATE: July 2, 2009 SUBJECT: Accreditation Review Committee & Charge I am pleased to appoint you to serve as a member of the Accreditation Review Committee to be co-chaired by Dr. Jackie Claunch and Mr. Jeff Hunt and supported by Dr. Adriana Contreras and Ms. Pamela Ansboury. An outside facilitator will also be provided to assist the committee in its work. Chairman McClendon, on behalf of the Board of Trustees, has charged me "... to formulate a committee to examine the advantages, disadvantages, costs, and cost savings on establishing joint accreditation for all of our colleges. Now, I would like for the committee that you form to be very inclusive, because I am sure there are some people who may have a difference of opinion on how best to do this. Also, I would like for you to come back to us with a written report, hopefully by our August meeting. The reason being, I would like to consider this before we approve our budget; because there are some costs associated with this one way of the other, so we need to really examine that.”

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In order to fulfill this charge, I am requesting that you advise me on the impact of both continuing separate accreditation and transitioning to a multi-college district by determining answers to a series of questions in order that the committee may identify and agree on the facts around accreditation and thereby providing me with a means by which I may make a recommendation to the Board based on these facts. I am not asking the committee to make a specific recommendation as to which model we should adopt. The committee should consider the Principles of Accreditation as the basis for its analysis, especially considering the following: “Both a process and a product, accreditation relies on integrity, thoughtful and principled judgment, rigorous application of requirements, and a context of trust. It provides an assessment of an institution's effectiveness in the fulfillment of its mission, its compliance with the requirements of its accrediting association, and its continuing efforts to enhance the quality of student learning and its programs and services. Based upon reasoned judgment, the process stimulates evaluation and improvement, while providing a means of continuing accountability to constituents and the public." (p. 3) This statement suggests that the purpose of accreditation should be to “…provide a means of continuing accountability to constituents and the public." Therefore, your efforts should consider those facts that illuminate for me and the Board, which accreditation approach would best serve the long-term and continuing improvement needs of our students and the community. Your analysis should also be based on chapter 130 of the Texas Education Code, which governs the creation and operation of junior and community colleges in Texas and section 11.151 which governs independent school districts and applies to the governing of a junior or community college. From the Fundamental Characteristics of the Principles of Accreditation (Page 4), determine if these statements apply equally whether we have a multiple college or single system of accreditation:

• Accreditation requires an institutional commitment for student learning and achievement. • Accreditation acknowledges an institution's prerogative to articulate its mission within the recognized context of higher education and its responsibility to show that it is accomplishing its mission. • Accreditation expects an institution to ensure that its programs are complemented by support structures and resources that allow for the total growth and development of its students.

The following questions should be addressed as thoroughly as possible, showing evidence of the facts associated with the committee's responses:

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1. Are the Standards of Accreditation any different for individually accredited versus singularly accredited multi-college institutions? Is the district capable of achieving the standards of accreditation if we become a singularly accredited system? What are the implications for the Alamo Colleges as independently accredited versus a multi-college district? 2. Is there any impact on Federal requirements for accreditation? 3. Is there any impact on either St. Philip's College's designation as an HBCU, or the colleges' designations as Hispanic Serving Institutions; are other designations or grants affected? 4. Are any of the Core Requirements of accreditation affected differently by becoming a multi-college district? 5. Are any of the Comprehensive Standards affected? If so, which ones and how? 6. Determine the costs associated with remaining as independently accredited colleges, especially determining the cost of establishing new colleges and the necessity of separate books and audits and the cost of on-going reaffirmation for the five colleges versus accrediting and reaffirming a multi-college district. Consider this over a ten-year cycle of accreditation and reaffirmation. Also, because our colleges as independent entities have organized themselves as autonomous organizations, consider the costs of continuing to operate separate yet concurrent systems, such as bursar services, at each of the colleges. 7. As we serve a relatively compact geographic service area and because students may desire to attend a college outside of their neighborhood or attend more than one of our colleges, what are the implications to student access and success of separately accredited or singularly accredited colleges? 8. Consider accurately from discussions with other multi-college districts whether any of the "unique cultures" of our five colleges will be adversely affected by becoming a singularly accredited district. How do others, both single and multi- college districts address the need to celebrate and reinforce the unique cultures of each of the colleges? Please be precise in how you analyze this item, as the response of the other colleges will depend on how the question is asked. 9. Which methodology provides the best opportunities for the future of our students and communities and why? 10. What are the timelines and processes for accrediting new colleges (NLC, NCC) versus achieving single accreditation? 11. Describe the pros and cons of each option. How do we mitigate the cons to either option? 12. Higher education is under great pressure to become more cost effective, more flexible and capable of rapid change. How does each model allow the Alamo Colleges to achieve these goals? 13. Are there any other considerations that should be explored? Please describe them and

their impact.

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The Board's charge is for me to provide a recommendation by the August meeting in order to include necessary costs in the 2009-10 budget. Is this achievable? If not, what advice does the committee provide? The Board of Trustees will, upon completion of the committee's fact-finding, share the findings with the colleges and hold meetings to inform and educate those interested including students and the community. This will ensure that no further questions require additional assessment prior to the trustees considering further action. I recognize that this is a complex project, one which will likely be further complicated by emotions. By serving on this committee, I am confident that you will remain open to uncover the facts, regardless of where they may lead. I look forward to your thoughtful, deliberate and thorough assessment of the issues posed. I will be pleased to make myself available during your deliberations in order to answer any questions and assist in the completion of your assignment. Our SACS' staff representative should also be available to meet with the committee, if invited . You will be informed as soon as possible as to the date and location of the first meeting. C: Board of Trustees Presidents and Vice Chancellors

 

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Appendix B – Response from United States Department of Education, November 4, 2009  

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Appendix C – 34 CFR Ch. VI (7-1-03 Edition) Subpart A—General § 606.1 What is the Developing Hispanic-Serving Institutions Program? The purpose of the Developing Hispanic-Serving Institutions Program is to provide grants to eligible institutions of higher education to—

(a) Expand educational opportunities for, and improve the academic attainment of, Hispanic students; and (b) Expand and enhance the academic offerings, program quality, and institutional stability of colleges and universities that are educating the majority of Hispanic college students and helping large numbers of Hispanic students and other low-income individuals complete postsecondary degrees. (Authority: 20 U.S.C. 1101) § 606.2 What institutions are eligible to receive a grant under the Developing Hispanic-Serving Institutions Program? (a) An institution of higher education is eligible to receive a grant under this part if—

(1) At the time of application, it has an enrollment of undergraduate full-time equivalent students that is at least 25 percent Hispanic students; (2) It provides assurances that not less than 50 percent of its Hispanic students are low-income individuals; (3) It has an enrollment of needy students as described in § 606.3(a), unless the Secretary waives this requirement under § 606.3(b); (4) It has low average educational and general expenditures per full-time equivalent undergraduate student as described in § 606.4(a), unless the Secretary waives this requirement under § 606.4(c); (5) It is legally authorized by the State in which it is located to be a junior college or to provide an educational program for which it awards a bachelor’s degree; and (6) It is accredited or preaccredited by a nationally recognized accrediting agency or association that the Secretary has determined to be a reliable authority as to the quality of education or training offered.

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(b) A branch campus of a Hispanic-Serving institution is eligible to receive a grant under this part if—

(1) The institution as a whole meets the requirements of paragraphs (a)(3) through (a)(6) of this section; and (2) The branch campus satisfies the requirements of paragraphs (a)(1) through (a)(4) of this section.

(c)(1) An institution that receives a grant under the Strengthening Institutions Program (34 CFR part 607) or the Strengthening Historically Black Colleges and Universities Program (34 CFR part 608) for a particular fiscal year is not eligible to receive a grant under this part for that same fiscal year, and may not relinquish its grant under those programs to secure a grant under this part.

(2) A Hispanic-Serving institution under this part may not concurrently receive grant funds under the Strengthening Institutions Program, Strengthening Historically Black Colleges and Universities Program, or Strengthening Historically Black Graduate Institutions Program.

(Authority: 20 U.S.C. 1101a and 1101d) [64 FR 70147, Dec. 15, 1999, as amended at 66 FR 1263, Jan. 8, 2001] § 606.3 What is an enrollment of needy students? (a) Except as provided in paragraph (b) of this section, for the purpose of § 606.2(a)(3), an applicant institution has an enrollment of needy students if in the base year—

(1) At least 50 percent of its degree students received student financial assistance under one or more of the following programs: Federal Pell Grant, Federal Supplemental Educational Opportunity Grant, Federal Work-Study, and Federal Perkins Loan; or (2) The percentage of its undergraduate degree students who were enrolled on at least a half-time basis and received Federal Pell Grants exceeded the median percentage of undergraduate degree students who were enrolled on at least a half-time basis and received Federal Pell Grants at comparable institutions that offer similar instruction.

(b) The Secretary may waive the requirement contained in paragraph (a) of this section if the institution demonstrates that—

(1) The State provides more than 30 percent of the institution’s budget and the institution charges not more than $99.00 for tuition and fees for an academic year;

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(2) At least 30 percent of the students served by the institution in the base year were students from low-income families; (3) The institution substantially increases the higher education opportunities for low-income students who are also educationally disadvantaged, underrepresented in postsecondary education, or minority students; (4) The institution substantially increases the higher education opportunities for individuals who reside in an area that is not included in a ‘‘metropolitan statistical area’’ as defined by the Office of Management and Budget and who are unserved by other postsecondary institutions; or (5) The institution will, if granted the waiver, substantially increase the higher education opportunities for Hispanic Americans.

(c) For the purpose of paragraph (b) of this section, the Secretary considers ‘‘low-income’’ to be an amount which does not exceed 150 percent of the amount equal to the poverty level as established by the United States Bureau of the Census. (d) Each year, the Secretary notifies prospective applicants of the low-income figures through a notice published in the FEDERAL REGISTER. (Authority: 20 U.S.C. 1101a and 1103a)

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Appendix D – Demographic Information, October 9, 2009

Based on federal Census projections for the Alamo Area Council of Governments, the percentage of Anglos will decrease as noted in the table below. That said, Anglo dilution is unlikely to be a future constraint on the Alamo Colleges grant writing potential under set-asides for minority-serving institutions.

Projection of % Anglo Population for Alamo Area Council of Governments Region 2005 41% 41% 40% 40% 2040 33% 30% 28% 25%

The data above is based on various migration scenarios utilized by the State Demographer. As noted on the website, the projections were completed using a cohort-component projection technique.

Source: Texas State Data Center and Office of the State Demographer. Population 2000 and Projected Population 2005-2040 by Race/Ethnicity and Migration Scenario for the Alamo Area. Retrieved from website on November 23, 2009. www.txsdc.utsa.edu

 

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Appendix E – 1998 Amendments to the Higher Education Act of 1965 P.L. 105-244

TITLE I--GENERAL PROVISIONS PART A--DEFINITIONS SEC. 101. GENERAL DEFINITION OF INSTITUTION OF HIGHER EDUCATION.

(a) INSTITUTION OF HIGHER EDUCATION- For purposes of this Act, other than title IV, the term institution of higher education' means an educational institution in any State that--

(1) admits as regular students only persons having a certificate of graduation from a school providing secondary education, or the recognized equivalent of such a certificate;

(2) is legally authorized within such State to provide a program of education beyond secondary education;

(3) provides an educational program for which the institution awards a bachelor's degree or provides not less than a 2-year program that is acceptable for full credit toward such a degree;

(4) is a public or other nonprofit institution; and

(5) is accredited by a nationally recognized accrediting agency or association, or if not so accredited, is an institution that has been granted preaccreditation status by such an agency or association that has been recognized by the Secretary for the granting of preaccreditation status, and the Secretary has determined that there is satisfactory assurance that the institution will meet the accreditation standards of such an agency or association within a reasonable time.

(b) ADDITIONAL INSTITUTIONS INCLUDED- For purposes of this Act, other than title IV, the term `institution of higher education' also includes--

(1) any school that provides not less than a 1-year program of training to prepare students for gainful employment in a recognized occupation and that meets the provision of paragraphs (1), (2), (4), and (5) of subsection (a); and

(2) a public or nonprofit private educational institution in any State that, in lieu of the requirement in subsection (a)(1), admits as regular students persons who are beyond the age of compulsory school attendance in the State in which the institution is located.

(c) LIST OF ACCREDITING AGENCIES- For purposes of this section and section 102, the Secretary shall publish a list of nationally recognized accrediting agencies or associations that the Secretary determines, pursuant to subpart 2 of part H of title IV, to be reliable authority as to the quality of the education or training offered.

Retrieved from US Dept. of Education website (ed.gov) on 11.13.09

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Appendix F – St. Philip’s College – HBCU Designation 1987  

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Appendix G – 20 U.S.C.A, Ch. 28, Subch. III, Part B §§ 1060 – 1063c

Strengthening Historically Black Colleges and Universities

§ 1060. Findings and purposes The Congress finds that--

(1) the historically Black colleges and universities have contributed significantly to the effort to attain equal opportunity through postsecondary education for Black, low-income, and educationally disadvantaged Americans;

(2) States and the Federal Government have discriminated in the allocation of land and financial resources to support Black public institutions under the Morrill Act of 1862 [7 U.S.C.A. § 301 et seq.] and its progeny, and against public and private Black colleges and universities in the award of Federal grants and contracts, and the distribution of Federal resources under this chapter and other Federal programs which benefit institutions of higher education;

(3) the current state of Black colleges and universities is partly attributable to the discriminatory action of the States and the Federal Government and this discriminatory action requires the remedy of enhancement of Black postsecondary institutions to ensure their continuation and participation in fulfilling the Federal mission of equality of educational opportunity; and

(4) financial assistance to establish or strengthen the physical plants, financial management, academic resources, and endowments of the historically Black colleges and universities are appropriate methods to enhance these institutions and facilitate a decrease in reliance on governmental financial support and to encourage reliance on endowments and private sources.

§ 1061. Definitions For the purpose of this part:

(1) The term “graduate” means an individual who has attended an institution for at least three semesters and fulfilled academic requirements for undergraduate studies in not more than 5 consecutive school years.

(2) The term “part B institution” means any historically Black college or university that was established prior to 1964, whose principal mission was, and is, the education of Black Americans, and that is accredited by a nationally recognized accrediting agency or association determined by the Secretary to be a reliable authority as to the quality of training offered or is, according to such an agency or association, making reasonable progress toward accreditation, except that any branch campus of a southern institution of higher education that prior to September 30, 1986, received a grant as an institution with special needs under section 1060 of this title and was formally recognized by the National Center for Education Statistics as a

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Historically Black College or University but was determined not to be a part B institution on or after October 17, 1986, shall, from July 18, 1988, be considered a part B institution.

(3) The term “Pell Grant recipient” means a recipient of financial aid under subpart 1 of part A of subchapter IV of this chapter.

(4) The term “professional and academic areas in which Blacks are underrepresented” shall be determined by the Secretary, in consultation with the Commissioner for Education Statistics and the Commissioner of the Bureau of Labor Statistics, on the basis of the most recent available satisfactory data, as professional and academic areas in which the percentage of Black Americans who have been educated, trained, and employed is less than the percentage of Blacks in the general population.

(5) The term “school year” means the period of 12 months beginning July 1 of any calendar year and ending June 30 of the following calendar year.

§ 1062. Grants to institutions (a) General authorization; uses of funds From amounts available under section 1068h(a)(2) of this title for any fiscal year, the Secretary shall make grants (under section 1063 of this title) to institutions which have applications approved by the Secretary (under section 1063a of this title) for any of the following uses:

(1) Purchase, rental, or lease of scientific or laboratory equipment for educational purposes, including instructional and research purposes.

(2) Construction, maintenance, renovation, and improvement in classroom, library, laboratory, and other instructional facilities, including purchase or rental of telecommunications technology equipment or services.

(3) Support of faculty exchanges, and faculty development and faculty fellowships to assist in attaining advanced degrees in their field of instruction.

(4) Academic instruction in disciplines in which Black Americans are underrepresented.

(5) Purchase of library books, periodicals, microfilm, and other educational materials, including telecommunications program materials.

(6) Tutoring, counseling, and student service programs designed to improve academic success.

(7) Funds and administrative management, and acquisition of equipment for use in strengthening funds management.

(8) Joint use of facilities, such as laboratories and libraries.

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(9) Establishing or improving a development office to strengthen or improve contributions from alumni and the private sector.

(10) Establishing or enhancing a program of teacher education designed to qualify students to teach in a public elementary or secondary school in the State that shall include, as part of such program, preparation for teacher certification.

(11) Establishing community outreach programs which will encourage elementary and secondary students to develop the academic skills and the interest to pursue postsecondary education.

(12) Acquisition of real property in connection with the construction, renovation, or addition to or improvement of campus facilities.

(13) Education or financial information designed to improve the financial literacy and economic literacy of students or the students' families, especially with regard to student indebtedness and student assistance programs under subchapter IV of this chapter and part C of subchapter I of chapter 34 of Title 42.

(14) Services necessary for the implementation of projects or activities that are described in the grant application and that are approved, in advance, by the Secretary, except that not more than two percent of the grant amount may be used for this purpose.

(15) Other activities proposed in the application submitted pursuant to section 1063a of this title that--

(A) contribute to carrying out the purposes of this part; and

(B) are approved by the Secretary as part of the review and acceptance of such application.

(b) Endowment fund

(1) In general

An institution may use not more than 20 percent of the grant funds provided under this part to establish or increase an endowment fund at the institution.

(2) Matching requirement

In order to be eligible to use grant funds in accordance with paragraph (1), the eligible institution shall provide matching funds from non-Federal sources, in an amount equal to or greater than the Federal funds used in accordance with paragraph (1), for the establishment or increase of the endowment fund.

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(3) Comparability

The provisions of part C of this subchapter regarding the establishment or increase of an endowment fund, that the Secretary determines are not inconsistent with this subsection, shall apply to funds used under paragraph (1).

(c) Limitations (1) No grant may be made under this chapter for any educational program, activity, or service related to sectarian instruction or religious worship, or provided by a school or department of divinity. For the purpose of this subsection, the term “school or department of divinity” means an institution whose program is specifically for the education of students to prepare them to become ministers of religion or to enter upon some other religious vocation, or to prepare them to teach theological subjects. (2) Not more than 50 percent of the allotment of any institution may be available for the purpose of constructing or maintaining a classroom, library, laboratory, or other instructional facility. § 1063. Allotments to institutions (a) Allotment; Pell Grant basis From the amounts appropriated to carry out this part for any fiscal year, the Secretary shall allot to each part B institution a sum which bears the same ratio to one-half that amount as the number of Pell Grant recipients in attendance at such institution at the end of the school year preceding the beginning of that fiscal year bears to the total number of Pell Grant recipients at all part B institutions. (b) Allotment; graduates basis From the amounts appropriated to carry out this part for any fiscal year, the Secretary shall allot to each part B institution a sum which bears the same ratio to one-fourth that amount as the number of graduates for such school year at such institution bears to the total number of graduates for such school year at all part B institutions. (c) Allotment; graduate and professional student basis From the amounts appropriated to carry out this part for any fiscal year, the Secretary shall allot to each part B institution a sum which bears the same ratio to one-fourth of that amount as the percentage of graduates per institution, who are admitted to and in attendance at, within 5 years of graduation with a baccalaureate degree, a graduate or professional school in a degree program in disciplines in which Blacks are underrepresented, bears to the percentage of such graduates per institution for all part B institutions.

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(d) Minimum allotment (1) Notwithstanding subsections (a) through (c), and subject to subsection (h), if the amount of an award under this section for a part B institution, based on the data provided by the part B institution and the formula under subsections (a) through (c), would be--

(A) an amount that is greater than $250,000 but less than $500,000, the Secretary shall award the part B institution an allotment in the amount of $500,000; and

(B) an amount that is equal to or less than $250,000, the Secretary shall award the part B institution an allotment in the amount of $250,000.

(2) If the amount appropriated pursuant to section 1068h(a)(2)(A) of this title for any fiscal year is not sufficient to pay the minimum allotment required by paragraph (1) to all part B institutions, the amount of such minimum allotments shall be ratably reduced. If additional sums become available for such fiscal year, such reduced allocations shall be increased on the same basis as the basis on which they were reduced (until the amount allotted equals the minimum allotment required by paragraph (1)). (e) Reallotment The amount of any part B institution's allotment under subsection (a), (b), (c), or (d) of this section for any fiscal year which the Secretary determines will not be required for such institution for the period such allotment is available shall be available for reallotment from time to time on such date during such period as the Secretary may determine to other part B institutions in proportion to the original allotment to such other institutions under this section for such fiscal year. (f) Special merger rule (1) The Secretary shall permit any eligible institution for a grant under part B in any fiscal year prior to the fiscal year 1986 to apply for a grant under this part if the eligible institution has merged with another institution of higher education which is not so eligible or has merged with an eligible institution. (2) The Secretary may establish such regulations as may be necessary to carry out the requirement of paragraph (1) of this subsection. (g) Special rule for certain District of Columbia eligible institutions In any fiscal year that the Secretary determines that Howard University or the University of the District of Columbia will receive an allotment under subsections (b) and (c) of this section which is not in excess of amounts received by Howard University under section 123 of this title, relating to annual authorization of appropriations for Howard University, or by the University of the District of Columbia under the District of Columbia Home Rule Act (87 Stat. 774) for such

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fiscal year, then Howard University and the University of the District of Columbia, as the case may be, shall be ineligible to receive an allotment under this section. (h) Conditions for allotments

(1) Student requirements for allotment

Notwithstanding any other provision of this section, a part B institution that would otherwise be eligible for funds under this part shall not receive an allotment under this part for a fiscal year, including the minimum allotment under subsection (d), if the part B institution, in the academic year preceding such fiscal year--

(A) did not have any enrolled students who were Pell Grant recipients;

(B) did not graduate any students; or

(C) where appropriate, did not have any students who, within 5 years of graduation from the part B institution, were admitted to and in attendance at a graduate or professional school in a degree program in disciplines in which Blacks are underrepresented.

(2) Data requirements for allotments

Notwithstanding any other provision of this section, a part B institution shall not receive an allotment under this part for a fiscal year, including the minimum allotment under subsection (d), unless the institution provides the Secretary with the data required by the Secretary and for purposes of the formula described in subsections (a) through (c), including--

(A) the number of Pell Grant recipients enrolled in the part B institution in the academic year preceding such fiscal year;

(B) the number of students who earned an associate or baccalaureate degree from the part B institution in the academic year preceding such fiscal year; and

(C) where appropriate, the percentage of students who, within 5 years of graduation from the part B institution, were admitted to and in attendance at a graduate or professional school in a degree program in disciplines in which Blacks are underrepresented in the academic year preceding such fiscal year.

§ 1063a. Applications (a) Contents No part B institution shall be entitled to its allotment of Federal funds for any grant under section 1063 of this title for any period unless that institution meets the requirements of subparagraphs (C), (D), and (E) of section 1058(b)(1) of this title and submits an application to the Secretary at

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such time, in such manner, and containing or accompanied by such information, as the Secretary may reasonably require. Each such application shall--

(1) provide that the payments under this chapter will be used for the purposes set forth in section 1062 of this title; and

(2) provide for making an annual report to the Secretary and provide for--

(A) conducting, except as provided in subparagraph (B), a financial and compliance audit of an eligible institution, with regard to any funds obtained by it under this subchapter at least once every 2 years and covering the period since the most recent audit, conducted by a qualified, independent organization or person in accordance with standards established by the Comptroller General for the audit of governmental organizations, programs, and functions, and as prescribed in regulations of the Secretary, the results of which shall be submitted to the Secretary; or

(B) with regard to an eligible institution which is audited under chapter 75 of Title 31 deeming such audit to satisfy the requirements of subparagraph (A) for the period covered by such audit.

(b) Approval The Secretary shall approve any application which meets the requirements of subsection (a) of this section and shall not disapprove any application submitted under this part, or any modification thereof, without first affording such institution reasonable notice and opportunity for a hearing. (c) Goals for financial management and academic programs Any application for a grant under this part shall describe measurable goals for the institution's financial management and academic programs and include a plan of how the applicant intends to achieve those goals. § 1063b. Professional or graduate institutions (a) General authorization (1) Subject to the availability of funds appropriated to carry out this section, the Secretary shall award program grants to each of the postgraduate institutions listed in subsection (e) of this section that is determined by the Secretary to be making a substantial contribution to the legal, medical, dental, veterinary, or other graduate education opportunities in mathematics, engineering, or the physical or natural sciences for Black Americans. (2) No grant in excess of $1,000,000 may be made under this section unless the postgraduate institution provides assurances that 50 percent of the cost of the purposes for which the grant is made will be paid from non-Federal sources, except that no institution shall be required to match

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any portion of the first $1,000,000 of the institution's award from the Secretary. After funds are made available to each eligible institution under the funding rules described in subsection (f) of this section, the Secretary shall distribute, on a pro rata basis, any amounts which were not so made available (by reason of the failure of an institution to comply with the matching requirements of this paragraph) among the institutions that have complied with such matching requirement. (b) Duration Grants shall be made for a period not to exceed 5 years. Any funds awarded for such five-year grant period that are obligated during such five-year period may be expended during the 10-year period beginning on the first day of such five-year period. (c) Uses of funds A grant under this section may be used for--

(1) purchase, rental or lease of scientific or laboratory equipment for educational purposes, including instructional and research purposes;

(2) construction, maintenance, renovation, and improvement in classroom, library, laboratory, and other instructional facilities, including purchase or rental of telecommunications technology equipment or services;

(3) purchase of library books, periodicals, technical and other scientific journals, microfilm, microfiche, and other educational materials, including telecommunications program materials;

(4) scholarships, fellowships, and other financial assistance for needy graduate and professional students to permit the enrollment of the students in and completion of the doctoral degree in medicine, dentistry, pharmacy, veterinary medicine, law, and the doctorate degree in the physical or natural sciences, engineering, mathematics, or other scientific disciplines in which African Americans are underrepresented;

(5) establishing or improving a development office to strengthen and increase contributions from alumni and the private sector;

(6) assisting in the establishment or maintenance of an institutional endowment to facilitate financial independence pursuant to section 1065 of this title;

(7) funds and administrative management, and the acquisition of equipment, including software, for use in strengthening funds management and management information systems;

(8) acquisition of real property that is adjacent to the campus in connection with the construction, renovation, or addition to or improvement of campus facilities;

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(9) education or financial information designed to improve the financial literacy and economic literacy of students or the students' families, especially with regard to student indebtedness and student assistance programs under subchapter IV of this chapter and part C of subchapter I of chapter 34 of Title 42;

(10) services necessary for the implementation of projects or activities that are described in the grant application and that are approved, in advance, by the Secretary, except that not more than two percent of the grant amount may be used for this purpose;

(11) tutoring, counseling, and student service programs designed to improve academic success; and

(12) other activities proposed in the application submitted under subsection (d) that--

(A) contribute to carrying out the purposes of this part; and

(B) are approved by the Secretary as part of the review and acceptance of such application.

(d) Application Any institution eligible for a grant under this section shall submit an application which--

(1) demonstrates how the grant funds will be used to improve graduate educational opportunities for Black and low-income students, and lead to greater financial independence; and

(2) provides, in the case of applications for grants in excess of $1,000,000, the assurances required by subsection (a)(2) of this section and specifies the manner in which the eligible institution is going to pay the non-Federal share of the cost of the application.

(e) Eligibility

(1) In general

Independent professional or graduate institutions and programs eligible for grants under subsection (a) of this section are the following:

(A) Morehouse School of Medicine;

(B) Meharry Medical School;

(C) Charles R. Drew Postgraduate Medical School;

(D) Clark-Atlanta University;

59  

(E) Tuskegee University School of Veterinary Medicine and other qualified graduate programs;

(F) Xavier University School of Pharmacy and other qualified graduate programs;

(G) Southern University School of Law and other qualified graduate programs;

(H) Texas Southern University School of Law and School of Pharmacy and other qualified graduate programs;

(I) Florida A & M University School of Pharmaceutical Sciences and other qualified graduate programs;

(J) North Carolina Central University School of Law and other qualified graduate programs;

(K) Morgan State University qualified graduate program;

(L) Hampton University qualified graduate program;

(M) Alabama A & M qualified graduate program;

(N) North Carolina A & T State University qualified graduate program;

(O) University of Maryland Eastern Shore qualified graduate program;

(P) Jackson State University qualified graduate program;

(Q) Norfolk State University qualified graduate programs;

(R) Tennessee State University qualified graduate programs;

(S) Alabama State University qualified graduate programs;

(T) Prairie View A&M University qualified graduate programs;

(U) Delaware State University qualified graduate programs;

(V) Langston University qualified graduate programs;

(W) Bowie State University qualified graduate programs; and

(X) University of the District of Columbia David A. Clarke School of Law.

(2) Qualified graduate program

60  

(A) For the purposes of this section, the term “qualified graduate program” means a graduate or professional program that provides a program of instruction in law or in the physical or natural sciences, engineering, mathematics, psychometrics or other scientific discipline in which African Americans are underrepresented and has students enrolled in such program at the time of application for a grant under this section.

(B) Notwithstanding the enrollment requirement contained in subparagraph (A), an institution may use an amount equal to not more than 10 percent of the institution's grant under this section for the development of a new qualified graduate program.

(3) Special rule

Institutions that were awarded grants under this section prior to October 1, 2008, shall continue to receive such grants, subject to the availability of appropriated funds, regardless of the eligibility of the institutions described in subparagraphs (S) through (X) of paragraph (1).

(4) One grant per institution

The Secretary shall not award more than 1 grant under this section in any fiscal year to any institution of higher education.

(5) Institutional choice

The president or chancellor of the institution may decide which graduate or professional school or qualified graduate program will receive funds under the grant in any 1 fiscal year, if the allocation of funds among the schools or programs is delineated in the application for funds submitted to the Secretary under this section.

(f) Funding rule Subject to subsection (g) of this section, of the amount appropriated to carry out this section for any fiscal year--

(1) the first $56,900,000 (or any lesser amount appropriated) shall be available only for the purposes of making grants to institutions or programs described in subparagraphs (A) through (R) of subsection (e)(1) of this section;

(2) any amount in excess of $56,900,000, but not in excess of $62,900,000, shall be available for the purpose of making grants to institutions or programs described in subparagraphs (S) through (X) of subsection (e)(1) of this section; and

(3) any amount in excess of $62,900,000, shall be made available to each of the institutions or programs identified in subparagraphs (A) through (X) pursuant to a formula developed by the Secretary that uses the following elements:

(A) The ability of the institution to match Federal funds with non-Federal funds.

61  

(B) The number of students enrolled in the programs for which the eligible institution received funding under this section in the previous year.

(C) The average cost of education per student, for all full-time graduate or professional students (or the equivalent) enrolled in the eligible professional or graduate school, or for doctoral students enrolled in the qualified graduate programs.

(D) The number of students in the previous year who received their first professional or doctoral degree from the programs for which the eligible institution received funding under this section in the previous year.

(E) The contribution, on a percent basis, of the programs for which the institution is eligible to receive funds under this section to the total number of African Americans receiving graduate or professional degrees in the professions or disciplines related to the programs for the previous year.

(g) Hold harmless rule Notwithstanding paragraphs (2) and (3) of subsection (f) of this section, no institution or qualified program identified in subsection (e)(1) of this section that received a grant for fiscal year 2008 and that is eligible to receive a grant in a subsequent fiscal year shall receive a grant amount in any such subsequent fiscal year that is less than the grant amount received for fiscal year 2008, unless the amount appropriated is not sufficient to provide such grant amounts to all such institutions and programs, or the institution cannot provide sufficient matching funds to meet the requirements of this section. (h) Interaction with other grant programs No institution that is eligible for and receives an award under section 1102a, 1136a, or 1136b of this title for a fiscal year shall be eligible to apply for a grant, or receive grant funds, under this section for the same fiscal year. § 1063c. Reporting and audit requirements (a) Recordkeeping Each recipient of a grant under this part shall keep such records as the Secretary shall prescribe, including records which fully disclose--

(1) the amount and disposition by such recipient of the proceeds of such assistance;

(2) the cost of the project or undertaking in connection with which such assistance is given or used;

62  

(3) the amount of that portion of the cost of the project or undertaking supplied by other sources; and

(4) such other records as will facilitate an effective audit.

(b) Use of unexpended funds Any funds paid to an institution and not expended or used for the purposes for which the funds were paid during the five-year period following the date of the initial grant award, may be carried over and expended during the succeeding five-year period, if such funds were obligated for a purpose for which the funds were paid during the five-year period following the date of the initial grant award.

63  

Appendix H – Alamo Colleges – Grant Information Note: list is not all-inclusive (only includes larger grants and/or grants associated with HBCU or HSI designations)

Grant Program (Agency, Program)

Eligible to Apply Funded

NLC NVC PAC SAC SPC NLC NVC PAC SAC SPC US Dept. of Education: Title V or Title III, Part A (Title V: total 5 yrs; Title III: total 5 yrs)

√ √ √ √ $264,742

√ $246,298

√ $237,798

DOE Title III Part B –HBCU (Year 2 of 5 –year award) ($5.7 - $6.0M per year)

√ √ $5,746,256

DOE College Cost Reduction Access Act – HSI

√ $1,231,492

√ $1,188,989

DOE College Cost Reduction Access Act -HBCU (Year 2 of 2)

√ $1,655,250

GEAR UP ($7,200,000 total 6 yrs)

√ √ √ √

Minority Science and Engineering Improvement Program($600,000 - $900,000 total 3 yrs)

√ √ √ √ √ $180,011

√ $86,495

Fund for the Improvement of Postsecondary Education-Comprehensive Program ($600,000 total 4 yrs)

√ √ √ √

Fulbright-Hays—Group Projects Abroad Program ($90,000 total 1 yr)

√ √ √ √

Undergraduate International Studies and Foreign Language ($180,000 total 2 yrs)

√ √ √ √

Migrant Education—College Assistance Migrant Program ($2,125,000 total 5 yrs)

√ √ √ √ √

Migrant Education—High School Equivalency Program ($2,375,000 total 5 yrs)

√ √ √ √ √

Women’s Educational Equity ($1,000,000 total 4 yrs)

√ √ √ √ √ $203,023

64  

Grant Program (Agency, Program)

Eligible to Apply Funded

NLC NVC PAC SAC SPC NLC NVC PAC SAC SPC Transition to Teaching ($3,750,000 total 5 years)

√ √ √ √ √ 27,000

TRIO Student Support Services ($1,000,000 – $1,100,000 total 5 yrs for new projects)

√ √ √ √ √ $292,905

√ $400,000

TRIO Upward Bound Regular ($1,250,000 total 5 yrs for new projects)

√ √ √ √ √ $250,000

TRIO Upward Bound Math & Science ($1,250,000 total 5 yrs for new projects)

√ √ √ √

TRIO Upward Bound Veterans ($1,250,000 total 5 yrs for new projects)

√ √ √ √

TRIO Education Opportunity Center ($1,100,000 total 5 yrs for new projects)

√ √ √ √

TRIO Talent Search ($1,100,000 total 5 yrs for new projects)

√ √ √ √

Prevention of High-Risk Drinking or Violent Behavior Among College Students ($300,000 total 2 yrs)

√ √ √ √

Dept of Ed CCAMPIS Child Development Center – Child Care Support

√ √ √ √ √ $179,668

√ $138,460

US Dept. of Housing & Urban Dev: Hispanic Serving Institutions Serving Communities ($600,000 total 3 yrs)

√ √ √ √ $246,013

HBCU Assisting Communities ($800,000 total 3 yrs)

√

National Science Foundation: Presidential Scholars

√ √ √ √ √ $137,986

√ $87,275

NSF HBCU UP GenX – to increase the number of minority STEM graduates (year 1 of 2)

√

$198,322

65  

Grant Program (Agency, Program)

Eligible to Apply Funded

NLC NVC PAC SAC SPC NLC NVC PAC SAC SPC

Advanced Technological Education ($900,000 total 3 yrs)

√ √ √ √

Course, Curriculum, and Laboratory Improvement ($600,000 - $1,000,000 total 3 yrs)

√ √ √ √

HBCU Program ($1,750,000 – 3,000,000 total 5 yrs)

√

STEM Talent Expansion Program ($1,000,000 – $2,000,000 total 5 yrs)

√ √ √ √

Nanotechnology Undergraduate Education in Engineering ($400,000 total 2 yrs)

√

National Endowments for the Arts: American Masterpieces – Dance ($15,000 total 1 yr)

√ √ √ √ √

$15,000

Access to Artistic Excellence ($100,000 total 1 year)

√ √ √ √

Challenge America: Fast-Track Review Grants ($10,000 total 1 yr)

√ √ √ √

The Big Read √ √ √ √ √ √ √ $10,000

Corporation for National and Community Services: Learn & Serve ($585,000 – $1,500,000 total 3 years)

√ √ √ √ √

$83,310

U.S. Department of Justice

√ √ √ √

Greater Texas Foundation

√ √ √ √ √ $100,000

√ $50,000

√ $100,000

√ $100,000

U.S. Dept. of Health & Human Services

√ √ √

$290,000 √

$144,858U.S. Department of Agriculture

√ √ √ √

$80,000

66  

Grant Program (Agency, Program)

Eligible to Apply Funded

NLC NVC PAC SAC SPC NLC NVC PAC SAC SPC U.S. Department of Agriculture – HSI Education Grants Program – Proyecto Alimento

√

$299,984

U.S. Department of Labor

√ √ √ √

U.S. Department of Homeland Security

√ √ √ √

Texas Guaranteed Student Loan Corporation (Various Programs)

√ √ √ √ √ √

$221,302

Texas Higher Education Coordinating Board (Various Programs)

√ √ √ √ √

$573,994 √

$656,706 √

$130,000

Gates Foundation/Early College High School

√ √ √ √ √ $120,000

√ $120,000

Texas Workforce Commission

√ √ √ √ √ $15,225

√ $6,013

City of San Antonio √ √ √ √ √ √ $15,000

√ $200,000

 

 

67  

Appendix I - Current Structure of Alamo Colleges as of September 9. 2009

 

68  

Appendix J - Proposed Structure of Alamo Colleges as of September 9. 2009

 

69  

Appendix K – Comparative Community College Systems Community College

System Accreditation Status Title V grant application submission

Maricopa CC Individually Accredited Colleges

Multiple Title V submissions (possible grant application submission of one per branch campus per competition)

El Paso CC One Accreditation (system accreditation)

One Title V submission (either for entire system or for only one campus per competition)

Pima CC * [spoke w/Lorraine Dischinger, Grant Dir. in summer; put in call to President’s office for clarification: USDOE listing campus as individually accredited (1971, 1974, 1981, 1993, 1997, 2003), and district as accredited (1975)]

One Accreditation (system accreditation)

Multiple Title V submissions (possible grant application submission of one per branch campus per competition)

Houston CC One Accreditation (system accreditation)

One Title V or Title III submission (either for entire system or for only one campus per competition)

Lone Star CC (accreditation currently under North Harris Montgomery CC District)

One Accreditation (system accreditation)

Only one eligible HSI campus; however, apply only either as system or one branch campus to other federal grant opportunities

Miami Dade CC One Accreditation Multiple Title V submissions (possible grant application submission of one per branch campus per competition)

USDOE accreditation search: http://ope.ed.gov/accreditation/Search.aspx 

   

 

70

 

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,944

 

71  

Appendix M – CR 2.11 Financial Core Requirement Core Requirement 2.11.1 provides the accreditation requirements regarding financial stability and resources. Committee’s note: Alamo Colleges provided written response in blue as part of Northeast Lakeview College’s (NLC) candidacy application in June 2009; and obtained SACS July 1, 2009 reply as to documentation required listed in red (from Ann Chard and Donna Barrett). Core Requirement 2.11.1: The institution has a sound financial base and demonstrated financial stability to support the mission of the institution and the scope of its programs and services. Each College of the district is responsible for sound fiscal management of programs and operations within an allocated expenditure budget to support its mission. The District provides additional financial stability and support of the College’s mission, through property tax revenues and state appropriations, allocated in a fair and equitable manner. The District also provides administrative services to the College for human resources, accounting, finance, facilities, procurement, legal and insurance/risk management. Minimum Documentation Required: 1. Audits and management letters for the three most recent years, including that for the fiscal

year ending immediately prior to the date of the submission of the application. If the institution is a part of a system, the most recent of the three audits must be a separate audit for the institution itself. Reportable financial entity under GASB Statement 14 is the Alamo Community College

District (“District”). Annual financial and compliance audit and opinion is for the District.

A Separate audit for NLC’s revenues and expenditures was performed and

submitted for the fiscal years 2008 and 2007; however, due to the District’s governance and legal structure, stand-alone separate full-set of financial statements in accordance with accounting principles generally accepted (GAAP) in the United States cannot be prepared without incurring expense to create college-level separate accounting records on a going-forward basis collecting detailed transactions at college level (“separate set of books”) and will involve allocations of District cash and liabilities to the colleges.

Submitted an independent auditor’s report/opinion given on a Schedule of Certain

Revenues and Expenses for the years ended August 31, 2008 for only Northeast Lakeview College

 

72  

SACS response: The most recent of the three audits must be a separate audit for the institution itself. Independent audit report meeting Generally Accepted Accounting Principles must include: Unqualified Audit Opinion on fairness of NLC financial statements GAAP NLC financial statements (comparative data would not be required for submission of

the application; however by the time the application progresses to the accreditation committee visit, 2-year comparative financials may be required) including statements of assets and liabilities, revenues and expenditures, cash flows, all GAAP required financial statement footnotes, and Management, Discussion and Analysis.

Separate NLC management letter on auditor’s tests of controls for NLC.

Additional Alamo Colleges response – June 2009: In order to obtain a clean GAAP External Audit opinion on stand-alone NLC Financial Statements, the Auditor requires Alamo Colleges MUST have established separate college full set of trial balance accounts (separate set of books for each college that supports District Totals used in District Financial Statements). Until the new Banner Student module finishes implementation 8/31/2010 & Payroll module as well as new chart of accounts comes up and captures a year worth of detailed data at the college level, any audit opinion will be qualified which will not meet the SACS requirement of a GAAP audited financial statement (Audit opinion, full F/S with footnotes and MD&A, Mgmt Letter on internal controls). Thus, earliest that Alamo Colleges will have 1 year NLC financial statements for candidacy application will be for fiscal year ending 8/31/11 with audit completed by Feb. 2012.

2. Information requested in Part A (sources and percentages of revenues during the past three

years and operating expenses during the past three years, including expenditures in auxiliary enterprises and other operations). NLC provided in the application. SACS response: agreed; however will need to be updated when separate audited NLC financial statements are available (see #1 above).

3. Assets and liabilities of the institution during the past three years.

NLC can provide certain asset information for its location. Capital assets by Location are included in the District’s audited Annual Financial Report. Debt issuances are specific to projects at locations throughout the District, however, the debt is issued in the name of the District and not by each college location. SACS response: see #1 above.

 

73  

4. A schedule of fund balances for the past three years. Each College is part of a system, which exists for and on behalf of the colleges within the District. A schedule of fund balances can be provided for the District. SACS response: see #1 above.

5. If a proprietary institution, statements describing the amount of net worth or equity and the

amount of net income for the past three years. Not applicable. SACS response: agree

6. Narrative establishing the financial health and stability of the institution with reference to its

ability to provide adequate faculty, learning resources, student support, and physical facilities for the programs and services it offers. Each College is not a separate legal, reporting entity nor does each College have a separate governing Board of Trustees. The District is the legal and financial reporting entity. Each College is given an annual budget to manage on behalf of its programs and operations for its location. This requirement is to determine if the College has a sound financial base and demonstrated financial stability. The College’s strength in these two areas is enhanced by the District’s support of the College’s mission. SACS response: the Narrative will need to be updated to include the NLC specific financial information from the separate audited financial statements in #1 above; with limited reference to District.

Additional information regarding member institutions’ reaccreditation (Palo Alto College, San Antonio College, St. Philips College and Northwest Vista College): SACS response: A member institution does not have to have a separate audit with the opinion resting on the individual institution, IF they have a system or district audit with supplemental schedules for the individual institution. So a system audit with supplemental schedules is okay for members at reaffirmation. Audit requirements are more stringent for non-members than for members: when a public institution applies for membership it must have audits opinioned at the institution level. Confirmed July 1, 2009 by Ann Chard/Donna Barrett, SACS  

 

74  

Appendix N – Review Committee’s Questions for Peer Institutions – Telephone Interviews Selected four community college districts for interviews:

1. Individual Accreditation District:

a. Dallas District. Interview on 9/24/09

i. Kim Green, District CFO

b. Richland College. Interview on 9/24/09 - (Baldrige award winner) regarding

curriculum and reaffirmation.

i. Janet James, SACs liaison & Dean 2. Single Accreditation Districts:

a. Houston (despite numerous attempts to schedule; unable to meet) b. El Paso. Interview on 9/24/09

i. Dr. Ernst E. Roberts II – Executive Assistant to the President

(representing the District)

ii. Mary Beth Haan, Faculty (responsible for researching, writing, organizing, compiling, etc., the SACS accreditation process at EPCC.)

iii. Saul Candelas, VP for Research & Development and our official liaison

with SACS

iv. Ron Stroud, Director for Institutional Effectiveness c. Lone Star (despite numerous attempts to schedule; unable to meet)

Questions for Dallas – Multi Accredited

o Dallas District Conference call with District CFO (Kim Green):

1. What was the date of DCCCD’s last college candidacy application (any after

2005)? Any plans for a new college application? Any plans to transition to single-accreditation at District level? Attached is a memo documenting current SACS requirements for applications for new members for context as to our question.

2. What financial information does Dallas submit for reaffirmation of its’ accredited colleges? Please describe the level of transactional information

 

75  

maintained at a college level in the District’s accounting records (assets, liabilities, revenues and expenses).

o Richland College Conference call with SACs liaison & Dean – Curriculum &

Reaffirmation (Janet James) 1. As we serve a relatively compact geographic service area and because

students may desire to attend a college outside of their neighborhood or attend more than one of our colleges, what in your view are the implications to student access and success of separately accredited or singularly accredited colleges?

2. Would any of the “unique cultures” of your colleges be adversely affected in your view by becoming a singularly accredited district? How do you address the need to celebrate and reinforce the unique cultures of each of the colleges?

3. Does Dallas hire outside consultants to help with reaffirmations?

4. Does Dallas hire outside consultants to help with a major substantive change such as adding a new college to the system?

5. Does Dallas reassign one or more internal employees on a full-time basis to work on reaffirmations?

6. Does Dallas reassign one or more internal employees on a full-time basis to work on a major substantive change such as adding a new college to the system?

7. What are the personnel requirements in terms of consultants or internal full-timers assigned to work on reaffirmations or new college accreditations? How many man-hours/months/years are necessary?

8. In your opinion, did Dallas’s multiple-accreditation status have any impact one way or another on Richland College winning the Baldrige Award? Could Richland have accomplished that in a single-accreditation district? Or did it have more freedom to operate and innovate due to its single accreditation?

Questions for Single Accreditation districts – El Paso

1. Questions regarding administrative structure (i.e. Colleges v. campuses, v.

district roles and processes).

2. Are curriculums identical across the district?

3. Are program objectives identical across the district?

 

76  

4. Are QEP and other self-study instruments identical across the district?

5. Do you have mirrored programs across campuses that need to coordinate curricular elements?

6. Alamo Colleges is investigating the pros and cons of switching over from a multiple-accreditation district to a single accreditation district; and would appreciate comments from those who currently operate as single accreditation district on the following transitional considerations: a. Would curriculums need to be identical across the district? b. Would program requirements, program outcome objectives, and self-study

instruments need to be identical across the District? c. Would intra-District student transfers need to be altered? d. Would student record-keeping need to be altered? e. What other realignments would be necessary? f. Comparing the single v. multiple accreditations models, which provides

the most protection to students when a sub-unit becomes dysfunctional? For example, in a multiple accreditation district, if one college is put on probation, it would not impact students at other colleges. Would this also be true of the single district accreditation model, or would all students in the district suffer the consequences of probation or suspension should one college or department become dysfunctional?

7. As we serve a relatively compact geographic service area and because

students may desire to attend a college outside of their neighborhood or attend more than one of our colleges, what in your view are the implications to student access and success of separately accredited or singularly accredited colleges?

8. How do you address the need to celebrate and reinforce the unique cultures of each of the colleges?

 

 

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GLOSSARY OF TERMS “Branch Campuses” (Department of Education) – With respect to institutions of higher education under Title V of the Higher Education Act, branch campuses refer to separate campuses that fall within an accredited institution. College – For purposes of this report, the term College refers to an accredited institution (versus the term branch campus as used by the Department of Education). Consolidated – Services, functions or programs which are combined to form one central service, function or program are referred to in this document as consolidated. Employee Services / Human Resources – The organizational unit of the Alamo Colleges that provides support and oversight for all hiring, evaluation and other employee systems is referred to as Human Resources or Employee Services. Individual Accreditation – The term individual accreditation is used in this report to refer to the current Alamo Colleges structure in which each college (NVC, PAC, SAC and SPC) is separately accredited and under which NLC has applied for accreditation. “Institution” (Department of Education) – Institutional Research (IR) – The organizational unit that supports research for the Alamo Colleges is called Institutional Research. Merged – Two or more entities, programs or functions are referred to as merged if they are brought together to form one entity, program or function (i.e. two colleges that combine to form one institution). Model – The term model is used in this report to refer to the structure under which the ACCD operates (i.e. the current structure with individually accredited colleges or the potential model with single Alamo Colleges accreditation). Program Accreditations – In addition to SACS accreditation for the institution, some programs have the opportunity to apply for accreditation from associated organizations (i.e. Pharmacy Technology program accreditation from the ASHP). Program Outcomes – The defined/desired student outcomes or competencies for a program of study (i.e. degree or certificate program) are referred to as program outcomes. QEP – The Quality Enhancement Plan required by SACS for reaccreditation of any accredited institution of higher education SACS – SACS is the Southern Association of Colleges and Schools under which NVC, PAC, SAC and SPC are accredited.

 

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School Based Management – School Based (or Site Based) Management in public education refers to management at the individual school or site versus management by the central administration of a school district. Single Accreditation - The term single accreditation is used in this report to refer to one accreditation for the entire Alamo Colleges (ACCD) as opposed to the individual accreditation under which each of the Alamo Colleges currently operate as separately accredited institutions. Student Learning Outcomes – The defined/identified outcomes or competencies for a course group of courses (i.e. English 1301 or the Core Curriculum or a specific program of study) are referred to as student learning outcomes.