ACICS
In her February 26, 2016, article in The Chronicle of Higher Education, Annie Waldman points out the folly of executives at one for-profit education company regulating other for-profit education companies. She underscores this folly by emphasizing that ACICS allowed Corinthian Colleges, Inc., to continue to operate until the company was forced to shut down by the government, and further, that ACICS named Corinthian to its ‘honor roll’ only months before the shut-down.
Waldman’s analysis of the ACICS commissioners is one important aspect of the “cesspool of corruption” as Robert M. Shireman has described the for-profit industry. Another aspect is the ground-level ACICS evaluators who visit for-profit institutions to determine whether to grant or renew accreditation. While studying the for-profit industry, I signed on as an evaluator for ACICS and I went on approximately ten site visits to various institutions. The view from the ground level is just as disturbing as it is from the top commissioner level.
The preparation for an accreditation grant from ACICS is facially similar to the regional accreditation process. The institution must first demonstrate eligibility for accreditation. The institution registers with ACICS and submits preliminary information about its campuses, programs, owners, administrators, and so-on. After reviewing the information, ACICS extends an invitation to the institution to apply for membership, and the institution is given the opportunity to purchase an application. Eventually a site visit is scheduled. The accreditation renewal process is more streamlined, since ACICS already has the basic information, but this process too involves a site visit.
While Waldman quotes ACICS’s director Albert C. Gray’s statement that ACICS has a conflict of interest policy, that statement is deceptive in the context of the site visit process. It is true that the site visit committee must be made up of evaluators who are either not connected with the institution, or who were formerly connected with that institution but severed that connection several years previously. Some evaluators are retired or have no connection to any institution, but the majority of the evaluators with whom I worked did work for competing institutions. There was a clear and pervasive understanding among the latter evaluators that if they made trouble for the institution, there would be payback when the evaluators’ institutions were up for ACICS accreditation renewal in the future. While this may not be considered a conflict of interest, it certainly had a chilling impact on objectivity.
ACICS evaluators are paid a small honorarium to go on site visits, and all their travel expenses are paid. Nobody is going to get rich as an ACICS evaluator, but they do tend to spend money lavishly on meals and alcohol. My sense was that quite a few evaluators were in the role solely for the fringe benefits (frequent flyer miles, hotel points, free food and drinks, etc.).
Although verifying eligibility for ACICS accreditation may have been a secondary reason for going on a site visit, I must say that the evaluators with whom I worked were diligent and conscientious in their processes at the institutions, but those processes themselves, which are established by ACICS, are fatally flawed.
The primary purpose of the site visit is to verify the information the institution submitted to ACICS. More specifically, the information must be verified as of the day of the visit. Not the day before. Not the day after. Here is an example of why that is important. At one institution in Ohio, I reviewed the published catalog and noticed a faculty member listed who had a Ph.D. from a diploma mill (and by that I mean the completely fraudulent business that sends you a diploma in the mail after you pay a fee, with no pretense of any classes or other work at all). Just as I was preparing to inquire about that bogus Ph.D., the institution’s director trotted into the room with an “Addendum” to the published catalog. The two-page document, which looked and felt as if it had just come off the printer, did not include that faculty member with the questionable credential. Did she teach classes at the institution the day before the visit? Perhaps. Did she teach classes at the institution the day after the visit? Perhaps. ACICS didn’t care about the day before or the day after. The only thing that mattered was that we had a piece of paper that did not list that faculty member, so no red flag from the ACICS perspective.
The evaluators are also expected to verify student job placements while on the visit. The institution provides the evaluators with a list of students who were placed in jobs in their fields of study, along with contact information for the employers. Evaluators in theory are expected to telephone some of the employers to verify that the students were hired. Some evaluators simply did not make the calls, but reported that they had. In one instance, an evaluator was sitting with the institution’s placement director, who was ostensibly calling the employers to verify employment, but there was no effort by the evaluator to speak with the employer or to verify the person to whom the director was speaking. There were also employers who reported that the student had been hired, but had been terminated. Is it any wonder that job placement is at the center of the government’s allegations against the industry?
At one site visit, I encountered a retired law enforcement officer who was serving as Chairman of the Legal Studies Department, which offered both Criminal Justice and Paralegal degrees at the associate’s level. He had the educational credentials and the experience to administer the CJ courses and to advise the CJ students. That aspect of his job was stellar. However, he had no credentials or experience sufficient to administer a paralegal program or to advise paralegal students. I raised that point – much to the consternation of my fellow evaluators, who knew that the issue would delay our departure – but I felt a duty to the paralegal students. After some administrative back-and-forth, we came up with a work-around. A practicing attorney who taught there as an adjunct agreed to serve as assistant chair of the department and to advise the paralegal students. She made a special visit to the campus that day to sign an agreement to that effect, and the issue was resolved, at least to the satisfaction of ACICS. Personally I would have wanted to verify that she did actually take on the responsibility, but ACICS does not follow-up on matters like that.
Thus, while ACICS goes through the motions of verifying institutional compliance with published accreditation standards, the actual practice is very ineffective in that verification process. Evaluators have very little room within which to maneuver. They fear each other to some extent. They get only a snapshot of what the institution wants them to see. Some evaluators are only there for the perks. Some evaluators falsify their reports. There is a strong chilling effect on any evaluator who believes a citation (i.e. a failure to meet an accreditation standard) is warranted. Waldman asks who is regulating the for-profits, and she focuses on the upper-most level, and finds disturbing answers. At the ground level, where the information is gathered, the answers are even more disturbing.