CCSF Accreditation Crisis: Seven Years in the Making

Last week the Accrediting Commission for Community and Junior Colleges (ACCJC), which operates under the corporate entity the Western Association of Schools and Colleges (WASC), voted to end accreditation for the City College of San Francisco (CCSF) as of July 31, 2014. Unless reversed, the loss of accreditation would like force the 85,000 student college to shut down. CCSF would be the largest college to date to lose accreditation, and it is also the largest community college in California.

Update 8/21: Date corrected to July 31.

It might be useful to recap the process and issues that led to the current accrediting crisis. This summary is based on the accrediting body’s findings. In a later post I’ll address the counter arguments made by the school and faculty unions.

Spring 2006 Evaluation

The immediate story did not start in 2012 with the institution’s request for reaffirmation of accreditation and subsequent ACCJC evaluation, but rather started back in 2006. In the 2006 evaluation report the commission “validated that that the college meets the eligibility requirements for accreditation and complies with the standards of accreditation” and identified eight key recommendations.

Recommendations #2, #3, and #4 were “overarching concerns that should receive the college’s focused attention and emphasis”. The recommendations are summarized below.

• 1) Mission Statement: Regularly review and approve the mission statement in a discrete process
• 2) Planning and Assessment: Build planning and assessment efforts in an integrated process linked back to the annual budgets, including clear criteria for resource reallocation and / or program and service development, expansion, or termination
• 3) Student Learning Outcomes: Ensure that student learning outcomes are fully institutionalized as a core element of college operations, with specific focus on curriculum and program development
• 4) Financial Planning and Stability: Develop a financial strategy that will: match ongoing expenditures with ongoing revenue; maintain the minimum prudent reserve level; reduce the percentage of its annual budget that is utilized for salaries and benefits; and address funding for retiree health benefits costs
• 5) Physical Facilities Contingency Planning:Ensure the development of adequate contingency plans, which should be implemented in a timely manner in order to reduce potential exposure to losses
• 6) Physical Facilities Maintenance Planning: Include the future costs of operating and maintaining new and existing facilities in its planning models and allocate funds in a timely manner to ensure the effective operation of these facilities
• 7) Technology Planning: Bring all unit technology plans up-to-date, and develop a unified college-wide technology plan; this plan should be integrated with facilities and budget plans; funds for technology acquisition and maintenance, including regular replacement of outdated hardware, should be integrated into the institution’s budget
• 8) Board of Trustees Evaluation: Establish a method of self evaluation for the Board of Trustees, determine the schedule for this process, and complete self evaluations on a regular basis

Based on this evaluation, the ACCJC “took action to reaffirm accreditation, with a requirement that the college complete a Progress Report and a Focused Midterm Report”. In the letter, two areas were highlighted for further review.

• The Commission asked that the Progress Report be submitted in 2007 to specifically cover resolution of Recommendation #4 (Financial Planning and Stability).
• The Commission required a Focused Midterm Report in 2009 “which must give evidence of progress” on specific recommendations #2 (Planning and Assessment and #3 (Student Learning Outcomes).

2007 – 2010 Progress Report, Focused Midterm Report, Follow-up Report

In 2007 the college submitted a Progress Report which the commission accepted (note that accepting a report does not constitute declaring that the issue is resolved).

In 2009 the college submitted a Focused Midterm Report which the commission also accepted, however, they required a Follow-up Report in 2010 that “should demonstrate status to resolution of recommendations #3 (Student Learning Outcomes) and #4 (Financial Planning and Stability). As part of this 2009 letter, the commission gave the first clear warning that the college was in jeopardy of losing accreditation.

I wish to inform you that under U.S. Department of Education regulations, institutions out of compliance with standards or on sanction are expected to correct deficiencies within a two-year period or the Commission must take action to terminate accreditation. City College of San Francisco must correct the deficiencies noted by June 2010. [emphasis added] [snip]

Please note that the next comprehensive evaluation of City College of San Francisco will occur in Spring 2012.

In 2010 the college submitted the Follow-up Report which the commission accepted, however, the Commission also gave specific warnings about the financial planning specific to unfunded liabilities (retirement accounts).

Commission Concern Regarding Other Post Employment Benefits (OPEB)

In assessing compliance with Standard III.D Financial Resources, the Commission has a concern about whether the college’s financial resources are sufficient to support student learning programs and services and to improve institutional effectiveness. [snip] Provisions of Standard III.D requiring a level of financial resources that provide a reasonable expectation of both short-term and long-term financial plans to ensure that adequate cash or liquid resources will be available to pay for OPEB liabilities at the time those costs become due.

The Commission notes that colleges not making the minimum payment or Annual Required Contribution (ARC) are now accumulating unfunded liabilities that will require cash to be paid out when benefits are paid to retired employees. [snip]

Eventually, unless this liability is funded the colleges’ financial condition will deteriorate to a level that will make it difficult for colleges to meet the requirements of Standard III.D.

Spring 2012 Evaluation

In March of last year, ACCJC evaluated CCSF as part of re-accreditation, and there were clear overtones of this being a follow-up on the 2006 issues and 2009 warning. Indeed, the Commission structured part of the report based on the eight recommendation from 2006, and they included a judgement on whether CCSF had resolved the issues since 2006. In summary: zero recommendations were fully addressed, five recommendations were partially addressed (1, 2, 3, 7, 8), and three recommendations were not addressed at all (4, 5, 6).

• 1) Mission Statement: Partially addressed
• 2) Planning and Assessment: Partially addressed
• 3) Student Learning Outcomes: Partially addressed
• 4) Financial Planning and Stability: Not addressed
• 5) Physical Facilities Contingency Planning: Not addressed
• 6) Physical Facilities Maintenance Planning: Not addressed
• 7) Technology Planning: Partially addressed
• 8) Board of Trustees Evaluation: Partially addressed

The full report documented the new evaluation that in order to “fully meet each ACCJC Accreditation Standard and Eligibility Requirements [sic]”, the college must follow 14 recommendations as summarized by Nanette Asimov in the San Francisco Chronicle.

1. Revise the college’s mission statement.

2. Develop effective planning processes.

3. Assess the effectiveness of the institution.

4. Identify what students should learn in each course and assess the effectiveness of courses and programs.

5. Assess the effectiveness of student support services.

6. Evaluate all employees responsible for student progress.

7. Create a way to determine if there are enough qualified support staff and administrators.

8. Include the cost of running buildings in long-term financial planning.

9. Develop a plan for maintaining, upgrading and replacing equipment and securing information systems.

10. Use the mission statement to decide how to allocate resources; increase reserves to a prudent level.

11. Report financial information accurately and in a timely manner.

12. Provide leadership training for all employees and elected trustees.

13. Improve governance; eliminate barriers to decision-making.

14. Trustees should follow their own policies and bylaws.

Summer 2012 Show Cause Judgement

Based on this report, in July 2012 the Commission ordered that CCSF must Show Cause and issue a Show Cause Report by March 2013 as well as a Closure Report (the idea that since the campus may have to close, the planning process for this contingency should begin immediately. From the letter:

Show Cause is issued when the Commission finds an institution in substantial non-compliance with the Commission’s Eligibility Requirements, Accreditation Standards, or policies, or when the institution has not responded to the conditions imposed by the Commission. [snip] The burden of proof rests on the institution to demonstrate why its accreditation should be continued. [snip]

Show Cause was ordered for City College of San Francisco (CCSF) because the College has failed to demonstrate that it meets the requirements outlined in a significant number of Eligibility Requirements and Accreditation Standards. It has also failed to implement the eight recommendations of the 2006 evaluation team; five of these eight were only partially addressed and three were completely unaddressed. The College is reminded that an institution is expected to fully address all of the recommendations of a comprehensive evaluation before the next comprehensive evaluation visit occurs.

Needless to say, this order woke up CCSF, the Community College of California system, and local politicians.

Fall 2012 Independent Financial Review

In September 2012 CCSF contracted with the Fiscal Crisis & Management Team (FCMAT) to provide an independent financial analysis as part of their plans for dealing with the Show Cause. FCMAT found that there were indeed significant problems.

Fiscal Health Analysis

City College of San Francisco (CCSF) has not developed a plan to fund significant liabilities and obligations such as retiree health benefits, adequate reserves, and workers’ compensation costs. Further, it has been subsidizing categorical programs with unrestricted general fund monies regardless of the effect on the general fund, and has provided salary increases and generous benefits with no discernible means to pay for them. The college has also used temporary one-time measures to mitigate its operating deficits, thus deferring difficult decisions to the future. These deficiencies raise significant concerns regarding CCSF’s ability to maintain solvency because of the unknown outcomes of an upcoming local parcel tax measure and the governor’s November 2012 state tax measure referred to as Proposition 30.

Multiyear Financial Projection

CCSF’s 2012-13 tentative budget is balanced in terms of anticipated revenues and expenditures, but it assumes and depends on passage of the governor’s November 2012 tax measure. Most of the expenditure savings in the tentative budget are one-time concessions from the employee groups for 2012-13 only, which means that CCSF will again need to make reductions for 2013-14. Even with the passage of the governor’s tax measure, CCSF projects a $13 million shortfall in fiscal year 2013-14. CCSF cannot afford to wait and see if the local parcel tax is approved before implementing expenditure reductions. To maintain financial solvency, reductions for 2013-14 and beyond must be ongoing rather than temporary.

Spring 2013 Report and July 2013 Judgement

In March 2013 as required CCSF issues a Show Cause and Closure Report which ACCJC acknowledged.

In July 2013 ACCJC provided their judgement of the Show Cause Report in the letter.

After careful consideration, the Commission acted to terminate accreditation effective July 31, 2014. This date was chosen to provide the college with one year to deal with all of the possible ramifications of the Commissioners’ action, including time to arrange for teach out agreements that may be necessary so that students will be able to complete their certificates and degrees. The Commission may extend this date at its sole discretion if it determines that conditions warrant such action.

The Commission action to terminate accreditation is not yet final. City College of San Francisco has the right to request a review of the Commission’s adverse action in accord with the Commission’s Policy on Review of Commission Actions. If the decision of the Commission, following the review, upholds the termination of the institution, the institution will then have the right to appeal in accordance with the ACCJC Bylaws. [snip]

The Commission also reviewed the Draft Closure Report submitted by the College and found it did not provide sufficient detail to ensure orderly closure, if the loss of accreditation would cause the college to close, including adequate retention of student records and transcripts, and the ability of students to complete their educational programs. [snip]

The 2012 Evaluation Team Report, and the Commission’s action letter of July 2, 2012, provided City College of San Francisco with fourteen recommendations that, if followed, would help the institution come into compliance with accreditation requirements. The College has fully addressed two of those recommendations (Recommendations 6 and 9), and has resolved the deficiencies associated with those recommendations. The College has addressed and nearly resolved the deficiencies noted in one other recommendation, (Recommendation 3), which is expected to be fully implemented next year. However, eleven of the fourteen recommendations were not adequately addressed, including recommendations identified in the 2006 comprehensive evaluation as noted in the 2012 evaluation team report and Commission action letter. As noted above, the institution remains out of compliance with many Accreditation Standards.

The letter then calls out specific challenges of the governing structure of the school and the effects of resistance to change in response to the accreditation challenge.

The evidence found in the institution’s Show Cause Report, the Show Cause Evaluation Report, and the testimony provided by the college representatives indicate that disagreements and undefined relationships still characterize the institution’s (new) governance system, and significant divisions in the faculty and the wider institution prevent the institution from responding effectively to requirements of accreditation and providing a sustained quality education. Testimony indicated that, within the college, some faculty feel strong pressure, even intimidation, to defer to designated faculty leaders even when they feel that a different approach should be considered. While some groups work to make needed changes, others militate against change The acrimony is evident in behaviors at governing board meetings among other venues.

The letter closes its case with reference to the financial management deficiencies.

Finally, City College of San Francisco has still not addressed, and appears to lack the capacity to address, the many financial management deficiencies (Standard IIID) identified by the 2012 Evaluation Team Report. The College has very significant internal control deficiencies that were largely unaddressed over the last year. The College contracted with the Fiscal Crisis Management Team (FCMAT) in 2012 and the team made 53 recommendations, most of which the Show Cause Evaluation Report found to be unaddressed as of 2013. [snip] The institution’s inability to identify the costs associated with all of its sites and centers, identified as a problem in 2006, still remains.