CCSF Accreditation Crisis: The Dissenting Voices

I recently wrote about City College of San Francisco (CCSF) and its impending loss of accreditation, which would essentially shut down the largest community college in California (85k students).

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 June 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.

The rest of the post walked through the seven years of history that led to the current crisis. In essence, CCSF was notified originally in 2006 by ACCJC that they were potentially out of compliance on three issues.

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).

But this is all one side of the story – the view according to the accrediting agency. What are the dissenting views?

Emerging Consensus from Institution and Political Leaders

There have been many complaints about the ACCJC process and decision, and the vast majority that disagree with the decision have originated from faculty and faculty unions. Despite their concerns over the potential closing of such a large college, most non-faculty groups have essentially supported the process.

• CCSF and the California Community College system have essentially agreed with the ACCJC findings and are trying to make progress and convince ACCJC to reconsider their decision based on changes being implemented.
• San Francisco Mayor Ed Lee and state government officials (a generalization, as they are not all in lockstep) mostly agree with findings and are seeking a resolution based on changes.

These groups (CCSF, CCC, San Fran mayor, state government) are all coalescing around the granting of special powers to Bob Agrella, Special Trustee.

The California Community Colleges Board of Governors voted unanimously Monday to elevate the special trustee overseeing City College of San Francisco, giving him extraordinary powers to assume control and management of the troubled community college in place of the locally elected Board of Trustees.

Primary Arguments From Faculty Groups

Faculty groups, however, are the most vocal in actually opposing the ACCJC decision.

• The California Federation of Teachers has complained the loudest, including filing a 280-page complaint as a “third party comment” (on behalf of CFT, but not on behalf of CCSF).
• The American Association of University Professors has not gone so far as to oppose the process or decision, but they are supporting people trying to save CCSF and are urging ACCJC to reconsider their decision.
• There have been numerous faculty as well as students attacking the decision.

Attorney Robert Bezemek summarized the CFT complaint in this 27 minute video.

The above dissenting voices strongly attack ACCJC, freely use the dreaded n-word (neoliberal), and try to get the case thrown out on technicalities of process. However, none of the previous complaints actually address the specific findings of the accrediting review and call out that ACCJC was wrong in its judgement.

The Most Significant Argument Against ACCJC

In my opinion, the best argument against the ACCJC decision to revoke accreditation was lodged by Martin Hittelman, former president of the CFT’s Community College Council. Hittelman lays out some pretty strong arguments against the ACCJC. His main argument is that ACCJC no longer follows the original intent of accrediting process. (all emphasis in original)

The goal of accreditation, according to the United States Department of Education, “is to ensure that education provided by institutions of higher education meets acceptable levels of quality.” In the Special Edition of the February 2001 ACCJC News it is pointed out that “In achieving and maintaining its accreditation a higher education institution assures the public that the institution meets standards of quality, that the education earned there is of value to the students who earn it, and that employers, trade or professional-related agencies and other colleges and universities can accept a student’s
credentials as legitimate.”

The ACCJC does not value colleges for their quality of instruction, but instead the ACCJC issues sanctions that are based on the successful performance of excessive documentation and data gathering, reviews of policy and procedures, and adherence to education practices that are not based on scientific studies.

Hittelman goes on to argue that ACCJC’s focus on Student Learning Outcomes goes beyond their charter, and that this practice is not widely accepted. Note that lack of SLOs was one of the original three complaints in 2006.

Article 1, Section 2 of the ACCJC Bylaws makes clear that the intent of the Commission is to require that colleges have “clearly defined objectives appropriate to higher education; has established conditions under which their achievement can reasonably be expected; appears in fact to be accomplishing them age 6substantially; it is so organized, staffed, and supported that it can be expected to continue to do so; and demonstrates that it meets ACCJC’s Eligibility Requirements and Accreditation Standards.” In short, the role of the ACCJC, as seen by the ACCJC, is to force colleges to spend enormous quantities of time demonstrating that they are properly (in the eyes of the Commission) organized while leaving less time on efforts to actually offer quality programs of instruction.

Approaches to evaluation such as Measurable Student Learning Outcomes (SLOs), that are not recognized as model standard practices by the majority of college educators as illustrated by faculty resistance to the imposition of the measurable student learning outcome methodology, are imposed on the colleges using the threat of sanction.

SLO’s are written to describe what specific knowledge and skills a student should have and be able to demonstrate at the conclusion of a course, program, and/or degree. SLO’s are to be used to provide data collection to measure student academic success. The implementation of SLO’s requires considerable work and effort. In addition to the tests given by instructors to determine how well a student is doing in a class and what grade should the student earn, SLO’s are used to determine whether the specific “outcomes” have been achieved. The data from the SLO’s is then supposed to be used to determine whether the classes are succesful in terms of student success .The visiting teams do not report on the success of the various SLO’s.

The problem with SLO’s in the eyes of many instructors is that they do not lead to better teaching and learning and are a very big waste of time. Instead they tend to lead to a standardized curriculum that does not address the full needs of the students. Such important elements as motivation,critical thinking, interest, creativity, and the ability to learn on one’s own are difficult if not impossible to measure with SLO’s – and as a result become less important in the minds of those who would rate educational qualitybased on SLOs.

34 Code of Federal Regulations (CFR) 602.13 require that an accrediting agency “must be able to demonstrate that its standards, policies, and accreditation decisions are widely accepted in the United States by educators and educational institutions, licensing bodies (if appropriate), practioners, and employers of graduates for accredited institutions/programs.” The ACCJC is out of compliance with this fundamental requirement. Their approach to governance, planning, coordination, fiscal responsibility, and research is not widely accepted either in the California community colleges or across the nation. In fact, I have found no evidence that suggests that the ACCJC has attempted to demonstrate that its standards, policies and decisions are widely accepted. To the contrary, opposition by the Academic Senate, faculty unions, the California Community College Consultation Council, and the RP Group underlines the general opposition to their policies and practices.

The other huge issue raised is the shocking preponderance of sanctions given by ACCJC compared to their peer agencies.

From 2003 to 2008 the six United States regional accrediting bodies issued a total of 126 sanctions to community colleges in the United States. 112 of these were issued by the ACCJC under Beno’s direction. ACCJC has continued to be out of step with the other accrediting agencies. From June 2011 to June 2012 the ACCJC issued forty-eight of the seventy-five sanctions (64%) issued nationwide. The community colleges in California represent about 19% of the community colleges accredited nationally. In short, the 19% of the colleges nationwide that are under ACCJC generated 64% of the national sanctions.

In 2013 the ACCJC continued its assault on California’s community colleges when it sanctioned 10 out of 23 (43.4%) colleges before it in January of 2013 and 10 out of 21 (47.6%) colleges in June of 2013. Their action included putting College of Sequoias on SHOW CAUSE (the college must prove that it should not have its accreditation removed) and removed the accreditation from City College of San Francisco effective July 2014.

Dissension Will Not Be Tolerated

There is another troubling dissent, this time from a former CCSF trustee, Rafael Mandelman, who originally campaigned to help fix the school but now believes ACCJC is the real problem.

He said a turning point for him came in April when a visiting accreditation team quizzed him extensively about an earlier opinion piece he’d published in March rebutting another piece by a former federal education official defending the accrediting commission’s strict approach.

The visiting team’s “take was that my piece was a troubling violation of the accrediting standard that the trustees speak with one voice,” he said. (The standard for college governance says, in part: “Once the board reaches a decision, it acts as a whole.”)

Mandelman said he understood the standard was meant to encourage effective governance, which he acknowledged was often lacking among the bickering trustees.

But he said he was amazed that the visiting team suggested his essay violated the standard.

“I don’t think accreditation requires elected officials to give up their First Amendment rights,” he said. “And if that’s what the standards require, there’s a problem with the standards.”

The article in question was a response to Bob Shireman’s op-ed that described confusing governance as still preventing CCSF from reforming (written in Nov 2012). Shireman argued against the tendency to view ACCJC as a villain and instead look at the broken system of governance at CCSF and legal requirements from California. Mandelman argued against Shireman, noting the big changes CCSF and its trustees were making and that Shireman is too focused on faculty power. While I think that Mandelman creates a straw man argument (Shireman was arguing against the complicated system of governance, and not against any sense of faculty power), it is very troubling if ACCJC feels that he cannot even speak his mind in public. Especially since Mandelman’s conclusion is that CCSF was reforming and that it was a necessary reform.

Notes

In my opinion, Hittelman has laid out a strong case against ACCJC processes with some serious complaints. While there is too much invective in the document, there are also real challenges on the merits of accrediting agency charters and observed disparities with peer agencies.

However, even Hittelman does not address the core issue of financial stability, which the San Francisco Chronicle has documented.

• In summer 2012, a state audit showed that the college was near bankruptcy.  Despite the warnings of ACCJC since 2006, CCSF trustees “were clueless” of the problems.
• CCSF trustees in 2007 discovered $40m in contracts never disclosed to the board, and 64 boxes of unpaid invoices.
• A new review in June 2013 showed that 125 people had access to the payroll system (too many to control, leading to risk of unauthorized wage changes) and that it will take 5 months to sort out all the cases of people being overpaid.

These are all real financial stability issues, and they align with the 2006 and subsequent findings from ACCJC. CCSF still has not addressed these problems, and none of the dissenting voices address this problem.

Reading all the dissenting opinions have convinced me that ACCJC has some real problems, but none of them have convinced me that CCSF has addressed legitimate accreditation findings.