the role of compliance and ethics in safeguarding the integrity … · 2014. 9. 3. · the role of...

The Role of Compliance and Ethics

in Safeguarding the Integrity of

Degrees and Accreditation

in Higher Education

SCCE’s Higher Education Compliance

Conference

June 13, 2011

Rhonda L. Bishop, CCEPChief Compliance and Ethics Officer

University of Central Florida

Jennifer L. Burruss, CCEPInterim University Compliance Officer

Virginia Commonwealth University

Ellie A. Fogarty, CCEPVice President

Middle States Commission on Higher Education

Disclaimer:

The content of this presentation does not necessarily represent or reflect

the views of the organizations with whom the presenters are affiliated.

University of Central Florida

• Nation's second-largest university located in Orlando, FL

• 12 colleges including the newly established College of Medicine

• More than 56,000 students in 216 degree programs

• Academic and research leader in optics, modeling and simulation, • Academic and research leader in optics, modeling and simulation,

engineering and computer science, business administration,

education, science, hospitality management and digital media

• Carnegie Foundation designations “Research University, High

Research Activity” , “Curricular Engagement,” and “Outreach and

Partnerships”


• VCU Rams made it to the NCAA 2011 Final Four in Houston, TX

• Located on two downtown campuses in Richmond, VA

• School of the Arts located in Qatar

• Carnegie Foundation designation “Research University, Very High Research Activity”

• More than 32,000 students in 211 certificate and degree programs in the arts, sciences and humanities

• VCU Medical Center is a nationally recognized leading academic medical center and the region’s only Level 1 Trauma Center

• More than 18,000 faculty, staff and hourly employees, including 1,927 full-time instructional faculty and 8,586 classified staff, make VCU and the VCU Health System the city’s single largest employer

Middle States Commission on

Higher Education

• Located in Philadelphia, PA

• MSCHE is a voluntary, non-governmental, membership association that is dedicated to quality assurance and improvement through accreditation via peer evaluation

• Accredits over 500 degree-granting colleges and universities in NY, • Accredits over 500 degree-granting colleges and universities in NY, NJ, PA, DE, DC, MD, Puerto Rico, and the US Virgin Islands

• One of 6 regional accrediting agencies throughout the US

• Recognized by the U.S. Secretary of Education as a reliable authority concerning the quality of the education offered by the institutions of higher education we accredit

Overview

• Recent degree scandals, lessons learned and what

compliance and ethics professionals need to know

• Leveraging compliance and ethics activities to

demonstrate institutional effectiveness and the demonstrate institutional effectiveness and the

integrity of the degree granting and accreditation

process

• Gaining recognition for compliance and ethics

programs and meeting accreditation agency

expectations for program assessment

Major Degree Scandals in 2008

Universities Involved

• Virginia Commonwealth University

• West Virginia University• West Virginia University

• Carnegie Mellon University

BACKGROUND

First Identification of

Student Name by the Media

9


• Failure to obtain 30 credit hours in residence

• No exception to that requirement was requested or approved

• Student afforded preferential treatment • Student afforded preferential treatment throughout the degree granting process

• More than one employee overlooked or disregarded institutional policies and procedures

• President’s name invoked in allegations

VCU Findings

• Investigation of over 15,000 degrees demonstrated only two degrees did not meet residency requirement

• VCU met all SACS requirements for policies and procedures

• Investigation found no systemic failures• Investigation found no systemic failures

• Identified opportunities to strengthen process

• Two university deans resigned and a faculty member provided with a letter of counsel and caution

VCU Corrective Actions

• Revised degree revocation policy

• Strengthened language on graduation application form

• Communication of student’s responsibilities to understand and satisfy graduation requirements

• Developed transfer and advising manual• Developed transfer and advising manual

• Developed degree audit function and registrar audit

• Code of Ethics, Creed and Code of Conduct training

• Compliance and Audit added annual reviews to work plan

West Virginia University

• Awarded a retroactive degree to a former executive MBA student due to uncertainty surrounding the student’s records

• Records later proved to include the falsification of gradesfalsification of grades

• Provost and dean of the business school resigned

• Later in June of 2009 the president resigned

Carnegie Mellon University

• Error in judgment involving the approval of

excessive transfer credits and excessive units

for independent study in lieu of course work

for a student who received a master’s degreefor a student who received a master’s degree

• Dean of the Heinz School of Public Policy and

Management resigned

LINKS TO KEY DOCUMENTS

� VCU Report to SACS:

http://www.provost.vcu.edu/pdfs/SACS_REPORT_9-5.pdf

� JLARC Report:

15

� JLARC Report:

http://jlarc.state.va.us/reports/Rpt373.pdf

� WVU Report:

http://provost.wvu.edu/provost/AACRAO%20Consulting%20Final%20Official%20Report.pdf

Integrity of Degrees

and Degree Programsand Degree Programs

Conducting Compliance Audits of the

Degree Granting Process

Why It Matters

• Failures in the degree granting process and in

meeting accreditation requirements may

result in

�Loss of accreditation�Loss of accreditation

�Sanctions

�Adverse actions for the university

�Risks to reputation and loyalty to the university

�Loss of eligibility to receive Federal Title IV funds

Why perform compliance audits?

• Issuance of degrees is a university’s “main product”

• Elevate the importance of the integrity of the university’s degree granting process

• Address complacency with the degree granting and • Address complacency with the degree granting and accreditation processes and periodic assessments

• Promote monitoring at each step in the process

• Raise awareness of accountability and responsibility

Areas to audit

• Admissions

• Transfer of credits

• Advising • Advising

• Grading, program and degree requirements

• Graduation application, degree audit and

award

Questions to ask?

• Do we have the appropriate policies covering each of these areas?

• Do our students understand they are responsible for knowing our academic

policies and procedures?

• Do our faculty know and understand our academic policies and procedures?

• Do our advisors know and understand our academic policies and

procedures?

• Does our graduation application require each signatory to certify that the

information is correct and that the student met both university and

program requirements?

• Do we have a policy to revoke a degree for any reason?

Questions to ask?

• Do faculty, staff and advisors receive training?

• What is included in review of the graduation application?

• What is the procedure when a problem or mistake is identified?

• Is there a policy and procedures for the timely notification and subsequent evaluation and resolution of degree issues and revocation of degrees?evaluation and resolution of degree issues and revocation of degrees?When do we contact the following:

– Dean

– Provost

– President

– Governing Board

! Do we conduct monitoring at each step?

Admissions

• All degree program admission processes meet

overarching university standards

• Test sample meets university and program policies and

procedures

• Admission decision process documented and maintained

according to requirements

• Most importantly - Admission process conducted without

bias or influence at both the university and program level

• Conduct interviews

Transfer of credits

• Transfer policies and procedures:

– Documented

– Easily accessible

– CommunicatedCommunicated

– In compliance with accreditation requirements

– Consistently applied

• Exceptions documented and approved

• Test sample meets university and program policies and procedures

Advising

• Advising policies and procedures

– Documented

– Easily accessible

– Communicated

– Consistently applied

• Advisors are trained and understand the importance of documenting • Advisors are trained and understand the importance of documenting exceptions/waivers/substitutions

• Test sample from advising file demonstrates appropriate approvals and documentation

• Student’s “official” student record matches program files

! Important that “degree audits” are conducted early enough for students to take additional courses if audits are used during advising process

Grading, Program and Degree

Requirements

• Grade change/appeal policy:

– Documented

– Accessible

– Communicated

– Consistently applied– Consistently applied

• Test sample:

– appropriate approvals for changes, exceptions, waivers, substitutions

– Program requirements consistent with university requirements and appropriately approved

– Recommend conducting interviews with faculty and staff

Graduation Application, Audit

and Award

• Language on graduation application communicates responsibility and accountability

• Application is complete and accurate

• Appropriate signatures are present

• Degree audit conducted

• Information on degree application matches “official” student record – any discrepancies addressed appropriately

• Correct degree conferred

! Failure to perform due diligence and confusion over responsibility/accountability increases the risk of improperly awarding a degree

Every compliance and ethics officer should

have a good understanding of the degree

granting process and the accreditation process

at their institution including any related

policies, procedures or external requirements.

If a university encounters issues in either of

these areas….nothing else matters!

Compliance Audit of Internal

Assessment for AccreditationAssessment for Accreditation

Philosophy of Accreditation

• The university is engaged in an ongoing

program of improvement and is able to

demonstrate how well it fulfills its mission

• The university is expected to document the

quality and effectiveness of all its programs

and services

Fundamental Characteristics of

Accreditation

• Accreditation requires institutional commitment and

engagement

• Accreditation requires institutional commitment to

the concept of quality enhancement through the concept of quality enhancement through

continuous assessment and improvement

• Chief Executive Officer (President) must certify

compliance with accreditation standards

Benefits of Accreditation

• Provides assurance for the integrity and quality of

the university’s degree granting programs

• Accreditation demonstrates accountability

• Reputation of quality, high standards and the ability • Reputation of quality, high standards and the ability

to improve

• Federal government requires accreditation for a

university to receive Federal Title IV funds


Assessment for Accreditation

�Compliance audit of internal assessment to

meet accreditation requirements provides

• Assurance that the university is committed to the Assurance that the university is committed to the

principle of integrity in the governance and

operation of the university

• Necessary control to protect the university’s

accreditation

Questions to ask?

• Who has responsibility for the accreditation

process?

• Where are we in the accreditation cycle?

• Does a time line exist?

• What process is in place to manage the

accreditation life cycle (e.g. collection of data)?

Questions to ask?

• Were concerns raised during the last

assessment? If yes, have they been

addressed?

• Are all processes documented?• Are all processes documented?

• Are sufficient resources allocated to

accreditation?

• Most importantly, is accreditation a priority ?



�Compliance audit evaluates the university’s compliance with accreditation requirements and standards including the university’s

�Commitment to accreditation principles, �Commitment to accreditation principles, requirements and standards

�Evaluation of its mission statement to determine whether it accurately reflects its values, aspirations, mandates and commitments to constituent groups



�Compliance audit evaluates (cont.)

�Institutional goals, programs and services and the

extent they are in alignment with the university’s

missionmission

�Compliance with accreditation principles in

evaluating the university’s programs, operations

and services




�Level of performance and whether it challenges

the university to move beyond the status quo or

beyond minimal compliance requirementsbeyond minimal compliance requirements

�Commitment to the concept of accreditation as an

ongoing rather than an episodic event

�Quality enhancement plan and impact on the

quality of student learning




�Ability of databases to provide ongoing documentation of improvement and compliance

� Involvement of the university community in � Involvement of the university community in successfully meeting accreditation requirements

�Compliance audit provides added assurance to individuals certifying compliance with accreditation standards



�Compliance audit evaluates internal

accreditation processes

�Processes need to be institutionalized rather than

personality drivenpersonality driven

�Processes need to be documented for continuity

and succession planning

Accreditation and Assurance

• Accreditation assures the public of the

integrity and quality of the university’s degree

programs and degrees

• Internal assessment and compliance audits • Internal assessment and compliance audits

give the university assurance that the degree

granting processes and requirements for

accreditation are met on an ongoing basis

Recognition for Compliance and Ethics

• The eighth element of an “effective compliance

and ethics program” is the periodic evaluation of

a program

• Accreditation cycles offer an opportunity for a • Accreditation cycles offer an opportunity for a

compliance and ethics professional to review his

or her own program over a number of years and

identify improvements

Regional Accreditation

• History and Context

• Evolution and Future

• Accrediting agency expectations for member

institutionsinstitutions

• Federal government expectations for

accrediting agencies

• Relationship to compliance and ethics

Accrediting Agency Expectations

• Accrediting agencies expect institutions to

answer the following questions:

– Given our mission, how well are we doing what

we say we are doing?

– In light of our mission, how are we complying with

accreditation standards?

– Are we satisfied with the results?

– If not, what are we going to do about it?

Accrediting Agency Expectations

• Mission-centered focus

• Compliance with Standards

• Self-study reports

• Peer review process• Peer review process

• Periodic review

– But policies, processes, systems, and structures must be in place to ensure ongoing compliance with standards between reviews

Middle States Commission on

Higher Education

• Utilizes 14 Standards of Accreditation called “Characteristics of Excellence” and 10 Requirements of Affiliation to evaluate institutions

• Maintains a 10-year cycle of review, beginning with a self-study and on-site evaluation visit, and followed by a Periodic study and on-site evaluation visit, and followed by a Periodic Review Report five years later

• Institutions may be reviewed in conjunction with follow-up reporting or substantive institutional change, or at the initiation of the Commission, based on developments within the institution

MSCHE-Specific Standards & Compliance

• Governance– Demonstrating the role of the governing body in policy

development

• Integrity– Demonstrating compliance with an institution’s own

policiespolicies

• Institutional Assessment– Demonstrating how an institution meets its own goals and

complies with Federal and State regulations

• Student Support Services– NCAA, Federal Financial Aid regulations

Federal Expectations for Accreditors

• Includes 34 CFR Part 602 and some of 600 and

668

• Requires agencies to have Standards in 602.16

– “that are sufficiently rigorous to ensure that the – “that are sufficiently rigorous to ensure that the

agency is a reliable authority regarding the quality

of education or training provided by the

institutions or programs it accredits”

Standards Accreditors Must Have

• Student achievement

• Curricula

• Faculty

• Facilities

• Fiscal and administrative capacity

• Measures of program length and the objectives of the degrees or credentials offered

• Record of student complaints received by, or available to, the agency

Fiscal and administrative capacity

• Student support services

• Recruiting and admissions practices, academic calendars, catalogs, publications, grading, and advertising

the agency

• Record of compliance with the institution’s program responsibilities under Title IV (based on student loan default rate, audits, reviews, etc.)

Example of a Required Standard

• Measures of program length and the

objectives of the degrees or credentials

offered [602.16(a)(1)(viii)]

– When an agency is reviewed, it is expected to – When an agency is reviewed, it is expected to

demonstrate that its standards ensure “that any

awarded academic credits/degrees/credentials

conform to commonly accepted practice,

including time invested and content mastered”

New Federal Regulations for Higher Ed

• Higher Education Opportunity Act of 2008

• New Requirements for Accreditors

– Review transfer of credit and student identity verification policies

– Review assignment of credit hours– Review assignment of credit hours

• New Requirements for Universities

– State authorization

– Misrepresentation

Example of a New Requirement

• Misrepresentation [34 CFR 668.71 to 75]

– Any false, erroneous, or misleading statement made by

the institution directly or indirectly to a student,

prospective student, member of the public, accrediting

agency, state agency, or to USEDagency, state agency, or to USED

• Substantial misrepresentation

– Any misrepresentation on which the person to whom it

was made could reasonable be expected to rely, or has

reasonably relied, to that person’s detriment

Example of a New Requirement

• Misrepresentation relates to

– Nature of the educational program

– Nature of financial charges

– Employability of graduates – Employability of graduates

– Relationship with USED

• Schools may not describe Title IV participation in

a way that suggests approval or endorsement by

USED of the quality of its educational programs

Relationship to Compliance & Ethics

• SCCE defines compliance as

– “the process of meeting the expectations of

others. More specifically, it is the process of

helping professionals understand and meet the

expectations of those who grant us money, pay for expectations of those who grant us money, pay for

our services, regulate our industry, etc.”

• A very natural fit!

Benefits for the University

• Compliance with accreditation standards and requirements provide

�Access to Federal Title IV funds

�Access to certain Federal grants

�Ease in transfer of credit for students�Ease in transfer of credit for students

�Assurances of quality for the public, employers, and graduate schools

�Membership in a prestigious community of higher education

Recognition for Compliance & Ethics

• Accreditation reviews can highlight the work of

well-designed and highly-functional compliance

and ethics programs

• Compliance and ethics programs help institutions • Compliance and ethics programs help institutions

meet accrediting agencies’ expectations for

institutional assessment and continuous

improvement

Thank You!

Questions?

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