Accreditation: Is it a game of Chutes and Ladders?

By Sara Bloomberg

The Guardsman

A child picks up a die. She shakes it in her hand for a few seconds before tossing it hopefully onto the game board and then closes her eyes for a moment.

When she opens them, a five appears in front of her. She holds her breath and  advances… One, two, three, four, five… landing her at the top of a long slide that takes her all the way back to the beginning of the game.

All that hard work, and for what? It’s a frustrating game of Chutes and Ladders and there’s no rhyme or reason to it—only the whim of the die and lady luck.

It’s also how the process of accreditation appears to work, at least under the auspices of the Accrediting Commission for Community and Junior Colleges. And the United States Department of Education seems to agree.

As City College instructors attended professional development workshops the day before fall semester began, news broke that the Department of Education had determined the commission was out of compliance with federal regulations.

The department cited four problem areas, including a lack of clarity in the commission’s evaluation of City College.

It is “difficult to ascertain what a recommendation represents—an area of non-compliance or an area for improvement,” the department wrote in its letter to the commission. “This lack of clear identification impacts the [commission’s] ability to provide institutions with adequate due process.”

This is particularly poignant because the commission has threatened to revoke the school’s accreditation next summer.

In July 2012, the commission placed City College on show cause status—its most severe sanction before terminating accreditation.

The department also cited lax internal controls to prevent conflicts of interest, too many administrators (and not enough faculty) on the visiting teams responsible for evaluating City College and not following proper procedures for applying sanctions, such as show cause.

Now the commission has one year to correct its behavior or the department could consider terminating its license to operate.

The commission released a statement that expressed disappointment with the decision and stated that it will correct some factual errors when it submits a response to the department this fall.

Additionally, the commission accuses the department of surreptitiously enforcing a new rule that lacks clarity.

“It also appears the department has developed a new requirement that is not included in federal regulations or in the [guidelines],” the letter states and continues that, “directions to accreditors remain vague, and will require clarification.”

A taste of their own medicine

It’s a twist of fate that vindicates what many in the college community having been saying since the commission placed City College on show cause in July 2012—that there’s a problem with how the commission operates and makes decisions.

“We’ve all known that something is very wrong here,” said Alisa Messer, president of the American Federation of Teachers Local 2121. “To have it validated and scrutinized … has really given people a boost.”

In fact, the Department of Education investigated the commission after the California Federation of Teachers filed a nearly 300- page complaint in April that pointed out the problems in the department’s letter.

 Department of Education officials confirmed that the agency has no authority to reverse any decisions made by an accrediting commission, but their decision carries heavy political weight, particularly as the college moves into the review and appeals process.

“CCSF can and likely will appeal the ACCJC decision, and the department’s letter could become part of their appeal,” the Department of Education wrote in an email to The Guardsman.

Judge, jury and executioner?

Before the Department of Education’s August decision letter, the chances of getting a fair trial for City College seemed bleak.

The commission oversees all aspects of the review and appeals process, which the department doesn’t consider a barrier to due process.

“Federal regulations require that the appeals body not include any members of the original decision-making body that took the adverse action” against City College, the department wrote in an email.  “Also, the agency allows the institution to challenge the appointment of one or more appeals body members.”

If the commission staff determines that City College has a valid claim for review, it will appoint a review committee. However, the commission’s chair—currently Sherrill Amador—has the power to approve or deny the request and City College is responsible for paying for the cost of the review, according to the commission’s “Accreditation Reference Handbook.”

Despite that, many people see the department’s decision letter as strong evidence that the commission simply cannot ignore.

However, faculty are frustrated with interim Chancellor Thelma Scott-Skillman and Special Trustee Robert Agrella for not including them in drafting the request for review.

Neither the American Federation of Teachers Local 2121 or the California Federation of Teachers have been contacted by the City College administration regarding the request for review, according to an Aug. 15 letter from Messer to both Scott-Skillman and Agrella.

“We are surprised by this occurrence because we have already filed a lengthy complaint against the ACCJC, and have information concerning the actions of the commission, which is relevant to the college’s request for review,” Messer wrote.

College officials had previously promised to post the request online.

Although requests for comment from The Guardsman were not returned before press time, Agrella apologized in an email to faculty on Aug. 19 for prematurely promising that the documents would be made public and explained that he later learned this was not allowed.

“We cannot share the review documents because we have been clearly informed by the Commission that all parts of the appeal process, including the review, are to be treated as confidential,” Agrella wrote in the email.

However, he also announced that the Department of Education’s letter would not be included in the review—a decision that is sure to upset a lot of people.

His reasoning? That both the college and the commission consider the faculty’s complaint and the Department of Education’s letter to be “third party communications,” and that using the letter would amount to an attack on the commission that college administrators don’t want to make.

“If we were to use these arguments they would become the college’s official position and therefore the college would join in the attack on the Commission,” Agrella wrote. “ If our review document joins the attack on the Commission, I believe that the review and appeals process will be unsuccessful.”

Enrollment woes

In the meantime, the college administration waged a public relations campaign this summer to combat the confusion and fear caused by the commission’s decision.

Compton Community College suffered a similar fate, and it hemorrhaged students until its accreditation was officially revoked in 2006.

Although a much smaller school than City College—which is the largest community college in California—Compton was down to about 2,000 students when El Camino Community College took over to save it from closure.

Six years later, the numbers were dramatically higher.

“Our Compton Center right now has about 10,000 students,” Community Relations Director for El Camino Ann Garten told the SF Bay Guardian in August 2012.

Garten also explained that many of the former Compton students most likely dropped out of school altogether.

“We looked at two or three colleges around Compton and none of us had a significant increase in students from the Compton district coming here,” Garten said. “So our president’s concern was, wow, we now have individuals that aren’t going anywhere. We can’t let this happen. We have to step in.”

It’s unlikely that another community college district would be able to absorb City College.

To help boost enrollment at City College, many faculty members and their students took to social media this summer to promote their own classes and departments.

“Dear Friends, As you know, City College is struggling to meet its enrollment goals. The most valuable and unique classes are also the ones that are likely to get cancelled if we don’t get more students,” one appeal on Facebook read.

The S.F. Examiner even published a story about a student who decided to commute to City College from Sacramento this semester to help the school out.

Morale appears to be rising school-wide.

“I really feel like student morale is surprisingly high,” Student Trustee Shanell Williams said. “With this news from [the Department of Education], people are really seeing things in a different light and feeling hopeful that we will see a reversal of the decision by [the accrediting commission].”

At one point, enrollment numbers for credit courses were inching toward reaching 16 percent below last year’s number for the same time period, according to the daily enrollment reports.

By the first day of classes, the school gained back more than five percentage points, bringing enrollment in credit courses to 10.2 percent below target.

The school receives state funding based on an averaged number of credit hours, known as “full time equivalent students,” or FTES.

Figures for non-credit classes weren’t available by press time, but if non-credit classes experienced a similar drop in enrollment, that would indicate the school is serving around 8,500 fewer students this semester, or approximately 76,500 total students.

“It is an act of defiance at this point to take more classes at City College,” Messer said. “It’s a win-win situation. It helps the college, and additional education usually helps the person.”

Gina Scialabba contributed to this report.