by Christopher C. Walck, Associate Chief Executive Officer/Director of Accreditation

The sixth and last most frequently cited criterion for the calendar year 2002 addresses the issue of NACCAS' Cancellation and Settlement Policy and Minimum Refund Guidelines. As you will recall, this criterion was also one of the most frequently cited criterion for 2001. Standard VII, Criterion 3 states:

The school documents that it meets all applicable state regulations dealing with refund of tuition and fees to students who withdraw, and that it also meets the NACCAS Cancellation and Settlement Policy and Minimum Refund Guidelines.

Criterion 3 addresses two separate issues. First, schools are required to have a refund policy that complies with either state mandated requirements or NACCAS' Cancellation and Settlement Policy and Minimum Refund Guidelines. Second, schools are required to conduct refunds in compliance with their published policy.

Policy Issues

1. Frequently, a school will receive a limitation because it is lacking one or more of elements of NACCAS' policy. One way of ensuring that your policy complies with NACCAS' policy is by using the "Cancellation and Settlement Policy Checklist" that requires you to identify where each of NACCAS' requirements are listed in your policy.
   
   
2. If the school has a state mandated refund policy, the school is required to use that policy in the place of NACCAS' policy. In those instances where the state has a mandated refund policy, the school must demonstrate that its policy is in compliance with state requirements.

Refund Practices

1. Criterion 3 is a documented criterion, therefore you are required to demonstrate that you have complied with your school's refund policy. Regardless of when a student withdraws from school, or is terminated for failure to comply with the school's policies, you must conduct a refund calculation. Frequently, a school will assume that because the student is not due a refund, but instead owes the school money, that they are not required to calculate a refund. Whether or not a student is due a refund, a school must perform a refund calculation in accordance with its published refund policy to determine the amount of money owed to either party.
   
   
2. During the on-site evaluation process, the school owner/administrator evaluator will be responsible for reviewing a random sample of withdrawn student files. In order for the evaluator to review the calculations for compliance with the school's published policy it will be necessary for you to have available:
   
   
   • a roster of all students who have dropped or been terminated within the last twelve months;
   • each student's enrollment agreement;
   • attendance records;
   • documentation of any official leaves of absence;
   • copies of all satisfactory progress determinations;
   • ledger of payments credited and due;
   • a copy of the refund calculation sheet; and
   • copies of the front and back of refund check(s) negotiated by the bank.
   • Frequently a limitation will be cited because the school's refund calculation sheet that does not correspond with the supporting documentation, such as the last date of attendance, withdrawal date, or the number of hours completed. In addition, limitations are frequently cited because the calculations are done incorrectly or late.
     
     
3. The school must have a policy for determining unofficial withdrawals from the program in order to determine if a refund has been paid in a timely manner. If the school's policy is to withdraw a student after thirty consecutive days of non-attendance, or if the school determines unofficial withdrawals the first day of each month, the team will review the withdrawn/terminated student's record to ensure that the school is following its written policy.
   
   

As always, if you have a question on how to comply with accreditation requirements contact the NACCAS office for assistance.